Mind the gapPrint publication
Also view our related article on ‘Covid-19 – Returning to Work – Meeting your legal health and safety obligations’ here.
How to effect a safe return to work
As the UK remains in lockdown as a result of the Coronavirus pandemic, uncertainty abounds about when a return to “normal” life can be expected. Government commentary suggests social distancing may continue for the rest of the year, raising questions about how to effect a safe return to work.
Government guidance for certain sectors is set to be released on Sunday, three days after the Government must review the current lockdown measures. In the meantime, businesses should proactively identify what practical steps can be implemented in their unique working environment to allow a return to work as soon as possible. Very clearly, one size simply won’t fit all and it is for every employer to discharge their legal obligations to ensure that they protect the health and safety of their employees when they return to work.
All employers have a duty under the Health and Safety at Work etc. Act 1974 (HSWA) to protect, as far as reasonably practicable, the health, safety and welfare of their employees and those affected by their undertaking. In relation to risks posed by the Coronavirus, this principally includes implementing social distancing and avoiding person to person contact, wherever possible.
What is ‘reasonable’?
To demonstrate working practices are objectively reasonable and evidence compliance with HSWA obligations, a carefully considered and specific Coronavirus risk assessment will be key. This should identify essential / non-essential activities and appropriate risk mitigation measures. Where activities are identified as non-essential or high risk, they should be avoided.
Risk assessments – a practical guide
For many, the concept of undertaking a comprehensive assessment of the risks arising from the Coronavirus will seem overwhelming. But it doesn’t need to be complicated. All businesses should be used to producing risk assessments and a Coronavirus risk assessment is no different. Set out below are key things every business should think about during this process.
Identify where person to person contact is likely to occur and minimise/eliminate that contact, where possible. Think about whether you can:
- Reduce the number of employees on site at any one time.
- Stagger start/finish/break times.
- Implement shift patterns. Can you create and maintain shift cohorts?
Record your risk assessment in writing. Keep it simple, clear and concise.
Where to start
Take a logical approach – how and where do employees/customers arrive at the premises? Now, follow their journey around the site to identify possible points of contact. For example:
- Car parks
- Can you block out alternate spaces?
- What about car sharing? Employees taking public transport?
- Can you have one entrance and one exit? Will this also be used by customers?
- Consider providing hand sanitiser.
- Reception area
- Can you mark out two meters from your reception desk and use a plastic screen?
- Cloakrooms and toilets
- Do you have appropriate space? Are additional racks required?
- Do you need separate facilities for employees and customers?
- Are stairs an available alternative?
- Consider limiting the number of people in the lift and providing hand sanitiser.
- Shop floor
- Identify the best single direction route and mark it out along with 2m intervals.
- Can you limit the number of customers in the premises at any one time?
- Do you need to protect employees on the shop floor by using PPE or plastic screens?
- Employee floors/warehouse space etc.
- How many employees can safely be in the premises at any one time? Do they require PPE? Do you need to control the direction of movement?
- Can you provide employees with their own work stations/equipment? How will you manage shared equipment e.g. photocopiers?
- Do you need any additional facilities e.g. hand washing stations?
- Use signage, demarcate two metre intervals, encourage good hand hygiene and remind employees of any key principles you want them to follow.
- Staff kitchen/canteen areas
- How will you provide access to refreshments? How will you manage shared facilities?
- Can you stagger break/lunch times?
- Can employees go outside on their breaks? Consider smoking shelters and how to avoid people congregating.
What else to think about
You should specifically identify all tasks that involve employees working closely together. These should be reviewed to establish if they are essential and/or can be done differently. Where tasks are essential and social distancing cannot be maintained, employees should work side by side or back to back, rather than face to face, and limit any face to face contact to 15 minutes.
Other practical things you should consider:
- Do you have the appropriate equipment/facilities/PPE and if not, how will you source it?
- Do you have contract cleaners? Do you need to increase the frequency of cleaning, particularly in high risk areas?
- How will you communicate with your employees/customers? Do you have up to date emergency contact details for all employees?
- How will employees raise any concerns about the work environment? What about vulnerable employees?
- Do you need first aid provision? How will this be safely and effectively provided?
- What should employees do if they or a member of their household displays symptoms of Covid-19?
Once a risk assessment has been completed and control measures identified to minimise or eliminate person to person contact, it is critical that these are implemented before the work place reopens and are communicated to everyone before they arrive / on arrival.
Re-iterate the new measures frequently (posters, leaflets and/or announcements may be appropriate) and take steps to ensure compliance.
Periodically review and audit the risk assessment/control measures to ensure they are fit for purpose, being followed and are working effectively. Encourage employees to provide feedback and commentary as part of the process to ensure they feel safe at work and that the measures are practical.
Getting employees back into the work place as soon as possible will be critical for both the economy and individual businesses. To ensure employers discharge their legal obligations, a return to work must be safe and eliminate or minimise person to person contact, wherever possible. A comprehensive risk assessment will help businesses identify their key risk areas and suitable control measures to allow a safe return to work. Keeping this simple will help businesses implement new ways of working that are reasonable, practical and easily communicated / understood by employees and customers, ensuring everyone is as safe as possible at this uncertain time.
“The Future World of Work: Life after Lockdown” in our webinar on Thursday 14 May 2020. Further details here.