COVID-19 RISK MANAGEMENT AT THE WORKPLACE
COVID-19 RISK MANAGEMENT AT THE WORKPLACE
The coronavirus is a new hazard that will require the implementation of new risk control measures. The world is currently in transition into what is being described as the “new normal”. The Government strategy has been to facilitate the mitigation of the risk exposure by the imposition of lockdowns in order to reduce the spread of infections.
COVID-19 Risk Management
Risk assessments for a re-opening of the workplace or a return to work must therefore:
- meet the “suitable and sufficient” criteria in that they identify foreseeable hazards, evaluate risks and implement the risk control measures that reduce risks to the ‘as low as reasonably practicable” (ALARP) criteria by following best practice
- be completed by competent persons (ie those with the skills, knowledge and experience to do so) but with input from others familiar with the working environment including employees and/or their representatives
- communicate outcomes to employees and others in terms of residual risks and risk control measures to be adopted
- be reviewed where there is “significant change” in matters to which the risk assessment relates or where it is suspected the risk assessment is no longer valid.
In terms of COVID-19, employers may have to justify risk management decisions and control measures taken to stakeholders including employees, trade unions, enforcing authorities, clients, etc.
As such, employers should ensure their framework for completing risk assessments is robust and capable of meeting the criteria noted above. As such employers should consider the following.
- Scoping: how will the organisation scope the assessment process (eg by building, by service or a combination of both) to ensure relevant risk control measures are identified and applied?
- Responsibilities: has the organisation determined who will be responsible for taking ownership and completion of the risk assessments and how the views of others can be included in the process?
- Upskilling: do those responsible have an understanding of the risk assessment process and access to all relevant guidance and information on the coronavirus to enable them to complete assessments?
- Methodology: can the current methodology be utilised to risk assess COVID-19 risks or does the methodology need to be adjusted?
- Hazard identification: has the organisation identified all useful sources of information on the hazards and risk control measures associated with COVID-19?
- Risk control: has the organisation agreed minimum standards of risk control (eg Government COVID-19 secure guidelines, Ministry of Health guidelines, association guidelines)?
Practicalities of Risk Control
Under health and safety requirements employers should have a competent person available who will be experienced at taking Health & Safety guidance and applying this in a practical manner in the workplace.
One approach is to examine the organisation and break down the potential hazards into people, property and management issues.
People Risk
Employees can be broken down into a number of working groups such as employees who:
- work from home undertaking general office work
- cannot work at home due to the work activities (eg manufacturing goods)
- work in public facing roles (eg insurance, banks, libraries, supermarkets)
- are peripatetic (eg plumbers, community workers, those who travel or go to other people’s premises to do their job)
- are vulnerable (due to COVID-19 or a protected characteristic).
For each group it is then possible to identify the hazards (direct and indirect) by breaking roles down and then by reviewing the relevant guidance. In this way organisations can decide on the risk control measures to reduce risks to as low as reasonably practicable based upon social distancing and risk mitigation.
For example with employees working in public facing roles, there is a foreseeable risk of COVID-19 transfer by proximity to members of the public but also through the transfer of items (eg library books, cash) where the virus may be present. Indirect risks may include what could be described as “COVID-19 violence” (eg public deliberately coughing at employees) as well as an increase in aggression (eg due to increased waiting times due to new procedures).
Buildings Risk
In respect of buildings, hazards may include the following:
- Failure to identify and apply social distancing and risk mitigation measures in workplaces.
- Failure to identify and apply revised cleaning regime to workplaces.
- Non-compliance with legislative requirements in buildings that have been empty (eg lifts thorough examination, testing of fire alarms, water hygiene).
- Ongoing proactive maintenance and reactive repairs that do not meet social distancing requirements.
- Failure to identify responsibilities in leased and/or multi-occupancy buildings for application of measures.
- Deliveries to and from the premises (eg postal, goods, merchandise).
Organisations with multiple sites will need to assess each building in terms of the application of social distancing and/or risk mitigation measures along with enhanced cleaning regimes. This in itself can create a “logistical hazard” due to resources and the application of official guidance in the work environment.
Similarly, it is important to ensure all relevant compliance requirements are met before the workplace is brought out of lockdown, while essential planned maintenance and repair activities will require thought.
Management Risk
There will be a series of management hazards that will need to be considered:
- fire evacuation arrangements (eg limited fire brigade responses, PPEs and social distancing, assembly points)
- first aid (eg coverage, certification expiration, undertaking of treatment such as CPR, etc)
- supply of sanitisers/PPE equipment due to supply and demand issues
- supply chain management to ensure contractors apply/abide by control measures
- employee information, instruction, training and supervision needs to apply control measures
- communication with stakeholders over revised risk control measures (eg contractors, public, visitors)
- employee mental health and stress due to changes and concerns over COVID-19
- procedures for dealing with COVID-19 illness, eg if a member of staff falls ill at work
- reporting of COVID-19 related incidents such as COVID-19 violence, breach of social distancing, first aid treatment given, etc.
These clearly are a mixture of direct and indirect issues that will need addressing and as such organisations must identify all relevant guidance.
Conclusion
There is no doubt that COVID-19 will change workplace business risk profile including the health and safety risk profile. Your organisation’s COVID-19 risk profile will be required to be kept under constant review as the national strategy is liable to change.