Covid 19: Starting Again After Lockdown
As the partial lockdown continues many organisations are starting to look at when and how they can reopen and relaunch their activities. One of our partner insurers Ansvar have produced a useful resource “Getting back to work after lockdown”. Part of the resource is shared below. As guidance is constantly changing, check for updates at www.gov.uk/workingsafely.
From Ansvar: COVID-19 Secure – Getting back to work after lockdown
Responding to the threat of COVID-19 has presented significant challenges across society already. No one can underestimate the scale of these for us all in managing the risk from this virus. We understand that in making sure everyone remains safe, whilst ensuring the resilience of your organisation, you are taking unprecedented steps to achieve this. This will be even more so now, as we move from lockdown to a point where staff can work safely without risking their health. We know that this will be a priority for you. Deciding how best to do this in your own particular circumstances is key. You will have to do everything that is reasonably practicable given the risk presented. This means identifying workable precautions for your own organisation, whilst understanding you will not be able to eliminate completely the risk that the virus presents.
Making a start
In many cases, you will already have tried and tested arrangements in place to keep safe all those who work at, visit or use your premises. You will need to review these and your existing precautions before restarting work after lockdown. This will be to check their adequacy given the risk presented by COVID-19 and in the light of the COVID-19 Secure guidance published by the Government and others. In nearly all cases, it is likely that you will have to introduce further precautions. It is important to remember, that any additional precautions you identify should be proportionate. This will depend on your own specific circumstances. For example, reflecting the size or type of premises you occupy, the numbers of staff you have and the nature of the work activities involved. With all of this in mind, here are some points for you to consider. Some may be more relevant to you than others and the list is not exhaustive.
- You will need to decide if you can legally open your premises. To reduce the risk of transmitting the virus, some businesses and venues remain closed by law. Further information is available here, including any separate guidance issued by Devolved Administrations.
- You will also need to decide if staff and others can travel to their place of work. The position may differ where regions are under the control of Devolved Administrations.
- If you have appointed someone to help you with your health and safety obligations, work with them to review your arrangements and precautions to make sure they are adequate in the light of the guidance issued. This should reflect any responsibilities you may have under health and safety law, along with any commitments you have made in your health and safety policy if you have prepared one.
- If you need to complete risk assessments to meet your health and safety duties, you must review these. This is to make sure that they are valid and have identified any additional precautions you need to take to deal with the risk of COVID-19. You should use the guidance or other trusted information to inform your decisions about the adequacy of your existing precautions and others that might be necessary. The guidance sets out useful checklists relating to specific precautions that might be appropriate for certain workplaces. You should pay particular attention to protecting those who are especially vulnerable to COVID-19 and may be at work. Once complete, you should share the results of your risk assessment with your staff. You should also consider publishing it on your website, if you have one. There is an expectation that all employers having more than 50 workers will do this. A formal notice is available that you should display to show you have followed the guidance. Also, you may need to review other, more specific risk assessments you have made. An example would be your fire risk assessment. This would be in the light of any changes you have made to your premises, its layout or work activities that may have a bearing on them.
- You must make sure that your staff are appropriately consulted on managing the risk from COVID-19, including any precautions to be taken. This may be through established channels already set up, including those required to meet any legal obligations you may have. Further guidance on consulting and involving your staff is available here.
- In the first instance, you should make every reasonable effort for staff to work from home. This may involve identifying all those who can continue to do this, as well as deciding if jobs can be changed to facilitate it. For these staff, you will have to provide any necessary equipment, keeping in touch with them and monitoring their wellbeing. Further information on how to protect those working from home is available here.
- Where working from home is not possible, you will need to think about which staff are needed ‘on-site’. This will include the minimum number needed to operate properly and safely. You may need to think about the practicalities of them being able to get to work in the first place. You will need to treat staff equally and not discriminate against them. You will also have particular responsibilities towards disabled workers and new or expectant mothers.
- You will need to consider what steps are needed to protect those who are clinically vulnerable (or shielding someone who is) or extremely vulnerable, making sure that anyone who is self-isolating does not physically come to work.
