Are you considering a (phased) return to the workplace?

Nonessential employees are still working from home and this could continue through the month of May (or possibly even longer). Employers need to formulate a plan to help keep employees healthy once they return to the workplace.

Companies are starting to consider a return to the workplace, or at least a partial return.

The general Government position is, currently:

Coronavirus (COVID-19): what you need to do Stay at home

  • Only go outside for food, health reasons or work (but only if you cannot work from home)
  • If you go out, stay 2 metres (6ft) away from other people at all times
  • Wash your hands as soon as you get home
  • Do not meet others, even friends or family. You can spread the virus even if you don’t have symptoms.

The first step is to make an informed business decision about the return to the workplace. This should be documented, as you may be asked to defend or justify the decision.

Social distancing (from the HSE website)

  • In these extraordinary times, the HSE is continuously reviewing the fast-moving situation with our partners across government to support the national effort to tackle COVID-19.
  • While social distancing is fundamentally a public health measure introduced to reduce the spread of infection, we recognise the concerns raised on social distancing within the workplace and are in contact with trade unions.
  • Where HSE identifies employers who are not taking action to comply with the relevant PHE guidance to control public health risks, e.g. employers not taking appropriate action to socially distance or ensure workers in the shielded category can follow the NHS advice to self-isolate for the period specified, we will consider taking a range of actions to improve control of workplace risks. These actions include the provision of specific advice to employers through to issuing enforcement notices to help secure improvements with the Public Health England guidance.

Although developed for the Construction Industry, this video – Link herecould be handy for Induction Training.

In practical terms, you should consider the following issues:

  • People should work from home if they can
  • You should create a Risk Assessment for the returning workers (see below).
    • This assessment should be updated to reflect the changing situation in your workplace.
  • You must require all workers on your sites to follow the social distancing rules.
  • The HSE has warned that employers that do not enforce social distancing measures could have works suspended and face fines.
  • People should keep at least 2 metres apart at all times.
    • Think also about travelling to site together as well as working!
  • Social distancing rules should be included in the site induction training for all workers.
    • This should also be reinforcement through toolbox talks.
  • You should require any contractors to cover social distancing in their RAMS and ask them to tell you how they will manage and enforce it.
    • You can share the responsibility with contractors.

Points to consider in you Risk Assessment and your Procedures

  • Use a suitable but simple risk assessment format. Share the risk assessment with all returning workers.
  • You must require all workers on your sites to follow the social distancing rules.
  • The HSE has warned that employers that do not enforce social distancing measures could have works suspended and face fines.
  • Social Distancing: People should keep at least 2 metres apart at all times.
    • This has implications on travelling to site together as well as working!
    • Think about meal times, etc.
    • Consider displaying floor signs, etc. that mark out two-metre distances.
  • Employers must carefully plan how social distancing is going to be maintained. In particular, reviewing the workplace layout and how people
    circulate within it is key. Key questions to consider include:

    • how can employees and others safely enter buildings
    • are there ‘pinch points’ within buildings and how are these managed
    • how to protect reception/security staff, i.e. are screens required
    • how will visitors be managed, i.e. are they required to sign a touch screen
    • how will people keep a safe distance in toilet/washing/showering facilities (remember that delivery drivers and others working on site will also require access)
    • how do people access welfare facilities, including drinking facilities
    • where will people eat
    • how will people exercise/get some fresh air
  • Possible control measures may include: the use of physical barriers; introducing one way systems; floor markings; and clear signage.
    Another approach is to reduce the number of people on-site at any one time by introducing a staggered/split working day, where possible.
  • There are other implications of the 2-metre separation that should be considered:
    • This may be assisted by having fewer people returning to the workplace (some may continue to work from home)
    • An alternative is to consider some form of shift system for accessing the workplace (with suitable cleaning of the workplace)
    • Staggering work start times for workers so that they do not all arrive at the same time
  • When social distancing is compromised – where it’s not possible for people to be 2m apart, you should do everything practical to manage the transmission risk by:
    • considering whether an activity needs to continue for the business to operate
    • keeping the activity time involved as short as possible
    • using screens or barriers to separate people from each other
    • using back-to-back or side-to-side working whenever possible
    • staggering arrival and departure times
    • reducing the number of people each person has contact with by using ‘fixed teams or partnering’
  • Will you need to carry out adaptations to the layout of the workplace and the organisation of work that will reduce COVID-19 transmission before resuming work?
    • Consider resuming work in stages to allow adaptations to be carried out.
    • Keep workers informed of changes and provide them with new procedures and training, as necessary, ideally before they resume work.
  • Social distancing rules should be included in the site induction training for all workers.
    • I would also recommend reinforcement through toolbox talks.
  • Ensure that Supervisors are aware of the need to oversee this and to monitor compliance with social distancing, etc.
  • Consider marking out individual work areas.
  • Ensure that PPE is used as appropriate to the task and the COVID19 risks
    • Gloves (disposable)
    • FFP3 masks
    • Face coverings (considered as non-personal protective equipment)
    • Consider disposable aprons
  • Think about First Aid provision and the stocking of kits (Paul Godwin will provide some information on this for you)
  • Consider date labels on handled goods to prevent the transfer of the coronavirus – Do Not Use Before etc.

