covid-19 health & safety back to business workbook · covid-19 health & safety back to business...

COVID-19 Health & Safety Back to Business WorkbookTo be used in conjuction with Ellis Whittam’s COVID-19 Back to Business Hub.

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Contents

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Introduction 3Using this pack 3Guidance documents and further support 3Government guidance 4Health and safety legislation 4COVID-19 Health & Safety Policy 6Business status 8COVID-19 Risk Assessment of the workplace and control measures 10Dealing with emergencies 16Statutory checks 18Staff information and training 18Monitoring 19Review 20

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IntroductionThese are unprecedented times. In a matter of a few weeks, the coronavirus (COVID-19) pandemic has created an unparalleled health crisis and presented businesses with a deadly new virus to manage in the workplace. Workplaces previously thought to be low risk have had to close, whilst others permitted to remain open have had to review risk controls measures and, in many instances, transition their employees to work from home.

But there is good news. With the government having announced the partial lifting of the UK lockdown, businesses across the UK will be preparing to reoccupy their workplaces and get back to ‘business as usual’. However, it is absolutely imperative that you do so safe safely and implement effective arrangements to mitigate the risks of COVID-19.

At Ellis Whittam, we understand the challenges you face, which we know are not helped by information overload. As such, we have assembled this business support pack to walk you through a logical process for managing the risks of COVID-19 and ultimately get you up and running. Created by our team of experienced Health & Safety Consultants, this pack is designed to be completed by you and, depending on the status of your business, it will identify what you need to have in place as you prepare for an eventual return to the workplace.

Using this packWhether you are preparing to return to work, remain in lockdown or continue to work from home, this pack can help you. It is divided into sections that will enable you to construct your COVID-19 Health & Safety Policy and Restart Plan. Each section begins with some background information, before recommending specific actions you should take to ensure that you maintain a safe workplace and remain legally compliant.

Where relevant, we will direct you to the various documents on our COVID-19 Back to Business Hub that can be downloaded and completed (such as checklists and risk assessments) or used to build your COVID-19 Policy. Remember that when completing these documents, especially the risks assessments, you must ensure that they accurately reflect your business activities and environment and that they are suitable and sufficient.

Important noteGovernment guidance on COVID-19 is constantly changing, hence it is important that you check the latest advice using the sources contained within this document and the information available on the Back to Business Hub.

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Guidance documents and further supportAll documents referred to in this pack can be accessed via the Back to Business Hub. Should you require further advice or assistance, existing Ellis Whittam clients can contact us on 01244 687 236. If you are not an Ellis Whittam client and you require further support, please contact us on 0345 226 8393.

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Government guidanceWhether it be England, Scotland, Wales or Northern Ireland, each devolved government will publish sector-specific guidance to help employers, employees and the self-employed understand how to work safely during the coronavirus pandemic and ensure workplaces are as safe as possible. It is important to refer to the guidance that is most relevant to your business and apply those control measures.

As many businesses operate more than one type of workplace, such as an office, factory and fleet of vehicles, you may need to use more than one of the guides as you think through what you need to do to keep people safe.

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Health and safety legislationDespite some businesses and organisations being forced to close, health and safety legislation has not been suspended in any way, shape or form in light of the COVID-19 crisis. In fact, certain areas of health and safety law have been expanded recently, including the requirement to report instances of COVID-19 – in certain defined situations – under the Reportable Injuries Diseases and Dangerous Occurrences Regulations 2013 (RIDDOR).

Some important pieces of health and safety legislation in relation to COVID-19 are set out below. Please note that this is not an exhaustive list.

Health and Safety at Work etc Act 1974

This is the fundamental piece of health and safety legislation under which other legislation is derived. It places general duties on employers to ensure the health, safety and welfare of all persons at work.

Management of Health and Safety at Work Regulations 1999

These regulations require employers to assess the health and safety risks to employees and others who may be affected by their work activities. Arrangements must be made for the effective planning, organisation, control, monitoring and review of preventive and protective measures.

