COVID-19 secure: for employers and others
05 November 2020
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. Making sure everyone remains safe, whilst ensuring the resilience of your organisation, requires unprecedented steps to achieve this. This is even more so now as lockdown restrictions ease and staff can return to work.
Deciding how best to do this in your own particular circumstances is key. You have to do everything that is reasonably practicable to protect your staff and others given the risk presented. This means identifying workable precautions for your own organisation, whilst understanding you will not be able to eliminate the risk that the virus presents entirely.
The current position
Local restrictions will determine what you can do at your place of work. These vary across England, Scotland, Wales and Northern Ireland. A range of workplaces can remain open as long as they can do so safely, that is they are ‘COVID-secure’. For some areas, there may be local restrictions in place that limit this such as in England.
If you can open, it is important to remember that some activities may still not be able to take place.
To make your workplace COVID-secure, you will have to apply the relevant government guidance to your own particular circumstances. Similar information is available for the Devolved Administrations. Here, you will need to refer to the guidance for Scotland, Wales or Northern Ireland as appropriate. All of this information remains under review, so it is important to keep up to date with the latest directions. You can follow developments and access the current advice by using the resources highlighted below.
In some cases, you may need to refer to more than one set of guidance to make sure you are doing all that is necessary. An example might be where you have peripatetic staff based in an office visiting other people's homes in England. In this case you would have to apply the guidance for offices, working in other people’s homes and vehicles to suit your own circumstances.
COVID secure: 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 or where there are changes in local restrictions and guidance. This will be to check their adequacy given the risk presented by COVID-19 and in the light of the guidance published by the Government and Devolved Administrations. In nearly all cases, it is likely that you will have to introduce and monitor 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. You may also need to think about how your premises are organised, operated, managed and regulated.
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.
- Whilst most workplaces are allowed to open, it may still be worth checking that you can do this legally. Further information is available for England, Scotland, Wales and Northern Ireland.
- 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 responsibilities under health and safety law, 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. In some cases you may choose to complete a specific risk assessment. 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. A sample risk assessment is available here. 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.
- You may need to review other, more specific risk assessments that you have made to comply with legal obligations. 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 you have 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. There is also a free leaflet available about talking to your workers during the coronavirus outbreak.
- As part of your risk assessment and staff consultation, you should determine who can come into your workplace safely. This will take account of staff journeys, caring responsibilities, protected characteristics, and other individual circumstances. Extra consideration should be given to those people at higher risk. You should also consider the impact of your premises reopening on local transport, implementing appropriate precautions where necessary (e.g. staggered start and finish times for staff). Working from home still remains one option to prevent the risk of virus transmission, although ensuring premises are COVID-Secure will also do this. 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.
- Where staff continue to work from home, you will need to provide any necessary equipment, keep in touch with them and monitor their wellbeing. Further information on how to protect those working from home is available here.
- Where staff are using public transport to return to your workplace, it is vital they continue to follow the latest guidance on travelling safely in England, Scotland, Wales and Northern Ireland. This includes avoiding peak times where possible, wearing a face covering unless exempt and maintaining a safe social distance.
- You will need to consider what steps are needed to protect those who are clinically extremely vulnerable (or shielding someone who is). Generally, they should work from home wherever possible but can return to workplaces that are COVID-secure. If individuals cannot work from home, they should be offered the option of the safest roles available on-site to help with social distancing. Alternatively, they could be offered an alternative role or temporarily adjusted working patterns. You may have to consider arrangements for staff who live with such individuals. Other steps may also be needed to protect other vulnerable staff.
- Making sure that anyone who is self-isolating, including those asked to do so under the test and trace service, do not physically come to work.
- You should 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 can be redesigned to achieve this (i.e. maintaining a 2m distance or 1m+ with additional precautions). Additional precautions could include increasing the frequency of hand washing and surface cleaning, keeping the activity time as short as possible, using screens or barriers to separate people and so on. If social distancing cannot be maintained even after redesign, you should consider if that activity is able to continue with other precautions.
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
ensure good standards of hygiene – by providing adequate washing facilities or the provision of hand sanitiser. You may need to provide hand sanitiser in multiple locations. You should also display signs and posters to build awareness of good handwashing technique
make sure premises, equipment and vehicles remain clean – before reopening and in general use thereafter, including any toilets, washing facilities, showers and changing rooms along with suitable waste disposal
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 staff 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 you share your workplaces with other employers, you may need to cooperate with them to make sure adequate precautions are in place to protect all.
- In some cases, you may also have to consider any changes to protective security as a result of any precautions you have 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 beneficial as a precaution. The guidance sets out additional information on this for each setting. Face coverings are mandatory on public transport and in a number of settings.
- You must check that your first-aid arrangements and facilities continue to be 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 need to complete one. Information on what to do if first-aid cover is reduced is available here along with further information for first-aiders on providing a response. 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 here.
- 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 over time.
- 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. Further information on carrying out thorough examination and testing of lifting and pressure equipment during the coronavirus outbreak is available here.
- 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 written health and safety policy, update it to reflect any changes to your arrangements for managing the risk from COVID-19.
- You may need to report an outbreak of COVID-19. Specific guidance sets out how to recognise an outbreak, report it and understand what measure the local health protection teams may advise in order to contain it. The guidance also provides action cards for various workplaces that you can download to display or refer to.
- For some premises you may need to keep accurate records of those attending. Further guidance about what is required is available here.
- In the event of a claim, evidence of what you have done to manage any risk may be important. As such, you should keep evidence as you apply the guidance to be able to demonstrate your decision making process and what you have done to manage the risks identified. 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. These records should be kept 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. If you don’t have a business continuity plan already, we have developed some guidance that may be of use to you.
COVID secure: keeping 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.
This includes general advice and the specific guidance for particular workplaces:
Information and support are available here.
The Health and Safety Executive
This includes general advice and specific guidance: