As we reported yesterday, the Prime Minister launched the Government’s roadmap to exiting lockdown, ‘Our Plan to Rebuild: The UK Government’s COVID-19 recovery strategy’ on Sunday. A scheme to return us to normality, if that is ever possible.
He further clarified during his Monday evening briefing, that this is not designed to produce a rush of workers returning to their workplaces, but more of a series of “baby steps” to get the economy back up and running. He also stressed that employees should talk to their employers about returning. We would add that it is equally important that you initiate conversations about returning, or not returning because they are not currently needed.
A very important plank of this programme is ensuring that workers are safe in their working environment. And, that employers take the necessary steps to minimise any risk of spreading Covid-19 among their workforce.
So, we have been busy digesting the 50-page strategy document from Sunday, the accompanying Q&A and other publications. Last night, we got our first glimpse of the Covid-19 Secure Guidelines for sectors of the economy that the Government wants to come back to work.
Our first impressions are that these are very comprehensive and sensible. They have been drawn up with input and the agreement of business leaders, the HSE and unions.
Details of each of these can be found at the following links, for those who work in the respective sector or working environment.
It is important to point out that, for some organisations there will be crossovers. Life is never neat enough to have all of your workforce in just one category. So, if you feel that you don’t quite fit, study the two, three or four Guides that most closely fit your workplace.
A considerable amount of the content of each Guide will apply across all sectors, while some of the advice is specific to one or more environments, but does not apply in others. And, recognise the Government’s key message that employees should work at home if at all possible.
Their logic is simple, less social interaction reduces the spread of the disease. Less travel to work allows more space for those who have to travel and have no alternative.
The first, and most important consideration, is that every employer, however large or small, needs to do a Covid-19 risk assessment. For many, this will be a review of your current workplace risk assessment, a legal requirement which you should have already done. For some, it might be simpler to do a separate risk assessment, and for others, it might be the first time they have ever attempted such a document.
Whatever happens, you must understand that this risk assessment will be a crucial document. In the event that there is ever a claim against you, the quality of this document, and your ability to demonstrate that you have followed it to the letter, will be very important.
Health and Safety Representatives and Committees
If you have a health and safety committee, then you must consult on this risk assessment with them. And for workforces larger than 50 workers, employers must liaise with health and safety representatives.
Health and safety representatives will be crucial in this. So, not only should your initial Covid-19 risk assessment be shared with them, so should the identity of regular breakers of your protocol, so that corrective actions can be taken.
If your workforce numbers over 50, and there are no safety representatives in your organisation, then you had better ask for at least one volunteer, or you could ask for a volunteer safety representative from each of your key business activities. Please note, you are not able to simply appoint health and safety representatives, they must be suggestions from within your workforce themselves. Whilst you should avoid scaring them with ‘responsibilities’, you should seek to make the most of their experience and common sense.
Employers will need to continually monitor health and safety, making sure that workers are complying with their requirements to maintain a safe workplace, especially if you are gradually phasing people back from furlough to work.
Social distancing is the first key principle in every part of every Guide. Keeping workers, customers, contractors and suppliers at a minimum of 2m, wherever possible, is essential.
Working out within the workplace how people can safely enter and exit, pass through pressure points, and share communal areas/equipment/facilities is as important as how they can safely work alongside each other.
Where social distancing is not possible, it is important that employers highlight this risk, and show what mitigating actions they have taken to reduce risk when this happens. Typically, such actions might include:
- Increasing hand washing and cleaning in such areas;
- Making activities where people are in close contact as short as possible;
- Erecting screens and barriers to separate people;
- Asking people to work back-to-back or side to side, rather than face-to-face;
- Working in fixed teams or partnering, to stop the spread within the organisation if close contact cannot be avoided;
Each Secure Guidelines document, which, do not forget, has been drawn up with both business leaders and trade union officials, emphasises the importance of social distancing.
At work, where possible, setting up a one-way system for travel around the workplace is desirable, like we are already used to in some supermarkets. Marking out the workplace in 2m squares gives clarity, having a separate entry and exit point reduces pinch points.
The placement of workstations and the screening between them makes work much safer. But employers should also be asking themselves how meetings can be safely held?
- Are they strictly necessary?
- Do they have to be in one room, or can they be outside?
- Can they be done better via video-conferencing?
- When they have to be held:
- How long should those meetings be?
- What preparatory work can be done before?
- What is the follow-up work that does not have to be done in the meeting itself?
Particular attention needs to be made to exit and entry points, but also to reception areas, serving counters, toilets, canteens and communal meeting areas.
How many people, especially customers, are allowed in these areas at one time? How can they be separated? Is there enough hand sanitising around if there are no hand washing facilities?
Organisations have to manage visitors, customers and contractors. Do you have a formal visitor booking in procedure? Does the visitor have to fill this out themselves, can they use their own pen, or can you fill it out for them?
Travel to Work
Although for many employers, travel to work was not their problem before, now it is at least a consideration.
