Reopening your Business?
Date: 23rd June 2020
COVID-19 has changed the way we live and work for the foreseeable future. As such, it is important that businesses take important steps to protect the safety of employees and visitors.
Here are some suggested measures that you and your clients may wish to implement upon reopening to limit potential exposure to COVID-19 in the workplace and reduce exposure to possible enforcement action by the Health & Safety Executive (HSE).
1. Conducting a COVID-19 risk assessment
Before commencing with work again, businesses should complete a thorough and robust risk assessment, concentrating on protecting their employees and visitors from COVID-19 and considering what precautions need to be put in place within the workplace.
Some of the hazards to consider are outlined below:
- Points of direct or close contact between individuals
- Where more than one person is using an item or space
- Handling goods or equipment
- How many people are in one space at any one time
- How people manoeuvre around spaces
- Where jobs cannot be conducted without close contact
- How spaces are being effectively monitored and cleaned
- Not having effective or sufficient PPE
2. Social Distancing
The COVID-19 outbreak has led many businesses to rethink how they conduct meetings, with most using online conferencing software instead. As businesses return, this emphasis on virtual meetings will likely continue. Employers may want to consider if a face-to-face meeting can be entirely avoided with remote working tools used instead.
If a face-to-face meeting is required, consider:
- Only inviting necessary participants to attend meetings and maintaining 2 metre separation throughout.
- Do not allow the sharing of pens and other objects.
- Providing hand sanitiser in meeting rooms.
- Holding meetings outdoors or in well-ventilated rooms whenever possible.
- Using floor signage to help people maintain social distancing.
Suggested ways in which social distancing can be maintained while using common areas are:
- Staggering break times.
- Using safe outside areas for breaks.
- Creating additional space by using other parts of the worksite or building that have been freed up by remote working.
- Using protective screening for staff in reception areas or similar spaces.
- Providing packaged meals or similar, which helps to avoid opening staff canteens.
- Reconfiguring seating and tables to maintain spacing and reduce face-to-face interactions.
- Encouraging staff to stay on-site during working hours.
Customer fitting-rooms (for shops)
The Government has issued guidelines to minimise the contact resulting from visits to shops. Measures include:
- Fitting-rooms should be closed where possible, given the challenges of operating them safely.
- Where deemed essential, they should be cleaned very frequently, typically between each use.
- Procedures should be created to manage clothes that have been tried on – for example, delaying their return to the shop floor.
- Contact should be limited between customers and colleagues during fitting, for example, by suspending fitting assistance.
Suggestions for achieving this include:
- Looking to minimise the number of visitors attending a site.
- Implementing good record-keeping to ensure traceability.
- Providing clear guidance on social distancing and hygiene to employees and visitors by using signage, visual aids, and prompting them before arrival – for example, by phone, on the website or by email.
- Establishing host responsibilities relating to COVID-19 and providing any necessary training for people who act as hosts for visitors.
- Reviewing entry and exit routes for visitors and contractors to minimise contact with other people.
- Coordinating and cooperating with other occupiers for those working in facilities shared with other businesses, including with landlords and other tenants.
3. Coming to work and leaving work
Employers should consider how to maintain social-distancing wherever possible, particularly during arrival and departure times. Some suggested ways to achieve this safely include:
- Staggering arrival and departure times.
- Providing additional parking or facilities, such as bike racks, taking into account social distancing measures.
- Limiting passengers in corporate vehicles, which could include leaving seats empty.
- Reducing congestion by having more entry points to the workplace.
- Putting markings in place and introducing one-way flow at entry and exit points.
- Providing handwashing facilities, or hand sanitiser where not possible at entry and exit points. All staff should ensure they use handwashing facilities upon arrival.
- Providing alternatives to touch-based security devices, such as keypads.
- Defining process alternatives for entry and exit points – for example, deactivating pass readers in favour of showing a pass to security personnel at a distance.
4. Controlling movement around the workplace
Moving around buildings and worksites
Again, employers should be considering how best to maintain social distancing in the workplace wherever possible. Some examples of how this could be achieved include:
- Reducing movement by discouraging non-essential trips within buildings, restricting access to some areas, encouraging use of radios or telephones, and remembering to regularly clean all areas and equipment.
- Reducing job and equipment rotation.
- Introducing more one-way flow through buildings.
- Reducing occupancy for lifts, providing hand sanitiser for the operation of lifts and encouraging use of stairs.
- Making sure that people with disabilities are able to access lifts.
- Regulating the use of high traffic areas, including corridors, lifts, turnstiles and walkways to maintain social distancing.
Workplaces and workstations
Consideration should be given as to how best to operate workstations whilst adhering to social distancing. Some potential ways to achieve this include:
- Considering the introduction of engineering controls (e.g. physical barriers between a person and the hazard, such as perspex screens at shop check-outs, etc.).
- Assigning an individual to a particular workstation as much as possible.
- If it is not possible to keep workstations 2 metres apart, consideration should be given to cleaning equipment and hygiene.
- Look at reviewing layouts, line set-ups or processes to allow people to work further apart from each other.
- Use floor tape or paint to mark areas to help workers keep to a 2 metre distance.
