Whether returning to work feels like the 'baby steps' suggested by UK prime minister Boris Johnson or a huge and daunting task, easing of the lockdown has now begun. Those who cannot work from home are largely being 'actively encouraged' back into workplaces and while managing the COVID-19 risk doesn’t squarely fit within health and safety, it is clear that as OSH professionals you are best placed to help your organisation effect a safe return to work. OSH lawyer Rhian Greaves offers advice on reopening your workplace safely.
1. Start where you always do: return to first principles
Your organisation needs an overarching COVID-19 risk assessment as a basis for determining its control measures. Once that is complete, review existing risk assessments to satisfy yourself they are not adversely impacted by any new processes or procedures you propose.
2. Identify sources of guidance and use them!
Last night (11 May) the government published eight sector-specific guidelines designed to help businesses become 'COVID-19 secure'. There are also pre-existing industry guidelines, which provide more detail and context. IOSH has also published risk assessment guidance. Think more broadly too; the ONS data around the impact on specific job roles, for example.
3. Your staff are individuals: treat them as such
You may have pregnant workers, or those who have underlying conditions. They may have familial caring responsibilities for those who are shielding. There is also an emerging evidence base regarding those who are more likely to be seriously impacted by the virus; men appear more vulnerable than women, those in BAME groups similarly so. It may be that your risk management cannot be 'one size fits all'. Protecting the higher risk and maintaining equality in the workplace both feature in the COVID-19 secure guidelines.
4. Take your employees with you
Engagement will be the key to your success. We have all been affected by COVID-19 to some degree. We have consumed the news, we have discussed it at length and – as is well publicised – our collective mental health has been adversely impacted. Reassuring workers that they will be safe when they emerge from their personal safe havens will be vital; so involve them in the process. Consult with them, listen to their views as to how they think they can work safely. When you reach conclusions, publish these clearly so they know you have them very much in mind as operations recommence.
5. Communication is critical
The COVID-19 secure guidelines expect businesses with more than 50 workers to publish their risk assessments online. But you should not leave your communications there. Set out a strategy before your workplace opens. Include clear and consistent messaging around any new requirements or procedures. Think about training needs and consider equipping managers with FAQs to support your approach.
6. Don’t forget about homeworkers
On this the government is clear: 'For the foreseeable future, workers should continue to work from home…wherever possible'. Far from the very short-term potential thought likely at the outset of lockdown, we are approaching the third month of homeworking for many, perhaps with several more months to come. Think, therefore, about ergonomics – is a further assessment needed? Are communication paths working well? Are staff feeling involved? Is their mental health and wellbeing subject to monitoring?
7. Test, track, isolate
How will you do this? As the population begins to circulate more, so will the virus. Set a clear plan for identifying symptomatic workers, isolating them, obtaining testing and tracing those they work with. Reinforcing public health messaging consistently is important.
8. Who else are you working with?
Where your operations require third party participation, interrogate their strategies for minimising transmission risk. This is particularly so where you may rely on them more than normal, for example cleaning contractors. Keep an open dialogue so that you manage the risk in a co-ordinated way.
9. Keep up to date
This is no mean feat! Sector by sector, guidance will emerge while the prime minister has been clear that rules can be changed at short notice depending on the scientific evidence. Identify someone whose task it is to keep the business updated so that you can adapt if required.
10. Remember RIDDOR!
Where there is a COVID-19 diagnosis and there is reasonable evidence the virus was contracted at work, a report will be needed with failure to report remaining a technical criminal offence. The guidance is vague and healthcare-centric but the requirement applies across all sectors.
COVID-19 presents a challenge unlike any other. For those who have been away from their workplaces for months, there will be fears and concerns. There will also be many opinions. It is likely employees will feel emboldened to blow the whistle where a business fails in its management of the risk and that is why engagement is going to be so important. But you are the experts in risk management and while this is perhaps something you never anticipated being asked to manage, you are the best placed to do it and I wish you all the best as you do!
Rhian Greaves is associate partner – regulatory at Pannone Corporate