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COVID-19 Risk Management

Beyond Level 0 (v1) – Advice for Employers

Introduction

After some 16 months of considerable COVID-19 related restrictions (based on ‘Protection Levels 0-4’), Scotland moved to ‘Beyond Level 0’ at midnight on the 9th of August 2021. The most significant changes include the following:

Physical distancing is no longer required
There are no limits in the number of people you can meet
‘Close contacts’ of positive cases who show a negative PCR and have received 2 doses of the vaccine do not need to self-isolate
Whilst home working should be maintained where possible with employers being encouraged to consider a hybrid model for the longer term, some staff may now go back to the office in line with their wellbeing requirements and the business needs

Whilst the majority of restrictions have now been lifted, some do remain (importantly the continuation of face-coverings in certain settings) and the virus continues to circulate in society. Therefore, it is important that employers still consider COVID-19 as a very real hazard, presenting a potential risk if not properly managed.

Our previous COVID-19 pages contained a considerable amount of information and links which were based on a range of guidance materials that have no validity in ‘Beyond Level 0’. Therefore, this revised guidance now contains basic pointers on the current position of the Scottish Government and HSE and aims to highlight the main considerations to manage the risk in a pragmatic manner. It is of course entirely possible that the situation may change over time (possibly even at very short notice) and this guidance will be updated accordingly.

Contents

COVID-19 Risk Assessment and Safe Working Arrangements
Precautionary Measures

2.1 Face Coverings in the Workplace

2.2 Self-isolation

2.3 Ventilation

2.4 Vaccination and Workplace Testing

2.5 Office vs Remote Working

2.6 Travel and Transport

2.7 General Good Practice Considerations

2.8 Useful Links

1 COVID-19 Risk Assessment and Safe Working Arrangements

The general advice being given to employers is to:

Follow the Scottish Government’s guidance and any industry guidance that may apply
Continue to conduct and regularly review risk assessments
Continue to work with employees, or employer representative, on health and safety matters.
Help employees to understand the steps they can take to prevent COVID-19 spreading in the workplace

COVID-19 Risk Assessments and the development of suitable control measures and safe working arrangements remain the cornerstone of both this guidance and the relevant legal requirements. The Scottish Government is now recommending the HSE guidance to carry out risk assessments, which can be found here.

Note also that the Scottish Government has stated the following in respect of risk assessing competence, so please do seek help and advice where appropriate: “Employers should ensure that their Health & Safety professionals and representatives have the skills, training and knowledge to understand the risks associated with COVID-19. Where there is no access to these skills in-house, external support options should be explored.”

As part of the risk assessment, employers must:

Identify what work activity or situations might cause transmission of COVID-19
Think about who could be at risk – this could include workers, visitors, contractors, the public and delivery drivers
Decide how likely it is that someone could be exposed
Identify the controls needed to reduce the risk

Key control measures to help manage the risks should include adequate ventilation; sufficient cleaning; and good hand hygiene. It is also essential to provide training to employees to ensure they are sufficiently briefed on any new working arrangements and to include a monitoring / supervising regime to check that your control measures are working as expected.

The Scottish Government has also developed a self-assessment tool to assess the effectiveness of COVID-19 control measures within your workplace.

Guidance is also available for employers with employees at highest risk (previously known as ‘shielding’). Employees at highest risk should not be discouraged from going back to the office should they prefer to do so. However, having a robust risk assessment in the workplace is essential and individual risk assessments should also be carried out for all employees at highest risk. The Scottish Government has developed guidance to help employers carry out individual occupational risk assessments.

In developing and reviewing your risk assessments, cognisance should be taken of the precautionary measures detailed below.

2 Precautionary Measures

A range of precautionary measures have been defined by the Scottish Government and will be reviewed every 3 weeks. These are classified as mandatory or advisory.

Mandatory precautionary measures include wearing a face-covering (as per existing requirements) and self-isolating when showing symptoms or testing positive. Advisory precautionary measures include getting vaccinated, maintaining good hand hygiene and surface cleaning, promoting good ventilation and maintaining the ‘work from home’ practice or having a hybrid approach to employees’ return.

2.1 Face Coverings in the Workplace

Face coverings must be donned in any indoor communal area in the workplace or where there are no measures to keep the employees at least 1 metre apart. The guidance for wearing face coverings in the workplace is detailed here.

2.2 Self-isolation

Employees with COVID-19 symptoms or who test positive should self-isolate immediately and follow advice from ‘Test and Protect’, even if they have received both doses of the vaccine. Employees who have been identified as ‘close contacts’ of positive cases will, however, not need to self-isolate if they have 1) received both doses of the vaccine and 2 weeks have passed since the second dose; 2) are asymptomatic and 3) return a negative PCR test (note that a negative LFD result is not sufficient here).

Employers should follow the advice given in the Scottish Government’s COVID-19: Fair work statement which states that no worker should be financially penalised by their organisation for following medical advice, and any absence from work relating to COVID-19 should not affect future sick pay entitlement, result in disciplinary action or count towards any future sickness absence related action.

