As the pandemic slows and the UK starts to return to work it is important that employers are doing everything as far as reasonably practicable to ensure the safety of their employees, clients, suppliers and other visitors to their place of work or anybody that could be affected by their operations. This is a duty set out within the Health and Safety at Work Act 1974 and further defined within various regulations such as the Management of Health and Safety at Work Regulations 1999.
The HSE have stated that if an employee catches Covid-19 at work or foreseeably while undertaking work activities then this would be come reportable under the Reporting of Injuries, Diseases and Dangerous Occurrence Regulations 2013.
You should have various risk assessments (written if you have more than 5 employees) in place and safe operating procedures to carry out your works that will have identified and mitigated foreseeable risks in your activities, these assessments and procedures should now be reviewed to also include the risk of infection and transmission of Covid 19.
When carrying out a risk assessment of Covid 19 the following hierarchy of control should be employed:
|Eliminate||• Workers who are unwell with symptoms of Coronavirus (Covid-19) should not travel to or attend the workplace
• Rearrange tasks to enable them to be done by one person, or by maintaining social distancing measures (2 metres)
• Avoid skin to skin and face to face contact
• Stairs should be used in preference to lifts or hoists and consider one ways systems
• Consider alternative or additional mechanical aids to reduce worker interface Meetings
• Only absolutely necessary meeting participants should attend
• Attendees should be at least two metres apart from each other
• Rooms should be well ventilated / windows opened to allow fresh air circulation
• Consider holding meetings in open areas where possible
|Reduce||Where the social distancing measures (2 metres) cannot be applied:
• Minimise the frequency and time workers are within 2 metres of each other
• Minimise the number of workers involved in these tasks
• Workers should work side by side, or facing away from each other, rather than face to face
• Regularly clean common touchpoints, doors, buttons, handles, vehicle cabs, tools, equipment etc.
• Increase ventilation in enclosed spaces
• Workers should wash their hands before and after using any equipment
|Isolate||Keep groups of workers:
• Together in teams e.g. do not change workers within teams
• As small as possible
• Away from other workers where possible
|Control||• Consider introducing an enhanced authorisation process
• Provide additional supervision to monitor and manage compliance
|PPE||Workplaces should not use RPE for Coronavirus (Covid-19) where the two metre social distancing guidelines are met.|
|• Coronavirus (COVID-19) needs to be managed through social distancing, hygiene and the hierarchy of control and not through the use of PPE
• Workplaces should not encourage the precautionary use of extra PPE to protect against Coronavirus (COVID-19).
|Behaviours||The measures necessary to minimise the risk of spread of infection rely on everyone in the taking responsibility for their actions and behaviours.
Please encourage an open and collaborative approach between workers and employers where any issues can be openly discussed and addressed.
(Source CLC, 2020)
One key health and safety phrase that sometimes can cause some confusion but is essential to correctly mitigating risk is ‘as far as reasonably practicable’. This is the balance between controlling the risk and the time, trouble and money involved in implementing this control. There is considerable case law relating to this idea. Where a risk is unforeseeable or so unlikely to occur money can not be justified to control the risk then this would not be deemed practicable however this wouldn’t be relevant to Covid 19 as currently the risk of infection is foreseeable. A more applicable illustration would be the idea that a significant investment is required to marginally reduce the risk of infection or makes the procedure far more laborious or even hazardous, an example of this in the case of Covid 19 would be providing full respirated bio hazard suit, while this would reduce the risk of infection the cost, time and effort of it would make this solution not practicable.
Essentially, if at all possible, work should be done at home in as much isolation as possible, where this isn’t feasible then social distancing and physical barrier controls should be implemented. If these cannot be suitably controlled, then the absolute need for this operation for running of the business should be considered. Please refer to the government guidelines as to industries that are still prohibited from operating.
You should always seek advice from a qualified and experienced Health and Safety practitioner to ensure you have fully met your obligations.