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Control of Substances Hazardous to Health Regulations 2002

These regulations require employers to carry out a suitable and sufficient assessment of the risks where employees or non-employees may be exposed to hazardous substances so that the necessary precautions to prevent harm can be identified and implemented.

Personal Protective Equipment at Work Regulations 1992

These regulations require employers to provide compatible, effective personal protective equipment (PPE), maintain and replace PPE, and provide information, instruction and training on the use of PPE.

Workplace (Health, Safety and Welfare) Regulations 1992

These regulations cover the need to provide a safe and healthy working environment.

Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 (RIDDOR)

These regulations require that specified injuries, diseases and dangerous occurrences are reported to the Health and Safety Executive (HSE) or Local Authority.

Safety Representatives and Safety Committees Regulations 1977 & Health and Safety (Consultation with Employees) Regulations 1996

These regulations detail the requirements for appointing and consulting with a trade union safety representative and your employees.

Other health and safety regulations which may apply include:

• Lifting Operations and Lifting Equipment Regulations 1998• Lifts Regulations 1997• Pressure Systems Safety Regulations 2000

Regulatory Reform (Fire Safety) Order 2005 / Fire (Scotland) Act 2005 & Fire Safety (Scotland) Regulations 2006

Finally, the significance of fire safety legislation should not be overlooked, especially when your arrangements to manage the risks during the COVID-19 pandemic may need to be reviewed.

Full copies of relevant legislation are available via the Office of Public Sector Information and the National Archives.

http://www.opsi.gov.uk/http://www.legislation.gov.uk/

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COVID-19 Health & Safety Policy

The starting point for your business is to develop and document a COVID-19 Health & Safety Policy which sets out how you are going to prevent and control the transmission of COVID-19. The policy we recommend is based on the principles of ‘Plan, Do, Check, Act’ and begins with a statement of intent (‘Policy Statement’) in which you set out your commitment to managing the risks from COVID-19. This statement should be signed by the most senior person in your organisation to demonstrate that the commitment is led from the top.

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Policy Statement

Helpful Hub documentFile-altPlease sign in and access the COVID-19 Back to Business Hub and refer to the COVID-19 Health & Safety Policy Template for an example Policy Statement.

Whilst the overall responsibility for health and safety and management of COVID-19 rests at the highest level, every employee has a role to play in helping to provide and maintain a safe place of work. Your policy should therefore set out those responsibilities and provide a clear understanding of what is expected.

Responsibilities

All “Helpful Hub document” activities for this section are located within the COVID-19 Health & Safety Policy dropdown.File-alt

NB: It is advised that you appoint someone to oversee COVID-19 controls within your business.

Helpful Hub documentFile-altPlease sign in and access the COVID-19 Back to Business Hub and refer to the COVID-19 Health & Safety Policy Template for an example section on health and safety responsibilities which can be used and modified according to your activities.

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https://elliswhittam.com/covid-19/registerhttps://elliswhittam.com/covid-19/register

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This section of your COVID-19 Health & Safety Policy provides an opportunity for you to specify the rules laid down for the attention of all employees. These rules are prepared in accordance with government guidance and legal requirements and a failure to observe them will be considered to be a breach of the Contract of Employment and may result in disciplinary action being taken.

Health and safety rules

Helpful Hub documentFile-altPlease sign in and access the COVID-19 Back to Business Hub and refer to the COVID-19 Health & Safety Policy Template for an example section on health and safety rules that can be used and modified according to your activities.

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https://elliswhittam.com/covid-19/register

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Business status

This section of your COVID-19 Health & Safety Policy reflects your current business status, which will either be that your business has:

• Remained open with no reduction in staffing levels during the COVID-19 outbreak;

• Stayed partially open with activities continuing;• Transitioned staff to work from home; or• Ceased operations temporarily as per government

instruction.

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Initial COVID-19 check

If your business activities have been temporarily suspended and your premises have been unoccupied (or partially occupied) during the COVID-19 pandemic, there are important checks that you will still need to perform. You should also stay alert to government announcements on return to work.

