With the majority of organisations now returned to operation, either fully or partially, work activities should have been reviewed and the risk of the spread of COVID-19 assessed for your workplace, your work activities and your employees.
The return to work has identified a number of concerns and frequently asked questions, which we cover below. In this article, we answer the following:
Please click a question to jump to the answer quickly.
- My risk assessment and procedures state that staff must ‘follow government guidelines’, is that enough?
- A member of staff has been in contact with someone who has tested positive, what should we do?
- A member of staff has developed symptoms whilst at work, what should we do next?
- How do I know if an employee has been exposed to Coronavirus at work?
- Our risk assessment has identified activities in which the risk of the spread of COVID-19 is increased and we have purchased masks which are available in the storeroom for staff to use at their discretion. Is this sufficient?
- We have enhanced cleaning procedures in place in practice, what documentation and records should we have for this?
- Our risk assessments are documented and available in a file for staff to read, is this enough?
- We have a COVID-19 risk assessment in place, how often should it be reviewed?
1) My risk assessment and procedures state that staff must ‘follow government guidelines’, is that enough?
No. Your risk assessments should refer to the elements of government regulations and guidelines which apply to your organisation.
Your safe working procedures should outline precautions that will be required to be followed by staff, including the circumstances when this would apply (as identified by your risk assessment). This would include legal requirements or precautions recommended in government guidelines.
2) A member of staff has been in contact with someone who has tested positive, what should we do?
You should have clear and documented procedures for self-isolation, which should outline what staff should do if they:
- Are displaying symptoms of Coronavirus – a high temperature, a new, continuous cough, a loss or change to their sense of smell or taste.
- Live in the same household as someone who has symptoms or has tested positive.
- Have been in close contact with someone who has symptoms or has tested positive.
- Have been notified by government Test, Trace and Protect (TTP) to self-isolate.
- Have returned from overseas travel and are required to self-isolate.
This includes procedures on what an individual should do if they develop symptoms, or are notified by TTP whilst at work, i.e. who they should report this to, requirement to leave the workplace immediately and avoiding further spread through travel where possible.
Procedures must outline that if there has been contact with a positive COVID-19 case (including if notified by Test, Trace and Protect) individuals must self-isolate for 10 days (14 days for particular variants – this will be confirmed by the NHS Test and Trace staff), regardless of a negative test result – as it can take up to 10 days for symptoms to develop. Staff must not be permitted to return to work until their self-isolation period is completed.
Procedures must also outline that anyone with symptoms should obtain a test within 5 days of developing symptoms and must self-isolate:
- If individuals test negative, providing they have no further symptoms and have not been in contact with a positive case in the last 10 days, would be permitted to return to the workplace.
- If individuals test positive, they must continue to self-isolate for 10 days from the onset of symptoms. If they have no symptoms, the 10-day isolation period must start from the date of the positive test result.
3) A member of staff has developed symptoms whilst at work, what should we do next?
As part of risk assessments, you should have emergency procedures documented on the steps to be taken to prevent further spread within the workplace. You should consider:
- If the symptomatic individual could not leave the workplace immediately, is there an area or room that could be used to segregate the person from the rest of the workforce until safe travel home can be arranged?
- Would you be able to identify the areas in which the infectious person has been, including work areas and communal areas (staff room, kitchen, toilets, etc.), to arrange for the area to be closed off until deep cleaning can be arranged or until 72 hours has passed?
- Do you have the information of everyone in the workplace on that day/time to be able to establish those who will need to be notified to self-isolate? This should include staff, visitors and contractors. Does information for visitors and contractors include contact information required for Test, Trace and Protect purposes?
- Would you be able to identify individuals who may have been in contact with the symptomatic person 48 hours before symptoms developed? Examples of contact includes having skin-to-skin physical contact, being coughed on, having face-to-face contact (under 1 metre) for any length of time(including talking, even if a face covering or face mask is worn), being within 1 to 2 metres of each other for 15 minutes or more (this can be a single exposure or cumulative, including travelling in a vehicle).
- Do you have a procedure on how individuals will be notified if they are suspected as being in close contact with a symptomatic or COVID-positive person whilst at work?
4) How do I know if an employee has been exposed to Coronavirus at work?
If it is suspected that employee(s) have contracted Coronavirus at work, this may be reportable under the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (RIDDOR).
There must be reasonable evidence linking the nature of the person’s work with an increased risk of becoming exposed to Coronavirus. For example:
- There is more than one employee who has tested positive who could have reasonably been in contact with others at work or have a shared work environment/equipment etc.
- The nature of the person’s work activities increased the risk of them becoming exposed to Coronavirus (e.g. providing care to someone who is symptomatic or COVID-positive).
