As a consequence, increasing numbers of employers and workplace professionals are looking at what they should be doing now, to maintain compliance, reassure staff and promote a safe and healthy working environment.
So, this month we’ve looked at what changes have and are occurring and what this could mean for those responsible for managing buildings. Combining these with some of the questions we’re being asked by customers, below is an update on the current state of play.
1. COVID-19 – How are the National requirements changing?
We continue to see a difference in the ongoing COVID-19 requirements across the UK.
In England, from the 1st April 2022, all remaining restrictions were removed, and COVID-19 has been incorporated into the public health advice for any respiratory infection, such as colds and flu. The key messages that remain are:
- Get vaccinated;
- Let fresh air in if meeting indoors, or meet outside; and
- Consider wearing a face covering in crowded enclosed spaces.
Except for the over 75 years and those over 12 years with a compromised immune system, free lateral Flow Tests (LFT) are no longer available.
In Scotland, most legal restrictions have been removed, although on public transport and in some indoor settings, face coverings will be required until 18th April 2022 (this will then become guidance).
Free COVID-19 tests will be available until the end of April 2022 and from the 1st May 2022:
- People with symptoms no longer need to test, but will be advised to stay at home while they persist; and
- Contact tracing ends.
Advice includes - Coronavirus (COVID-19): guidance - gov.scot (www.gov.scot)
In Wales, the requirement for face coverings has been removed, but recommended for shops or on public transport, although still compulsory in health and social care settings.
Wales is continuing with a testing programme until the end of June 2022, with free LFT for people with symptoms. Contact tracing also remains in place.
Advice includes - Coronavirus (COVID-19) | Topic | GOV.WALES
In Northern Ireland, most COVID-19 restrictions have already been removed, along with the need to self-isolate (although it is strongly advised). Free LFT testing will be available to the end of June 2022.
Advice includes - Coronavirus (COVID-19) | nidirect
As there has been historical differences in how the various parts of the UK has managed their pandemic response, these changes are unlikely to cause further issues. However, as organisations we need to be clear on the expectation and messaging for staff, particularly where you have introduced your own sets of rules/requirements.
2. COVID-19 – What about workplace guidance?
The suite of workplace guides first published by GOV.UK in May 2020 have now all been withdrawn and replaced by one document “Reducing the spread of respiratory infections, including COVID-19, in the workplace”.
While it still covers COVID-19, it is more general in nature, highlighting flu as another example. Six main headings are included:
- Who this information is for?;
- Know which symptoms to look out for;
- What to do if a member of staff has symptoms of a respiratory infection, including COVID-19;
- Actions to reduce the spread of respiratory infections, including COVID-19;
- Management of members of staff who are at risk of serious illness from COVID-19; and
- Risk assessment.
It identifies its target audience for the information as “employers, workforce managers (of both paid staff and volunteers) and people who are managing a workplace or organisation. This information will help you to understand how to reduce the spread of respiratory infections such as COVID-19 and flu in the workplace. This is especially important if there are people in the workplace whose immune system means they are at higher risk of serious illness from COVID-19.”
A link to the document is: Reducing the spread of respiratory infections, including COVID-19, in the workplace - GOV.UK (www.gov.uk)
The Health and Safety Executive (HSE) have also updated guidance, with much of the previous COVID-19 focussed content removed. Messaging has also changed with it being recognised that COVID-19 remains a public health issue, and the specific workplace guidance replaced with “Coronavirus (COVID-19) – Advice for workplaces”. This covers general information on the changes, including:
- COVID-19 restrictions are being replaced by public health advice;
- Complying with general health and safety law;
- RIDDOR reporting of COVID-19;
- Advice from public health bodies and other government departments;
- Protecting those who may be at higher risk; and
A link to this document is - Coronavirus (COVID-19) – Advice for workplaces (hse.gov.uk)
Except for those employers still directly working with the SARS-CoV-2 virus, in general, health safety and environmental compliance is defaulting back to the pre-pandemic situation. How the intervening time will have modified these in terms of what individual organisations now see as control, or indeed what the workforce now expects, remains to be seen.
What hasn’t changed is the need to be able to demonstrate effective compliance management against those risks, material to the organisation’s activities. Risk assessment and risk management are investments in this process. After something has gone wrong is really not the time to find out they were not suitable and sufficient. With numbers of suppliers still suffering the effects of the last two years, getting reliable, quality assured, and independent advice is more important than ever.
3. What about COVID-19 risk assessments?
Simply, unless you are an organisation (for example a laboratory) working with SARS-CoV-2, there is no longer a need to have a specific COVID-19 risk assessment (or consider it within your other workplace risk assessments).
The GOV.UK guidance does state “Employers may choose to continue to cover COVID-19 in their risk assessments” and the HSE point out that “it is important that as a business, organisation or an employer you continue to comply with your legal obligations relating to health and safety, employment and equality duties.”
With the increased employee awareness of health, safety and wellbeing, as more people return to workplaces, you need to make sure that the risk assessments and schemes of control you have in place are suitable, sufficient and effective.