Premises and activities closed

All “Helpful Hub document” activities for this section are located within the Business status dropdown.File-alt

Helpful Hub documentFile-altPlease sign in and access the COVID-19 Back to Business Hub and refer to the Initial Audit Form to determine what action you need to take.

Helpful Hub documentFile-altPlease sign in and access the COVID-19 Back to Business Hub and complete the Empty Building Checklist before reoccupation.


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You should make every reasonable effort to enable working from home as a first option to reduce the transmission of COVID-19. Where this is possible, a Homeworking Risk Assessment should be performed.

Working from home

Please sign in and access the COVID-19 Back to Business Hub and read the guidance titled Health & Safety for Homeworking and consider providing employees with our document titled Homeworking – Employee Guide to Health and Wellbeing.

Complete the Homeworking Risk Assessment with homeworkers to identify potential hazards and put in place control measures to ensure they are able to work safely.

If you are preparing to return to work at your premises after lockdown, you should start by asking yourself the following questions:

• Are there any staff who can continue to work from home?• Which staff cannot work from home and must therefore

return to work?• Who will continue to be furloughed until further notice?

This will then help you to decide on who is at risk and what risk controls to implement.

Returning to work

Helpful Hub documentsFile-alt

Helpful Hub documentFile-altPlease sign in and access the COVID-19 Back to Business Hub and complete the Reoccupation Checklist to record important checks of your premises before returning to work after lockdown.


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COVID-19 Risk Assessment of the workplace and control measures

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All “Helpful Hub document” activities for this section are located in various dropdown areas of the COVID-19 Back to Business Hub.File-alt

Once you have returned to your normal work environment and it is business as usual, you will need to introduce new arrangements to manage the risks from COVID-19. The starting point is to undertake a COVID-19 Risk Assessment, which will help you to decide what action to take.

Health and safety legislation requires that your COVID-19 Risk Assessment is ‘suitable and sufficient’ and that a written record is made of all significant findings. When considering your COVID-19 control measures, you should seek to apply measures according to the ‘Hierarchy of Controls’, with the most effective controls (those at the top) considered first.

Health and safety law does not demand absolute safety when considering what safety controls are required but measures taken should go as far as is ‘reasonably practicable’. This requires a balance between risk and costs; the greater the risk, the greater the need to commit resources in terms of time and money to remove or control it.

An action plan will need to be developed from your COVID-19 Risk Assessment and the issues within it will need to be implemented as soon as possible. Finally, those carrying out the risk assessment must be competent – in other words, they must have the necessary skills and knowledge gained through experience and training and may have qualifications that enable them to make sound judgements.


Please sign in and access the COVID-19 Back to Business Hub and and refer to the COVID-19 Health & Safety Policy Template in the COVID-19 Health & Safety Policy dropdown for an example section on risk assessment that can be used and modified to set out your arrangements.

Complete your risk assessment using the sector-specific Coronavirus Risk Assessment templates that are relevant to your business within the COVID-19 Risk Assessment and control measures dropdown. You must ensure that the template you use is modified to reflect your activities and environment.

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Vulnerable persons are those who are at increased risk of severe illness from COVID-19. These individuals have been separated into three categories and the management of each category will vary. These categories are:

• Clinically extremely vulnerable people – those notified by the NHS;

• Clinically vulnerable people; and• Vulnerable people (non-clinical).

Clinically extremely vulnerable people

This group should stay home at all times and reduce face-to-face contact as much as possible. Individuals in this group should not be in the workplace. These include:

• People receiving chemotherapy;• Renal dialysis patients; and• Hard organ donor recipients.

Clinically vulnerable people

This group can include, but is not limited to:

• People aged 70 or older;• People with liver disease; • People with diabetes; and• Pregnant women.

This group can be permitted to work but social distancing measures should be extremely stringent and further control measures may be required to safely accommodate them.

Vulnerable and extremely vulnerable people

Please sign in and access the COVID-19 Back to Business Hub and refer to the COVID-19 Health & Safety Policy Template in the COVID-19 Health & Safety Policy dropdown for an example section on vulnerable people that can be used and modified to set out your arrangements for conducting your Vulnerable Persons Risk Assessment.