- You should then implement suitable precautions in-line with the guidance set out by the government or other trusted sources e.g. recognised trade body. The risk assessment that you complete, should indicate what will be necessary in your own particular circumstances. Where social distancing guidelines cannot be followed, you will need to decide if that activity is able to continue. If it does, other precautions will be necessary, for example increasing the frequency of hand washing, keeping the activity time as short as possible, using screens to separate people and so on. In general, common precautions may include those necessary to:
- maintain social distancing – when moving around buildings and worksites; completing various tasks; when at workstations; for common areas such as canteens; and for meetings
- make sure the premises, equipment and vehicles remain clean – before reopening and in general use, including any toilets, washing facilities, showers and changing rooms
- make sure there is access to adequate sanitation facilities – along with the safe handling of any waste or materials
- re-organise work – to reduce the number of contacts each employee has, for example through introducing shifts or staggering work activities; avoiding unnecessary work travel and keeping staff safe when they need to do this; protecting peripatetic workers or dealing with high absence rates
- minimise the number of unnecessary visits to premises – from customers, visitors and contractors and to make sure that people understand what safety precautions are needed whilst on-site
- provide support for staff – who may be anxious about returning to work; self-isolating or shielding others; returning to work after being ill with COVID-19 themselves; or for those managing others so that they are clear on procedures for dealing with things like sickness reporting, sick pay or someone who is taken ill at work. More specific precautions may be necessary for certain workplaces. Here, you should check the relevant guidance provided.
- If your premises have been shut for a period of time, you may want to inspect them to ensure that they remain in good condition. This will include checking that all utilities, water systems, work and emergency equipment (such as fire-fighting or fire detection equipment), ventilation systems, access routes including any emergency routes or exits etc. remain serviceable. You may also want to check that there are no accumulations of waste, stock etc. that could present an additional hazard. Obviously, before re-opening your premises you will want to complete any necessary workplace adaptations identified by your risk assessment. You will also want to carry out any required cleaning. In some cases, you may want to consider resuming work at your premises in stages to help with this. Whatever the case, you will need to make sure that staff know about any changes and the additional precautions to be taken before they start work.
- In starting up any equipment, such as heating plant, you should make sure that this is done safely following any necessary procedures. You should also make sure that any statutory inspections of equipment are up to date or that appropriate action is being taken.
- As regards the use of personal protective equipment (PPE), the guidance makes it clear that using additional equipment beyond what is normally worn is not beneficial. The exception to this is in a clinical setting, like a care home or for first responders, where different rules apply. Outside these settings, employers are advised not to promote the use of additional PPE and their risk assessment should reflect this. Beyond the use of PPE, there are some circumstances when wearing a face covering may be marginally beneficial as a precaution. The guidance sets out additional information on this.
- You must provide any additional training and information for staff to make sure they know how to work safely and protect others against COVID-19. This may include detail about social distancing precautions, personal hygiene or the use of PPE for example. It may also set out details for following government guidance on self-isolation, shielding and travelling to work as well as your arrangements for returning to work following illness with COVID-19. You should keep records of any information or training you provide. These should contain detail relating to the persons who were trained (including their signatures to say that they have received and understood the training); when they were trained and by whom; an overview of the training that was provided etc. In addition to this, you may want to keep staff up to date with how safety measures are being implemented or updated.
- You must check that your first-aid arrangements and facilities are adequate for the correct emergency response. This will include if someone is taken ill with COVID 19 at work. You may need to review your formal assessment if you have need to complete one. Further information for first responders and others is available here. You will need to make sure that contact numbers and emergency contact details are up to date. In the event of an accident, your existing arrangements for recording and investigating these should apply, suitably adapted to maintain social distancing rules. For those more serious, you may need to report them and keep certain records. Clarification on what needs to be reported in relation to COVID-19 is available on the government website.
- You should carry out any necessary periodic checks to ensure that the precautions you have taken remain effective and adequate. This may include simple inspections to check that the premises and any equipment is safe. If you have completed risk assessments, these will help you identify where these checks will be necessary.
- If you have prepared a health and safety policy, update it to reflect any changes to your arrangements for managing the risk from COVID-19.
- In the event of a claim, evidence of what you have done may be important. This may include specific health and safety documents, such as risk assessments; records of maintenance, inspections and other checks; records of information and training provided; policy etc. You should keep these records in-line with your document retention policy.
- As things start to normalise, you may want to review any business continuity plans you have in place. You may be able to learn from your recent experiences to develop contingencies further to deal with any shutdown and start-up events in the future.
Keep up to date As we collectively learn more about the virus and its control, official guidance is frequently changing. You will want to keep up to date as it does, to make sure the precautions you have in place adequately protect people. You can check for updates at www.gov.uk/workingsafely