- There has been a specific, identifiable incident that led to an increased risk of exposure (e.g. an employee provided first aid to/was in physical contact with someone who has fainted and subsequently tests positive for Coronavirus).
- The person’s work directly brought them into contact with a known Coronavirus hazard without effective control measures (as set out in the relevant PHE guidance) in place, such as personal protective equipment (PPE) or social distancing.
5) Our risk assessment has identified activities in which the risk of the spread of COVID-19 is increased and we have purchased masks which are available in the storeroom for staff to use at their discretion. Is this sufficient?
No. Your risk assessments should have identified additional hazards within the workplace, such as:
- Activities or use of equipment involving face-to-face contact.
- Work involving physical contact.
- Working within 2m of other people.
- Working in teams or groups.
- Using equipment/items used by others or shared between individuals.
- Working in areas that are enclosed or deemed a confined space.
- Working in areas where maintaining hygiene and handwashing may be an issue.
- Work involving employees or volunteers who are deemed as being in the at-risk category, vulnerable or shielding.
You should ensure that you can demonstrate that all reasonable steps have been taken to reduce the risk to the lowest level as reasonably practicable.
Where such steps involve a requirement to wear suitable personal protection equipment (PPE), such as masks/visors/face protection, these should be issued to staff directly along with appropriate information, instruction and training.
You should ensure that your risk assessment and information, instructions and training for staff details:
- The type of PPE required and where such items must be worn.
- Instructions for donning, wearing and removing PPE to avoid contamination.
- Procedures that must be followed for disposable items of PPE, i.e. single use, disposed of after use.
- Procedures that must be followed for reusable items of PPE, i.e. cleaning of PPE to avoid contamination, storage between use etc.
- Emergency plans for disposal of items/materials if someone is symptomatic or COVID-19 positive. Click here to learn more.
- Procedures for obtaining replacement PPE.
- Reporting procedures for reporting PPE-related issues and non-compliance in the workplace.
6) We have enhanced cleaning procedures in place in practice, what documentation and records should we have for this?
In order to evidence any COVID-19 related precautions being adopted, it is recommended that the following documentation is produced and kept up-to-date:
- Risk assessments identifying any needs for additional or enhanced cleaning as a precaution and also assessing the risk of contact with hazardous substances.
- Cleaning schedule outlining what is cleaned (e.g. touch points, toilets, shared equipment etc.), frequency of such cleaning (e.g. hourly, daily, twice daily etc.), who the cleaning is carried out by (e.g. toilets may be cleaned by cleaning staff, whereas individual desks may be cleaned after use by staff), what should be used for cleaning (outlining substances and materials to be used for cleaning, such as Dettol spray and disposable cloth), any safety precautions to be followed (e.g. diluting procedures, requirements for personal protective equipment etc.). Some substances may not normally require the use of PPE, however items of PPE may be required to prevent the spread of COVID-19 if cleaning in populated areas or cleaning of communal or shared facilities.
- Copies of Safety Data Sheets (SDS) for individual cleaning products and substances used.
- Copies of specific COSHH Risk Assessments for each substance.
- Emergency plans for additional/deep cleaning in the event of a symptomatic person and/or positive case within the workplace itself.
- Evidence of any safe working procedures or information and instructions provided to staff in relation to cleaning. This may also include evidence of any signage displayed in the workplace that relates to cleaning procedures, cleaning checks etc.
7) Our risk assessments are documented and available in a file for staff to read, is this enough?
No. Given the changing situation with COVID-19 in the UK and changes that can occur within the workplace itself, it is recommended that significant findings and material updates to risk assessments are communicated clearly and effectively to relevant persons (such as employees, volunteers, temporary staff, customers etc.).
It is also recommended to remind and refresh information and instructions on the risk and the workplace precautions that must be followed – this could take the form of staff bulletins, signage, toolbox talks or training.
8) We have a COVID-19 risk assessment in place, how often should it be reviewed?
Procedures should be in place to allow for planned reviews and unplanned reviews.
Planned Review: This would be a periodic review to ensure that the risk assessment is still valid for the workplace, its conditions and reflects current government legislation and HSE guidance. It is recommended that COVID-19 risk assessments are reviewed monthly at this current time.
Unplanned Review: Risk assessments would need to be reviewed following a material change or incident.
For example: If new measures have been introduced to manage the risk, such as split shifts, cohorting teams, installing barriers etc.
Or, for example, if there has been a person reporting symptoms whilst at work or identification of a positive case who has attended the workplace.
Have Any More Questions?
If you need further advice or additional information, please contact our Health & Safety team today on 02920 853794 or at firstname.lastname@example.org.