Amongst several sector specific guides issued by the Government on 11 May, there is a 31 page document for those working in offices and contact centres. It has been prepared to help employers, workers and the self-employed understand how to attend work safely during the various phases of the easing of the lockdown.
It reminds employers about their legal obligations to provide a safe working environment and safe system of work for workers, as well as complying with existing obligations relating to individuals with protected characteristics under the Equality Act 2010, such as those with disabilities who may be at high risk if they catch COVID-19.
The cornerstone of the Guidance is about enabling workers in offices and contact centres to attend work but still observe social distancing as much as possible.
From an employer’s point of view, the key point that will apply is the need to carry out a COVID-19 risk assessment, just as employers would do for other health and safety related hazards.
The assessment must be done in consultation with unions or worker health and safety representatives. A workplace health and safety representative must be selected by a recognised trade union or if there is not one, chosen by workers themselves. They must be involved in discussions about managing risks and employers must listen to what they have to say, not ignore them.
Employers should not overlook that the current lockdown guidance is for those who can work from home to continue to do so for the foreseeable future. Employers should continue to facilitate this wherever possible.
When home working is not possible, every reasonable effort should be made to comply with social distancing, that is, keeping people 2 metres apart wherever possible. If social distancing cannot be followed, then this raises the question of whether the particular activity placing workers at risk of not being able to observe the 2 metre rule needs to continue for the business to operate and if so, take all mitigating actions possible to reduce the risk of transmission between staff.
Mitigating actions include:
• keeping activity time involved as short as possible;
• using screens or barriers to separate people from each other;
• using back to back or side to side working rather than face to face wherever possible; and
• reducing the number of people each person has contact with - by using fixed teams or partnering so that each person works with only a few others.
No one is obliged to work in an unsafe work environment, particularly those who are especially vulnerable to COVID-19.
Risk assessment results
The Guidance recommends sharing the results of the risk assessment with your workforce and publishing the results on your website. The Guidance provides a template notice that should be displayed in the workplace to show staff that employers have followed this Guidance. The notice sets out the five steps to safer working together that have been signed off by the employer; and a name of a person to contact about the risk assessment or the number and website of the Health and Safety Executive.
Who is to go into work?
When deciding who should go to work, employers must consider who is essential to be on site and allow others to continue to work from home. Those remaining on site are likely to be workers in roles critical for business continuity, safe facility management or regulatory requirements which cannot be performed remotely.
Some workers may be able to perform their roles remotely but may be unable to do so due to home circumstances or unavailability of equipment. For these people required on site, employers should plan for the minimum number of people needed to operate safely and effectively, whilst monitoring their wellbeing so that they stay safe but connect with their colleagues.
One of the objectives of the Guidance is to protect clinically vulnerable and clinically extremely vulnerable individuals, with the latter continuing to be required to shield themselves from any contact with other people. Extremely vulnerable individuals are those, for example, with pre-existing conditions such as cancer or have undergone an organ transplant. Vulnerable individuals are those with breathing problems, anyone entitled to an influenza jab (free of charge) or pregnant women. Clearly, the message for people who need to self-isolate is that you need to stay at home.
Arrivals and departures
There is guidance for employers on those coming to and leaving work to maintain social distancing wherever possible on arrival and departure, with, especially, handwashing upon arrival.
This means staggering arrival and departure times to reduce crowding in and out of the workplace, providing additional parking or other facilities such as bike racks to help people walk, run or cycle to work where possible, thus reducing public transport use.
For the workplace, this means having more entry and exit points into the workplace, using markings and introducing one way flow at entry and exit points, providing more storage for workers for clothes and bags and providing alternatives to touch-based security devices such as keypads or fobs. Or even deactivating pass readers at turnstiles in favour of showing a pass to a security personnel at a distance.
Managing social distancing
The Guidance recommends eliminating hot-desking and if hot-desking is necessary, work stations should be shared by the smallest number of people and cleansed between occupancy shifts. Reducing job and equipment rotation is also to be recommended. One way flow through the buildings is repeated often throughout the Guidance.
Supermarkets are a good example of using floor tape or paint to mark areas to keep 2 metre social distancing and the Guidance suggests that this is key to ensuring that social distancing is maintained in the workplace. Green markers may be used to limit desk usage and maintain social distancing.
If meetings do have to take place, the objective is to reduce virus transmission from face to face meetings by maintaining social distancing in meetings and dispense with objects like pens and other materials that can so easily be shared. Certainly hand sanitisers should be present in meeting rooms.
These areas for employees to gather for breaks or meals need to be risk assessed and recommendations include:
• working with landlords and other tenants in multi-tenant buildings to ensure consistency in common areas such as receptions and staircases;
• staggering break times to reduce pressure on break rooms or places to eat;
• using safe outside areas for breaks;
• creating additional space;
• using protective screening for staff in receptions or similar areas;
• encouraging storage of personal items in personal storage spaces;
• regulating the use of locker rooms and changing areas to reduce concurrent usage;
• providing pre-packaged meals to avoid opening staff canteens; and
• re-configuring seating and tables to maintain spacing and so reduce face to face interactions.
The guidance recommends cleaning the workplace before reopening after lock down and keeping the workplace clean with deep cleaning, restrictions on the use of high touch equipment and plenty of hand washing sanitation facilities.
The Guidance suggests that unless employers are in a situation where the risk of COVID-19 transmission is very high, then the risk assessment should reflect the fact that the role of PPE (personal protective equipment) and providing additional protection is extremely limited. However if the risk assessment does show that PPE is required, then this must be provided free of charge to workers who need it and such PPE must fit properly.
The Guidance is full of helpful steps broken down by activity and aspects of working life in offices and contact centres. The Government promises to update it regularly to deal with changes to the overall assessment of the risk to public health.