2.3 Ventilation

Despite having been classified as an advisory precautionary measure, good workplace ventilation remains an important control measure to prevent COVID-19 spread. The Scottish Government has developed comprehensive guidance on ventilation for workplaces that can be found here. The HSE has also produced guidance on ventilation that should be considered in the risk assessing process.

In addition to assessing and aiming to optimise your workplace ventilation requirements, the monitoring of CO₂ levels is also being suggested (as an indicator of fresh air requirements) in many situations.

2.4 Vaccination and Workplace Testing

Employers should encourage their employees to take the vaccine, which includes granting time paid off to attend their appointments and sharing and displaying information leaflets.

Rapid test kits for workplace testing are also available in Scotland for business with at least 10 employees to help prevent outbreaks at work and to break the chain of spread in asymptomatic employees.

2.5 Office vs Remote Working

A gradual return to offices can now begin but the Scottish Government is asking employers to consider a hybrid model of home and office working for the longer term, which may have benefits beyond the need to control a virus. Therefore, is important that employers continue to support their employees with home/remote working whilst taking account of their business needs.

When prioritising a return to the office, some key considerations are:

Who would benefit from a return to work on mental health or disability grounds?
Who has less appropriate settings for working at home?
Who needs to be in the workplace for priority business reasons?
Who is new to the organisation and requires training/mentoring (and who is needed to support this)?
Who would benefit most from collaborative working in person?
Is there a sufficient provision of first aid and fire safety duty holders?

Further information can be found here.

2.6 Travel and Transport

Unnecessary work-related travel should be avoided and the following advice should be followed:

Minimise non-essential travel – i.e. consider remote options first
Minimise the number of people travelling together in any one vehicle; use fixed travel partners; increase ventilation when possible (such as by opening windows); and avoiding sitting face-to-face
Ensure drivers and passengers maintain good hygiene and wash their hands regularly
Clean any shared vehicles between shifts or on handover

Advice on how to travel safely can also be found in the website of Transport Scotland.

Border controls for international travel have been retained and must be taken into account by employers where employees travel for business needs or go abroad on holidays. Further guidance can be found here.

2.7 General Good Practice Considerations

The following key principles should be followed by employers and employees and may be useful in the development of risk assessments and safe systems of work:

Think about keeping everyone safe: provide information to staff and visitors about your control measures and encourage your employees to be considerate of others.
Maximise the use of outside space: encourage the use of outdoor space for meetings and breaks.
Keep distance between people where you can: establish limits on room/area capacities and manage the flow of people, even now that the statutory requirements for physical distance have been removed, as this is well known to help to control virus spread.

Some practical control measures could include:

- staggering break times to reduce pressure on break/eating areas
- using outside areas for breaks and meetings, where possible and appropriate
- reconfiguring seating and tables to maximise space
- using protective screening
- regulating use of locker rooms, changing areas and other facility areas to reduce concurrent usage
- minimise congested areas in the premises such as narrow corridors, staircases, doorways and storage areas by introducing one way systems
Avoid the generation of crowds or larger groups.
Design a plan to manage infections and outbreaks within the workplace.
Consider long-term plans for home/hybrid/flexible/remote working and the new Health, Safety and Wellbeing considerations that this might bring (remember that employers are responsible for these no matter where the employee works).

Address ‘moving around the workplace’, which may include the following:
- physical distancing (see above).
- one-way systems on walkways, taking into account disabilities.
- reducing maximum occupancy for lifts, providing hand sanitiser for the operation of lifts and touch-points and encouraging use of stairs.
- making sure that people who are disabled are able to access lifts whilst encouraging physical distancing and other protective measures.
- regulating use of high traffic areas including corridors, lifts, turnstiles and walkways.

Consider how meetings can be carried out as safely as possible, for example:
- using remote working tools to avoid in-person meetings.
- only necessary participants to attend meetings with physical distancing being encouraged.
- avoiding the sharing of pens or other objects.
- providing hand sanitiser in meeting rooms.
- holding meetings outdoors or in well ventilated rooms.

Plan shift-patterns to minimise numbers, optimise productivity and reduce the need for traveling at peak times or consider ‘Work Cohorts’ where a job role requires groups of the same workers to work in proximity.
Train employees in any new control measures and the principles of COVID-19 risk control.

Consider the Mental Health and wellbeing of employees, for example by:
- supporting a work/life balance and encouraging staff to manage working hours hours, eat lunch away from their desk and try to get fresh air during the day.
- keeping in touch – maintain regular, scheduled contact.
- reminding staff of the support available.
- encouraging home/remote workers to create a productive working environment by working in a quiet space and in an uncluttered environment.
Follow guidance from Transport Scotland when vehicle sharing is necessary.
Handle inbound and outbound goods in the safest way possible, bearing in mind hand hygiene, ventilation, access to the premises of visitors, etc.
Address workplace facilities safety issues when re-opening premises (e.g. Legionella within water supplies, out of date fire risk assessments, gas servicing overdue, etc.)

2.8 Useful Links

The following links contain useful guidance for moving your workplace and operations Beyond Level 0:

The ACS Team

0141 427 5171

info@acsrisk.com

training@acsrisk.com