How can you mitigate the dangers of travelling on public transport, and arriving and leaving work? Can you make it easier to store bikes? Is walking to work a serious alternative? Are employees travelling together in company vehicles? Is there sufficient parking?
Washing and Cleaning
It is clear that hand washing and cleaning of surfaces is fundamental to safely working in this pandemic. Identifying surfaces that get touched regularly by many people is vital, as is putting in a cleaning routine to make sure the surfaces are safe. Getting your workers to take personal responsibility for cleaning shared surfaces after they have used them is key to this.
Likewise, and this is a message that we have heard from the start of this pandemic, providing enough hand washing facilities, enough instruction about regular hand washing and, where that is not possible, providing hand sanitisers will also be very important.
Split your Workforce
Not only should employers split their workforce and potentially, especially when they are working in close proximity, establish fixed teams or partnerships, but they should also identify clearly those who can work at home, for instance office and accounts staff, compared to those who have to be at work.
Clearly, some workers may be able to spend three or four days at home, working, before they need to go to the office to perform certain functions or actions. Others might be able to split their day, and work before or after travelling to work, to reduce their exposure on the transport system, by travelling at other times, and by carrying out work at home where possible.
When considering those who can work at home, consideration must be given to those higher risk categories of workers, the extremely vulnerable and the vulnerable. Employers are also requested now to consider others at home living with your employees, especially the extremely vulnerable. Avoiding putting them at risk is viewed as important.
Do not Assume and Communicate
And, it is also easy to assume that certain groups would prefer to be on furlough, or be working from home. You might assume this of the disabled for instance, when in fact, they are not in a high-risk group and actively want to work.
The message is, clearly communicate with your workforce and find out what each of them feel they are capable of doing, and what they want to do.
Conversations with all parts of your workforce are needed. Whether it is those who are reluctant to turn return to work, those who feel vulnerable, or those who are running out of money and really want to return to work.
The Government has stressed that it expects employers to take socially responsible decisions with regards to its workforce. They are thinking in particular of employees with childcare responsibilities who cannot make alternative arrangements (like grandparents), without breaching social distancing rules.
Each Guide states that businesses that have been closed for some time will need a deep cleaning before reopening.
Your risk assessment should consider how frequently you clean shared areas, and shared surfaces. The clear implication is that this frequency should be sufficient to ensure minimal spread of the virus.
How often do you remove waste? If you used to do it every week, should that now be every day or even every hour?
And, while hand washing, sanitising and cleaning are clearly essential, and where you have goods inwards and outwards, what are your cleaning procedures there?
Personal Protective Equipment (PPE)
Government guidance is very specific. Personal protective equipment is only required in specific areas, mainly in health and social care, where the disease is more prevalent and social distancing is not possible.
The Government has made it clear that personal protective equipment outside these environments is not generally necessary. Nor do they wish to encourage it when it might take vital equipment away from where it is needed for front line workers.
They particularly talk about face coverings on, which they have been ambivalent from the start. There may be places, for example on public transport, where social distancing cannot be reduced and face covering may play a limited role.
But, for the majority of workers, face coverings are optional. Where employees want to wear such face coverings, they should provide their own, unless your risk assessment has identified it as being necessary, in which case you must provide and pay for it. However, employers should educate workers on the right protocol to use them. As they argue that face coverings worn incorrectly or removed incorrectly are more of a danger than no face covering at all.
Staggering the workforce, potentially reducing the workforce that is present by half while maintaining productivity, involves staggering shifts.
The recommendation in each of the Guidelines is that these shifts, once established, should be kept together. Mixing the shifts will increase the risk of spread between the shifts.
Staggering start times reduces congestion at entry and exit points. Alternating shifts reduces presence in the workplace.
Moving to double shifts may be the only alternative for some employers, who would otherwise have to make redundancies to halve their workforce. Especially when the Government’s support ends.
These messages need to be clearly communicated to the workforce.
Communication is vital in such times. Both to allay workers fears about returning, and to train them in the new way of working.
Things post coronavirus will not be the same as before. They have suggested holding a mini induction programme for returning workers, and a refresher course for current workers. This is relevant for workers who might be about to see a sudden influx into what had not been a crowded workplace.
Each Guide contains a number of posters that can be reproduced, and signage that can be used in the workplace.
It is the Employers’ Responsibility
Each of these Guides is very detailed, even if they are rather repetitive, if you read all of them.
We cannot emphasise enough that the responsibility for assessing the risk to your workforce, and the responsibility for ensuring that all risks are monitored and reported on, lies with the employer. And every workplace will have a different set of considerations. So, while we can provide you with a generic template to start from, you must carry out these risk assessments yourself.
You may not fall neatly into one sector or another, in which case, we suggest you read the bits that change between two or three different sectors, while studying in depth the sector that most closely matches your own.
If you need any help in getting started, let us know.
Our Consultants would be pleased to advise you on any element of the issues arising from this newsletter.