Complete the Vulnerable Persons Risk Assessment Template within the COVID-19 Risk Assessment and control measures dropdown for each individual deemed to be vulnerable.



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Maintaining distances of two metres between individuals is particularly important in order to reduce the risks of a person encountering an air droplet containing COVID-19.

Social distancing

Please sign in and access the COVID-19 Back to Business Hub and refer to the COVID-19 Health & Safety Policy Template in the COVID-19 Health & Safety Policy dropdown for an example section on social distancing that can be used and modified to set out your arrangements for promoting and maintaining social distancing in the workplace.


Hands are one of the main pathways of COVID-19 transmission. People frequently encounter bacteria, viruses and other germs through:

• Handling foods and drinks; • Touching handrails, table tops and other objects; and• Using toilets and public environments

These can then enter the body via the eyes, nose and mouth from hands.

Guidance

Important information to remember:

• Washing hands with soap removes germs much more effectively than just water alone. 20 to 30 seconds is deemed the most effective time to allow the soap and water to remove the harmful germs from the skin. With a shorter contact time, the soap may not have the most desired effect.

• Wetting hands first enables the soap to properly lather, allowing it to cover the front and backs of hands including thumbs.

• When washing hands, people will often focus only on the insides and palms of the hands. Harmful germs can live on the backs of hands and thumbs, so it is important to ensure that these areas are washed thoroughly.

• The friction of a paper hand towel or cloth removes germs if you haven’t removed them with soap and water. As such, disposable towels should be preferred over hand dryers as these are better at removing germs and can be binned to prevent spread. If reusable towels are used, they will need to be washed at high temperature to kill any germs.

Effective hygiene

Please sign in and access the COVID-19 Back to Business Hub and refer to the COVID-19 Health & Safety Policy Template in the COVID-19 Health & Safety Policy dropdown for an example section that can be used and modified to set out your arrangements for promoting effective hygiene in the workplace.



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COVID-19 can be spread by touching contaminated surfaces and then touching your eyes, nose and mouth. Cleaning an area with normal household disinfectant will reduce the risk of passing the infection on to other people. The virus can potentially live on surfaces for up to 72 hours, so it is important to ensure that areas are cleaned on a regular basis.

Cleaning regime

Please sign in and access the COVID-19 Back to Business Hub and refer to the COVID-19 Health & Safety Policy Template in the COVID-19 Health & Safety Policy dropdown for an example section on cleaning that can be used and modified to set out your arrangements for promoting an effective regime in the workplace.

The Daily Cleaning Checklist within the COVID-19 Risk Assessment and control measures dropdown should be completed at each location in order to ensure that suitable cleaning practices are conducted to manage COVID-19.


Staff should be encouraged to bring their own food to work each day and staff canteens and distributors should move to takeaway(s). Where no practical alternatives exist, workplace canteens may remain open to provide food to staff with appropriate adjustments for social distancing.

Eating areas

Please sign in and access the COVID-19 Back to Business Hub and refer to the COVID-19 Health & Safety Policy Template in the COVID-19 Health & Safety Policy dropdown for an example section that can be used and modified to set out your arrangements for promoting effective controls in eating areas within the workplace.



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COVID-19 is a respiratory illness, spread largely through respiratory droplets from coughing and sneezing, and it enters the body through the eyes, nose and mouth. As such, PPE has an important role to play in controlling the risks presented by COVID-19. However, it is important to remember that PPE appears at the bottom of the Hierarchy of Controls because its effectiveness is dependent on the person wearing it properly. Other measures should therefore be considered first.

PPE has been recommended for workers who are coming into close contact with persons with the virus. These include doctors, nurses, and healthcare professionals/staff. The government has stated that the control measures listed below are far more effective in non-healthcare settings and should be used in conjunction with PPE, where supplied:

• Stay at home if you have respiratory symptoms (coughing, sneezing, shortness of breath) and/or a temperature above 38C (100.4F).

