As isolation is eased and people return to work, governments across the UK are requiring organisations to complete risk assessments as part of the permission to resume normal service.
Health and safety law requires employers, who continue to operate under current circumstances, to do ‘what is reasonably practicable’ to protect their staff and members of the public.
As an employer, you’re required by law to protect your employees, and others, from harm. Under the Management of Health and Safety at Work Regulations 1999, the minimum you must do is:
To fulfil this duty in addressing the risk from COVID-19 all companies must review their risk assessments and put in place measures to ensure the guidance available from their respective governments (in England, Northern Ireland, Scotland and Wales) is implemented.
Risk assessment covering exposure to Covid-19 will be different from one organisation to another. Healthcare workers, retail cashiers, home delivery drivers, utility engineers and construction workers have different exposure to this risk.
A risk assessment should recognise the virus as a hazard. It should also reflect that the virus is spread in minute water droplets that are expelled from the body through sneezing, coughing, talking and breathing.
The virus can be transferred to the hands and from there to surfaces. It can survive on surfaces for a period after transfer (depending on such things as the surface type, its moisture content and temperature). The risk assessment should conclude that if it is passed from one person to another, while many survive infection, some may die from the disease. It should be regarded as a high hazard.
The safety hierarchy of control can serve you well in considering what can be done. Any mitigation controls devised and implemented must reduce exposure of employees and anyone else who could be infected by your employees.
Control considerations must include identification of those who may have the disease, preventative measures and what to do if you find if an employee has contracted the disease. In other words, there may be elements of management systems design to think about. Decisions about what may be done must be realistic and reasonably practicable: achievable given the resources available.
Elimination is the best form of control. Can we eliminate the virus? Only through vaccination, so there is little that can be done by organisations. They are reliant on government response. Organisations should monitor vaccine availability and the priority of their workforce in any future vaccination programme so that arrangements can be made promptly. Social distancing and staying at home are not forms of elimination, but an administrative control.
Next in descending order is substitution: replacing the virus for something less harmful is not possible. Engineering controls place a physical barrier between the person and the hazard, or provide mechanical reduction of the hazard. Placing screens between people (e.g. cashier points in shops) will interrupt the flow of air from one person to another and therefore provide protection.
Providing ventilation is also an option. Recent research has shown that downward ventilation onto a patient’s bed considerably reduces the exposure of healthcare workers to infected droplets suspended in the air. Care must be taken if ventilation is to be considered. The fundamental question is where the potentially infected water droplets are ventilated to. It’s no good if they are blown onto other people or surfaces and increase exposure elsewhere. But as a principle it is worthy of some consideration e.g. ask whether the job must be done in a workshop, or can be done outside.
But then also consider exposure to ultraviolet radiation and other risk. Ventilation is a good control if it takes infected air away from people and transfers it to somewhere where the virus will not do harm.
Administrative controls provide the best options for most organisations. The risk assessment must consider how you will keep the workplace and equipment clean, adjust your working practices and ensure people are safe.
As an ISO consultancy obviously there is a big focus on taking a risk-based approach and the assessment of risk, evaluating effectiveness of control measures, complying with regulations, legislation, etc.
As businesses start to mobilise they’ll have the twin issue of new, immediate significant risks which will have arisen due to the pandemic alongside dealing with budget constraints and limited compliance resources.
We’ve been helping businesses in these scenarios, assessing their risk and conducting a review with the aim of identifying core compliance requirements. Much of this has been driven by their own clients requiring supply chains to undertake a proper Risk Assessment of current working arrangements.
Significantly, the crisis may have caused companies to find new suppliers that have not been fully vetted due to time pressures. Likewise, the pandemic may have caused substantial risks to employee safety associated with reopening businesses, such as effective social distancing. This emerging risk will likely call for the development of new policies and procedures that will require close oversight by senior management.
Our review will usually entail a historic review of internal procedures and controls to identify past activities or other problems to determine where the biggest risks reside. At this point we undertake a detailed COVID-19 Risk Assessment. External industry risks such as enforcement actions are considered as well.
But for those businesses who simply want to undertake their own detailed assessment, we are giving away the template we use for free. You can simply download it here.
There is no catch, we won’t ask you to sign up for anything, simply download, conduct the Risk Assessment and get back to work!
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