24 Jul 2020
Conducting a risk assessment is both a necessary and vital part of managing infection within your organisation. However, your responsibilities extend far beyond that.
When your staff return, it’s your responsibility to implement and enforce social distancing. Familiarise yourself with the practice in your workplace, whatever form it takes.
While conducting a risk assessment is a legal requirement, it isn’t the only responsibility you have as an employer. You must also:
- Create safe working practices specific to your workplace
- Maintain and review these working practices regularly
- Provide adequate handwashing facilities, as well as PPE and training to employees
- Review and update your risk assessments where necessary
- Thoroughly investigate claims of unsafe practices
Creating safe working practices
There are steps you can take to ensure staff follow the practice, including:
- Employee training (remember to make the training social-distancing safe, either via online presentations or in meeting spaces with plenty of room)
- Displaying posters with relevant information and advice
- Banning certain activities, including face-to-face meetings
- Displaying markers on the floor to highlight the appropriate distance between colleagues
- Staggering work hours
- Moving office furniture
- Review welfare facilities and ratio to staff
Managing risk when travelling
There are certain risks employees face in relation to work even when they’re not in the workplace. Commuting, for example. The obvious solution to prevent risk from travelling is to perform homeworking. However, this isn’t possible for some roles and you may wish to suggest suitable alternative means to travel to work such as cycle to work or driving their own.
So what can you do to assist those who need to commute on public transport?
Well, aside from providing PPE for those working on-site, you can ensure all staff have appropriate PPE when travelling as well. If you provide face masks for work, ensure your staff know they can use them both inside and outside of work, so long as it prevents or reduces risk and these are free of charge.
Aside from this, make sure you reinforce the need to wash their hands or use alcohol gel frequently, and maintain social distancing where possible.
The one metre plus rule
Where the 2m social distancing rule cannot be followed, there is now the “1 metre plus” rule. This means employees will need to maintain a minimum of 1 metre distance from others with extra measures in place.
“Extra measures” include:
- Face masks
- Face shields
- Frequent hand-washing
This change was brought about to try and help businesses struggling to open under the 2m rule. However, don’t assume that you don’t need to use PPE, or any other measures, just because you can maintain a 2m distance in your workplace. In some industries, PPE is vital, particularly in roles where the employee comes into contact with the general public, or vulnerable people.
In these scenarios, you should not only be providing PPE, but ensuring staff know how to use it. PPE used without appropriate training can introduce additional risks (such as cross infection) seek out training and support to ensure your staff are being appropriately protected. Take this into consideration when conducting your risk assessment and plan ahead.
Work environments often have a variety of settings including office areas, bathrooms, changing rooms, kitchens, and meeting rooms. Each area will have different surfaces and materials and all need to have routine environmental cleaning protocols. Special attention should be given to the high touch point areas such as shared equipment, door handles, light switch etc. As well as creating an environmental cleaning regime for the different working areas, careful consideration should be given to the products used to complete these tasks to ensure they are compatible and effective.
- Work areas and equipment needs to be cleaned frequently using effective products
- High touch points such as door handles, keyboards and light switches should be cleaned frequently with products freely available and accessible to users
- Maintain a ‘Clear Desk Policy’ at the end of the shift to allow for adequate cleaning
- Cleaning products used should have appropriate safety data sheets, training / instructions and disposal arrangements.
- Provide at desk cleaning wipes and personal hand gels
- If you have a known or suspected case of Covid-19 then additional cleaning and requirements will be necessary
- Keep a good air flow in the workplace – open windows and doors frequently, where possible
Reviewing your risk assessment
The HSE states that you should review your assessment when one of the two apply:
- It’s no longer valid (reviews should be undertaken at least annually to check the status)
- There’s been a significant change
We recommend annual reviews to check the status of your assessment. But, given the circumstances of lockdown, and the commitment of the HSE to ensure safety in all workplaces across the UK, it’s best to review as regularly as possible. As a minimum, you should review your assessment before shielding workers return.
As a reminder, the HSE carried out more than 1,000 spot checks in the first three weeks after it resumed inspections. And, the government provided the regulator with £14m in funding to help ensure COVID-19 safety.
Investigating claims of unsafe practices
If you have employees failing to follow social distancing measures, and someone reports it, you must investigate. Failure to do so may result in claims of constructive dismissal or a visit from the HSE.
You should conduct this investigation as you would a disciplinary or grievance issue. Speak to witnesses, let the accused give their side of the story, and gather evidence.
If your investigation finds that an employee was failing to follow safe practices, begin disciplinary proceedings. The severity of this will depend on the severity of the conduct. Considering the employee in question may be putting others at serious health risks, you might be tempted to deal with them quite severely. However, be cautious, don’t jump to suspension or dismissal until you’ve at least considered all alternatives.
Lockdown, social distancing, and a safe return to work presents both HR and health & safety risks. Croner are experts when it comes to the law, Aura Infection Control are the experts when it comes to managing transmission risk.
Contact Croner for legal advice on 01455 858 132.
Contact Aura for infection prevention solutions and advice, on 01833 630393 or visit the website www.aiconline.co.uk
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