Site cleaning

  • Ensure that touchpoints are cleaned regularly (door handles, levers, handrails, etc.).
    • Provide disposable wipes to make surface cleaning quick and easy.
    • Workers to clean their own work areas.
    • Wipe down controls, handles, tools, etc.
  • Clean tables in canteens regularly
  • Clean toilet facilities regularly

Handwashing

  • Remind people of the absolute need for good handwashing.
  • Display suitable notices and posters.
  • Check soap, paper toilets, running water, etc.
  • Provide hand sanitiser.
  • Display suitable notices to remind about the need for handwashing.

Simple Health Declaration

  • Ensure that those coming to work should not be self-isolating

Keep suitable, but simple, records

  • Doing the right things will keep workers safe
  • Being able to demonstrate that you have done the right things will keep the Company safe
    • Record your Risk Assessments
    • Update them regularly
    • Inform the workers of the Risk Assessments and of the Control Measures that they need to follow
    • Monitor Compliance and Record Compliance
    • Deal with any non-compliance issues

Help people to work from home

You should take all reasonable steps to help people work from home by:

  • discussing home working arrangements
  • ensuring they have the right equipment, for example remote access to work systems
  • including them in all necessary communications
  • looking after their physical and mental wellbeing

In early May, the Trade Unions warned about mass walkouts if workers lives are being risked, and tell workers to simply not turn up to jobs if health and safety demands are not met when coronavirus lockdown eases.

  • The Government is preparing to publish a back-to-work dossier for seven sectors of the economy at the end of the week
  • Keir Starmer lined up with the complaints of the Unions and commented that “PPE is not a luxury item for workers”

An Unplanned Return to the Workplace

The Prime Minister has announced significant, but ill-defined changes to the UK Lockdown. In effect, those who cannot do their jobs from home are being “actively encouraged” to return to work from Monday. That is tomorrow (at the time of writing). This could lead to workers returning to the workplace without adequate time for sensible planning and without suitable precautions implemented.Of the Prime Minister’s announcement, the leader of the Labour Party, Sir Keir Starmer said:

This statement raises more questions than it answers, and we see the prospect of England, Scotland, Wales and Northern Ireland pulling in different directions. The Prime Minister appears to be effectively telling millions of people to go back to work without a clear plan for safety or clear guidance as to how to get there without using public transport. What the country wanted tonight was clarity and consensus, but we haven’t got either of those.

Interestingly, Scotland, Wales, and Northern Ireland are not following this agenda.

  • Scotland’s First Minister, Nicola Sturgeon, has condemned a move to change the ‘stay at home’ messaging;
  • Adam Price, the leader of Plaid Cymru, described the message as ‘confusing and dangerous’. He added:’ There is no clearer and simpler message than “stay at home”.’

Any return to the workplace (including in the areas of construction and manufacturing), should be carried out with a carefully considered plan.

This simply cannot be the case if the return to work is dropped on companies without notice. One of the critical elements for safety in the workplace is social distancing, and this starts on arrival at the workplace. One of the tools that some companies may choose to use is the expedience of staggering the time of arrival of the workforce. Such an approach is simple and without significant cost to the company. It does, however, require planning and forward notice, which is missing for any company returning to work tomorrow without warning. It is also essential the companies have prepared for the return of workers, such as plastic screens, notices and signs within the workplace, enhanced cleaning regimes, and other sensible and often low-cost solutions. Again, each one of these requires some modicum of planning and coordination.

Only a day earlier, Britain’s biggest trades unions warned Boris Johnson that they would not recommend a return to work for their three million members until the government and employers agree on a nationwide health and safety revolution as a result of the Covid-19 pandemic.

In a letter to the Observer, leaders of the “big four” (Unison, Unite, the GMB and Usdaw) together with the TUC, pointed out that many workers have already lost their lives. To minimise further deaths at work, the Unions are insisting that Health and Safety need to be radically overhauled and stepped up in all workplaces if they are to back the government over easing, and eventually ending, the lockdown.

The union leaders say that all employers should have to draw up and publish risk assessments and state what measures they have taken to make work safe for their employees.

In the words of the Shadow Health Secretary (Jonathan Ashworth)

Many tonight will be asking whether they are being asked to go back to work or not tomorrow, what safety measures will be in place, how will they get to work.

My advice for a Phased Return to the Workplace

  • Plan the (phased) return to the workplace.
  • Carry out a suitable Risk Assessment for the Planned Return to the Workplace.
  • Implement suitable workplace strategies and precautions to keep workers (and others) safe.
  • Talk to your safety advisers, and others, to assist with your plans.
  • Communicate your plans carefully and thoroughly with your workers.

stay alert

Stay alert

We can all help control the virus if we all stay alert. This means you must:

  • Stay at home as much as possible
  • Work from home if you can
  • Limit contact with other people
  • Keep your distance if you go out (2 metres apart where possible)
  • Wash your hands regularly

Self-isolate if you or anyone in your household has symptoms.