- Where it is not possible to move workstations further apart, look to arrange people to work side-by-side or facing away from each other rather than face-to-face.
- Consider installing screens to separate people from one another if work stations cannot be moved further apart.
- If people must work in close proximity (e.g. during 2-person working, lifting or maintenance activities that cannot be redesigned), look to use a consistent pairing system.
5. Handling goods, merchandise and other materials
Things to be considered here include:
- Encouraging increased handwashing and introducing more handwashing facilities for workers and customers, or providing hand sanitiser where this is not practical.
- Limiting customer handling of merchandise – for example, through different display methods, new signage or rotation of high-touch stock.
- Implementing pick-up and drop-off collection points where possible, rather than passing goods hand-to-hand.
- Staggered collection times for customers collecting items with a queuing system in place to ensure a safe distance of 2 metres.
- Setting up a ‘no contact’ return procedure, where customers take returned goods to a designated area.
- Encouraging contactless refunds.
- Keeping returns separate from displayed merchandise / stock to reduce the likelihood of transmission through touch.
- Providing guidance on how workers can safely assist customers with handling large item purchases.
6. Cleaning and PPE procedures
Consideration should be given to the cleaning of workspaces, including vehicles.
It is important to ensure there is frequent cleaning of work areas, equipment and surfaces that are touched regularly, such as door handles, lift panels, printers, copiers, telephones, keys and steering wheels. There should be adequate disposal arrangements to remove waste and belongings from the work area at the end of a shift.
We would suggest that cleaning procedures are also developed for the parts of shared equipment that are touched after each use, considering equipment, tools and vehicles (e.g. pallet trucks and fork-lift trucks).
Where water systems have been out of use for a period of time, there is an increased risk that Legionella bacteria could have multiplied to hazardous concentrations. Water systems should be flushed and thoroughly cleaned and disinfected. Consideration should also be given to the need to conduct microbiological sampling.
Businesses should consult with air-con providers regarding what provision has, or can be made, to ensure air cannot be contaminated should any employee have COVID-19. Timings could be adjusted so the system comes on at least an hour before, and an hour after, the workplace is occupied. If you have windows that can be opened, encourage employees to do so to allow fresh air to circulate.
Hygiene: handwashing, sanitation facilities and toilets
As the Government has made clear, it is important to build awareness around hygiene standards through promoting increased handwashing frequency and reminding employees of the need to avoid touching their faces and to cough or sneeze into a tissue which is binned safely, or into their arm if a tissue is not available.
You may wish to consider providing hand sanitiser in multiple locations, in addition to washrooms. Also perhaps enhanced cleaning for busy areas, providing more waste facilities and more frequent rubbish collection. Where possible, provide paper towels as an alternative to hand dryers.
The Government has given detailed advice on the use of PPE and face coverings in the workplace. Full details on all the guidance, which is continually being updated, can be found here: https://www.gov.uk/government/publications/wuhan-novel-coronavirus-infection-prevention-and-control/covid-19-personal-protective-equipment-ppe.
Wearing a face covering is optional and is not required by law in the workplace (unless the workplace involves the use of public transport). For those who choose to wear one, it is important to use face coverings properly and ensure hands are washed before and after putting a face covering on.
Employers can support their workers in using face coverings safely if they choose to wear one by telling them to:
- Wash their hands thoroughly with soap and water for 20 seconds, or use hand sanitiser before putting a face covering on, and after removing it.
- When wearing a face covering, avoid touching their face or face covering, as they could contaminate them with germs from their hands.
- Change the face covering if it becomes damp or if they’ve touched it.
- Continue to wash hands regularly.
- Change and wash the face covering daily.
- If the material is washable, wash in line with manufacturer’s instructions. If it’s not washable, dispose of it carefully.
7. Record your findings
t is important employers record their findings for their risk assessment. It is also good practice for employers to involve their workforce in producing their risk assessment.
Once complete, employers should also effectively communicate and train staff in the control measures detailed in the risk assessment. It is important to make sure all workers understand COVID-19 related safety procedures by providing clear, consistent and regular communication to improve understanding and consistency of ways of working.
Employers should engage with workers and worker representatives through existing communication routes to explain and agree any changes in working arrangements. Communication and training materials should be developed for workers prior to returning to site, especially around new procedures for arrival at work.
Communication and training must be recorded and signed off by the employer and workers. It is important to bear in mind that workers will have been away from the workplace for a number of weeks and may require some form of refresher training. Unqualified workers should not pick up tasks with which they are unfamiliar.
8. RIDDOR reporting of COVID-19 – What to report?
The government has an extensive list of guidance on the key definitions of reportable incidents, who should report, when to report and how to do so on their website:
In summary, a report under RIDDOR should only be made in the event of:
- Dangerous occurrences: E.g. if something happens at work which results in (or could result in) the release or escape of coronavirus, you must report this as a dangerous occurrence.
- Cases of disease: If someone is diagnosed with COVID-19 and it is attributed to an occupational exposure to COVID-19, this must be reported as a case of disease using the ‘case of disease’ report form.
- Death: Where a worker dies as a result of occupational exposure to coronavirus, and there is reasonable evidence that a work-related exposure was responsible for the death, this should be reported within 10 days through the ‘case of disease’ report form.