• Shield coughs and sneezes with a tissue, elbow, or shoulder (not bare hands).

• Wash your hands often with soap and water for at least 20 seconds or use a 60% alcohol-based hand sanitiser.

• Routinely disinfect any frequently-touched surfaces, such as workstations, countertops and doorknobs.

• Increase cleaning of common areas using standard cleaning agents.

• Adhere to social distancing of two metres between yourself and other people.

Personal Protective Equipment (PPE)

Please sign in and access the COVID-19 Back to Business Hub and refer to the PPE Guide within the COVID-19 Risk Assessment and control measures dropdown to conduct an assessment to decide whether PPE is required in your workplace



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Unless absolutely essential, you should aim to limit visitors and contractors to your workplace as this will reduce the risk of transmission.

Site visitors and contractors

Please sign in and access the COVID-19 Back to Business Hub and refer to the COVID-19 Health & Safety Policy Template in the COVID-19 Health & Safety Policy dropdown for an example section that can be used and modified to set out your arrangements for receiving visitors and contractors in the workplace. Otherwise, you will need to introduce certain arrangements.

Complete the Contractor Checklist – Inviting Contactors on Site document within the COVID-19 Risk Assessment and control measures dropdown for all visiting contractors prior to them arriving on site. The Deliveries Risk Assessment Template may also be used.


If your employees undertake visits to other businesses, you must ensure that safe measures are in place before doing so.

Visiting other premises

Please sign in and access the COVID-19 Back to Business Hub and complete the Contractor Checklist – Site Safety document within the COVID-19 Risk Assessment and control measures dropdown before an employee is sent to another organisation’s premises.


Although there is an argument that commuting to a place of work may not be under the jurisdiction of an employer, if the virus is spread amongst workers, this will potentially have a damaging effect to any organisation.

Getting to work

Please sign in and access the COVID-19 Back to Business Hub. Depending on how your employees travel to the work, please refer to the COVID-19 Health & Safety Policy Template in the COVID-19 Health & Safety Policy dropdown for example sections on commuting to work that can be used and modified accordingly.


https://elliswhittam.com/covid-19/registerhttps://elliswhittam.com/covid-19/registerhttps://elliswhittam.com/covid-19/register

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Dealing with emergencies

It is important to put procedures in place to deal with worst-case scenarios. You will need to compile a COVID-19 Emergency Action Plan to outline how you will respond to a suspected case of COVID-19, particularly where the person potentially could have spread this to others. You must then communicate this plan to all employees and relevant parties, including visitors.

The incident may potentially be RIDDOR reportable. You are only required to make a report under RIDDOR (The Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013) in relation to COVID-19 when:

• An unintended incident at work has led to someone’s possible or actual exposure to COVID-19. This must be reported as a dangerous occurrence.

• A worker has been diagnosed as having COVID-19 and there is reasonable evidence that it was caused by exposure at work. This must be reported as a case of disease.

• A worker dies as a result of occupational exposure to COVID-19. If this occurs, we strongly recommend contacting us to discuss. Further information can be found on the HSE website.

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Emergency Action Plan

All “Helpful Hub document” activities for this section are located within the Dealing with emergencies dropdown.File-alt

Please sign in and access the COVID-19 Back to Business Hub and use and modify the Emergency Action Plan. Communicate this to all members of staff and display it in a prominent position within the workplace.


During the pandemic, you may have reduced employees within the premises. It is therefore important to review your arrangements for first aid and fire. You must ensure that there is sufficient first aid provision on site for anyone who continues to work there. This means you must review the first aid needs risk assessment to ensure there has been no impact.

First aid

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During the lockdown, it is likely that your fire risk will change, which means that you should review you fire risk assessment. If your workplace has been closed or work activities have changed significantly, this will change your fire risk.

Before reoccupying the workplace, make sure that your fire alarms and emergency lighting functions properly. Are all fire extinguishers in their correct location? Are fire doors robust? Do you have a sufficient number of fire marshals returning to work or do arrangements need to be made to train others?

You will need to ensure your Fire Risk Assesment is reveiwed for accuracy of the control measure identified.

