With further restriction having, albeit for just a month hopefully, again re-emerged, maintaining COVID-19 Secure and building operations is very much back in focus.
With changes to a number of the high impact activities such as air quality, water and fire now relatively well established, for this month we’ve picked three areas that may not be as obvious, but along with a plethora of others still need consideration, particularly as occupancy rates continue to fluctuate.
Below are the three questions for you to consider by investing 15 minutes of your time to review your processes and procedures. In addition to the questions, supporting information is provided for you on each of the topic areas.
- How has your portable electrical appliance management been affected over the last 6 months?
- Have you reviewed your workplace provision for people with disability and those at increased risk of COVID-19?
- What about your asbestos management?
1. How has your portable electrical appliance management been affected over the last 6 months?
The Electricity at Work Regulations 1989 requires dutyholders to make sure that any electrical equipment (that has the potential to cause injury) is maintained in a safe condition. Portable appliance testing (PAT) describes the methodology used to examine electrical appliances and equipment to ensure they are safe. This is usually completed through a combination of visual inspections and testing. A risk-based approach should be used on the type of equipment and environment within which it is used, to determine the frequency and extent of checks you carry out.
The Health and Safety Executive advise “brief user check (based upon simple training and perhaps assisted by the use of a brief checklist) can be a very useful part of any electrical maintenance regime. However, more formal visual inspection and testing by a competent person may also be required at appropriate intervals…”
Most dutyholders already have established procedures in place, but where might the disruptions caused by COVID-19 have adversely affected these?
- If you were due more formal checks or testing over the periods of “lock-down” and they didn’t occur, have these since this time been identified and reinstated?
- With more agile working, has a review of how your electrical equipment is now used been and your scheme of checks and test amended accordingly?
- Have those employees now using electrical equipment remotely and possibly in a range of different environments been advised of the checks needed/they should carry out as relevant to your policy?
- With the reconfiguration of your workplace to meet COVID-19 Secure requirements, for example has any:
- Daisy chaining of electrical supplies or damage to equipment occurred?
- Personal electrical equipment found its way back into the office?
- Electrical equipment been removed that needs to come of your PAT register?
2. Have you reviewed your workplace provision for people with disability and those at increased risk of COVID-19?
COVID-19 Secure has seen less people in the workplace and modifications to a number of procedures - covering everything from access/egress to fire. These in turn could present significant changes for especially those with a disability, needing additional support or at greater risk of contracting COVID-19.
For many employees needs assessments on workstations, work locations (home/agile) and shift patterns have been successfully adjusted to accommodate the changes.
- Have your COVID-19 and other risk assessments, as applicable, be reviewed and amended as necessary to consider the impact on groups such as ethnic minorities, pregnant and older workers that may be at greater risk?
- For employees working at home who routinely use equipment in the office such as voice activated software, how do they access and who pays for such aids?
- Have all your Personal Emergency Evacuation Plans (PEEPs) been reviewed to reflect any changes to procedures caused by COVID-19? As applicable, have you consulted with your landlord/tenants on any changes, so both are aware, and an understanding of the wider implications can be gained?
- Should you review your evacuation procedures to confirm that disability egress is adequately included and have these been rehearsed?
- Have you reviewed for example that the emergency alarms in accessible washrooms are properly operational and that items such as the emergency pull cord have not been tied up?
- Have you practiced your documented procedures for when the accessible washrooms emergency pull cord alarm is activated? This should include checking all local and remote alarms.
- Have you reviewed your company website to confirm that it has been updated, as needed, and includes all relevant access and inclusivity information?
3. What about your asbestos management?
The pandemic has seen a rapid and changing shift in priorities and activities for those managing the workplace. Air and water quality, fire, remote work and hygiene, to name but five areas, have all been directly impacted and affected by COVID-19 Secure. There are though a myriad of other aspects of health and safety that other things may have been indirectly impacted by these changes too. Asbestos is one of them.
For some, in particularly newer (post 1999) buildings, and where they can demonstrate they have no asbestos, it is fortunately not an issue. For others, where they have robust process in place and the asbestos they have is in good condition, well managed and away from likely disturbance, they too can rest slightly easier in the scheme of things.
But for those with asbestos still in readily accessible areas or management that may not be all it needs to be, it may be a different matter. You need to consider where any part of the workplace has been changed by you, your contractors, tenants or others (whether COVID-19 related or not), and where people could come into contact with and disturb any asbestos containing materials (ACM).
Regardless whether you are in the second or third of these groups, the following questions should help you to understand exactly where you are now, and if there are actions you need to be taking:
- Have you reviewed your asbestos management plan in the last 12 months?
- Do you have sufficient information about asbestos in all your buildings? Do your surveys cover all areas?
- Is your asbestos register up to date and do you know the condition of all your known ACM’s?
- Is your asbestos register included in your contractor induction procedure?
- Have all your staff received suitable training in asbestos awareness and/or management?
If, having checked each of these questions, the answer to any of them is “no”, there are actions you need to take.
A further consideration is, have any COVID-19 Secure, or other, changes made to your workplace likely to have caused someone to come into contact with any of your ACMs, have they become damaged or disturbed as a result of this activity?
Again, check what work has been done against your asbestos register and if any ACM are present in the area, review the condition to see if there have been any changes. If there are changes, you need to take some action. Remember to document it either way.