4. COVID-19 - Do we still need to consider vulnerable people?
Most people who were identified as clinically extremely vulnerable (CEV) are now considered “well protected” if they have been fully vaccinated (including boosters). Women who are pregnant continue to be strongly advised to get vaccinated, and if they develop COVID-19 symptoms to seek medical advice.
Guidance for people previously considered clinically extremely vulnerable from COVID-19 - GOV.UK (www.gov.uk)
However, there remains guidance for people whose immune system could mean they may be at higher risk. In a workplace context, this will almost certainly be for individual consideration, rather than an influence on your overall workplace arrangements.
Information can be found at - COVID-19: guidance for people whose immune system means they are at higher risk - GOV.UK (www.gov.uk).
Such considerations will no doubt form part of your EDI processes and procedures. As with fire and first aid requirements, in a more occupancy varied work environment, attention does need to be given to the abilities of the organisation to meet these needs at all relevant times.
5. COVID-19 – Do I have to continue with my wider controls (e.g. ventilation and cleaning/hygiene)?
Despite the removal of the ventilation related advice due to COVID-19, both the HSE and GOV.UK continue to highlight the requirements of the Workplace (Health, Safety and Welfare) Regulations 1992. These cover ventilation (Regulation 6) and cleanliness (Regulation 9), and a host of other related areas including temperature, washing facilities, drinking water, workstations, and seating (Regulations 7,21,22 and 11 respectively).
As well as reducing the potential for the transmission of several respiratory viruses and other microorganisms, a well-managed workplace and indoor environment (air and water quality and occupancy comfort) can improve productivity, promote health and safety and reduce absenteeism.
While the GOV.UK information focusses on the need for “fresh air”, the HSE messaging in their “Ventilation in the workplace” guidance concentrates more on the risks associated with poor ventilation. It covers aspects such as:
- Assessing the risk of poor ventilation;
- How to improve ventilation;
- Keeping a comfortable temperature;
- Using CO2 monitors; and
- Examples of improving ventilation.
The amount of recirculating air and use of Carbon dioxide monitors (CO2) are increasingly being left to the discretion of the employer/duty holder.
A link to the document is - Overview - Ventilation in the workplace (hse.gov.uk)
Again, both the HSE and GOV.UK have provided information on cleaning and cleanliness within the workplace. Under “Maintain a clean workplace” in the GOV.UK advice “Reducing the spread of respiratory infections, including COVID-19, in the workplace”, they highlight:
“Keeping workplaces clean reduces the risk of infection and can reduce sickness in a workforce. It’s especially important to clean surfaces that people touch a lot. Staff can be supported to maintain a clean working environment by providing them with cleaning products, soap and hot water, and/or sanitiser.”
Within the HSE guidance “A safe place of work”, as part of wider information on facilities they include:
- provide clean floors and stairs, with effective drainage where necessary
- provide clean premises, furniture and fittings
- provide containers for waste materials
- remove dirt, refuse and trade waste regularly
- clear up spillages promptly
- keep internal walls or ceilings clean
Hygiene and welfare
You must provide:
- clean toilets and hand basins, with running hot and cold or warm water, soap and towels or another suitable means of drying
- drinking water
- somewhere to rest and eat meals, including facilities for eating food which would otherwise become contaminated
- showers for dirty work or emergencies
- drying facilities for wet work clothes, if practical and necessary
- accommodation or hanging space for personal clothing not worn at work (and somewhere to change if special clothing is worn for work)
- rest facilities for pregnant women and nursing mothers
- In some circumstances your risk assessment will highlight the need to provide additional specific controls, for example:
- skin cleansers, with nail brushes
- barrier cream and skin-conditioning cream where necessary
- certain facilities for workers working away from base, e.g. chemical toilets in some circumstances”
A link to this information is - A safe place of work (hse.gov.uk)
It is very possible that occupants will be far more questioning of their places of work and building environments, including air quality and hygiene standards. While the latter is usually very visible, the former is not so easily visualised.
Dust and microorganism levels, volatile organic compounds (VOC), filter efficiencies, plant maintenance and system balance, all play as much a part in your indoor environmental performance as do CO2 levels and recirculation rates.
With variable rates of occupation likely to continue, and further cold snaps predicted, getting enough heat into the building can be problematic for some. This in turn could mean greater recirculation of air within the building to meet occupancy comfort (temperature, humidity and airflow) requirements (not to mention energy use too!). They will all need to be considered as part of your return strategy.
Having over 35 years of experience monitoring workplace environmental conditions (air and water quality and occupancy comfort), we typically find that well managed and well maintained workplaces deliver very good results. Whether they were recognised and reported on, is of course another matter. We are here if you need us.
Assurity Consulting is the UK’s leading independent consultancy specialising in workplace health, safety and environmental solutions. As your partner in compliance management you will reap the benefit of our more than 35 years’ experience of helping customers across a range of different sectors – manage their compliance responsibilities as effectively as possible. If you need any help with your health, safety or environmental compliance, or if you would like more information on the services Assurity Consulting offer, please get in touch.