Fire safety

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Statutory checks

Employers must ensure that statutory inspections as required under health and safety legislation continue to be undertaken. Checks on such items as lifting equipment and pressure systems will need to be undertaken in accordance with the inspection schedule for as long as they continue to be used.

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All “Helpful Hub document” activities for this section are located within the Statutory checks dropdown.File-alt

Please sign in and access the COVID-19 Back to Business Hub and Use the Empty Building Checklist and Reoccupation Checklist to record important checks of your premises before returning to work after lockdown.


Staff information and training

It is most important that you inform and train your staff on the measures they can take to protect themselves and others from contracting COVID-19. This means sharing with them your COVID-19 Health & Safety Policy and the findings of your risk assessments, including the control measures you have implemented. You may wish to do this electronically or by providing a hard copy. You must also display the ‘Staying COVID-19 Secure in 2020’ notice.

All “Helpful Hub document” activities for this section are located within the Staff information and training dropdown.File-alt

Please sign in and access the COVID-19 Back to Business Hub and use the COVID-19 Toolbox Talk to deliver staff training on COVID-19.

Display the ‘Staying COVID-19 Secure in 2020’ poster in your workplace.

Further guidance information available on the Back to Business Hub that can be shared with staff includes:

• Symptoms Chart• Health & Safety FAQ (England and Wales)• Health & Safety FAQ (Scotland)



Monitoring

All employees will need to be proactively checked for symptoms prior to entry onto site. Any indications of raised body temperatures or symptoms will be a likely indicator for that employee to return home.

There is much debate as to whether thermometers should be used. A temperature reading may not always indicate a fever and may give a false sense of security. A temperature reading may also give a false indication of temperature, which may have been affected by someone sweating, walking or cycling to work, etc. An organisation may decide to take temperature readings; however, this has not been advised by the government as necessary at present.

Monitoring of symptoms

All “Helpful Hub document” activities for this section are located within the Monitoring dropdown.File-alt

Measuring the effectiveness of your COVID-19 control policy is essential, hence you should ensure that you are actively monitoring conditions and behaviours in the workplace.

You should conduct a daily management check to ensure you are managing the control measures that have been put in place.

Daily checks

Please sign in and access the COVID-19 Back to Business Hub and use the Daily Management Checklist to help structure your monitoring checks.

The organisation will also need to keep up to date with the latest government advice by ensuring that the official guidance is checked on a daily basis for any significant changes.


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https://elliswhittam.com/covid-19/registerhttps://www.gov.uk/guidance/social-distancing-in-the-workplace-during-coronavirus-covid-19-sector-guidance

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The government is currently expanding the testing network to different demographics of the population. It is strongly recommended that people are tested for COVID-19 if they are eligible, whether they are symptomatic or not. It is important to check the guidance regularly on this point.

If the person qualifies for testing, they should visit the government website and book a test. A decision on their return to work can be made based on receiving these results. If a member of staff has helped someone who was taken unwell with a new, continuous cough or a high temperature, they do not need to go home unless they develop symptoms themselves.

There are currently both regional and home-based tests being completed:

• Regional testing is where the individual to be tested drives to a site or mobile testing station.

• Home-based testing is where the individual has a test delivered to them at home.

Testing

Please sign in and access the COVID-19 Back to Business Hub and refer to the Testing FAQ for more information and answers to common questions.

When an employee undergoes testing, the Testing Record should be completed and kept confidential.

If an employee has been off work and been diagnosed with COVID-19 or had suspected symptoms, the Return to Work Form will need to be completed and appropriate action taken.


ReviewYou must review your COVID-19 Health & Safety Policy on a regular basis to ensure it remains effective and aligns with current government guidance and legislation. We recommend working with staff to assess what is and isn’t working and continually refine your controls to ensure that they offer the best possible protection against COVID-19.


To find out how we can support your organisation with your Employment Law, HR & Health & Safety needs call us on 0345 226 8393.

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covid-19 health & safety back to business workbook · covid-19 health & safety back to business...

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