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12.05.2020

Yesterday, the Government published guidance on Working safely during COVID-19 in factories, plants and warehouses (Guidance on Working Safely), as well as a ‘road map’ of next stages in the response to the pandemic in its document, Our plan to rebuild.

There is a shift of emphasis in relation to work. The message continues to be that for the foreseeable future, workers should continue to work from home rather than their normal physical workplace, wherever possible. However, from 13 May 2020 those who cannot work from home should go to work if their workplace is open and is ‘COVID-secure’. Note that businesses that were ordered to close must remain closed.

Employers have a duty to reduce workplace risk to the lowest reasonably practicable level by taking preventative measures. The Guidance on Working Safely is non statutory, but sets out recommendations of steps that manufacturing companies should consider in order to comply with this duty to reduce workplace risk. Each business will need to translate the Guidance into specific actions it needs to take depending on the nature of the business. Relevant factors include the size and type of business, how it is organised, operated, managed and regulated.

Manufacturing companies are advised to read the Guidance on Working Safely in full. It covers the following issues:

Key principles

  • Employees should work from home, if they can. This will involve planning for the minimum number of people needed on-site to operate safely and effectively and monitoring the wellbeing of people who are working from home.    
  • You should make every reasonable effort to comply with the 2 metre social distancing guidelines for those who cannot work from home and whose workplace has not been told to close.
  • Where people cannot be 2 metres apart, transmission risk should be managed by considering whether that activity needs to continue for the business to operate. If the activity is required, you must take all reasonably practicable mitigating actions to reduce the risk of transmission between staff, recognising that you cannot completely eliminate the risk of COVID-19.
  • If you have not already done so, you should carry out an assessment of the risks posed by COVID-19 in your workplace as soon as possible to establish what improvements may be required to meet the government guidelines. You should do this with your workforce representative or trade unions. You should think about the risks your workforce may face, identify sensible measures to control those risks and take all reasonably practicable steps to minimise them. You should have particular regard to whether the people doing the work are especially vulnerable to COVID-19.
  • You should reinforce cleaning processes, before you re-open part or all of workplace and on a continuing basis. The workplace should be cleaned more frequently, paying close attention to high-contact objects like door handles, stair rails and keyboards.
  • You should display a notice in your workplaces to show your employees, customers and other visitors to your workplace that you have followed the government’s guidance. If possible, you should publish the results of your risk assessments on your website.

The Guidance on Working Safely provides detailed examples of steps that will usually be needed to comply with this guidance. It breaks this down into measures relating to social distancing at work; managing your customers, visitors and contractors; cleaning the workplace; personal protective equipment (PPE) and face coverings; workforce management; and inbound and outbound goods.

Steps to maintain social distancing of 2 metres

The Guidance on Working Safely recommends ways of maintaining social distancing of 2 metres which include:

  • consideration of how individuals move around buildings and worksites, such as creating one way walk-throughs and passing points and opening more entrances and exits;
  • reducing movement where you can;
  • maintaining social distances in between individuals who are at their workstations;
  • staggering access to common areas such as break rooms and changing seating lay outs;
  • re-designing workspaces to maintain 2 metre distances between people;
  • staggering start times to reduce crowding on the way in and out of the workplace;
  • revising procedures on fire evacuation and what to do in case of an emergency or accident;
  • minimising the number of meetings.

Mitigating actions where people cannot be 2 metres apart

The Guidance on Working Safely recommends that you take mitigating actions to reduce transmission of the virus where the social distancing guidelines cannot be followed in full and the activity needs to continue for the business to operate. Mitigating actions may include:

  • Increasing the frequency of hand washing and surface cleaning. Keeping the activity time involved as short as possible.
  • Using screens or barriers to separate people from each other.
  • Using back-to-back or side-by-side working (rather than face-to-face) whenever possible.
  • Reducing the number of people each person has contact with by using ‘fixed teams or partnering’ (so each person works with only a few others).

If people must work face-to-face for a sustained period with more than a small group of fixed partners, then you will need to assess whether the activity can safely go ahead.

Reinforcing cleaning processes

Before reopening, make sure that any site or location that has been closed or partially operated is clean and ready to restart.

Workplaces should be cleaned more frequently, paying close attention to high-contact objects like door handles, stair rails and keyboards. You should provide handwashing facilities or hand sanitisers at entry and exit points to help everyone keep good hygiene through the working day. Use signs and posters and even floor markings to build awareness of good handwashing technique and the need to increase handwashing frequency. Introduce cleaning procedures for the parts of shared equipment that employees touch after each use, thinking about equipment, tools and vehicles, for example, pallet trucks and forklift trucks.

PPE

The Guidance on Working Safely states that PPE beyond what employees usually wear is not beneficial. This is because Covid-19 is a different type of risk from the risks normally faced in a workplace, and needs to be managed through social distancing, hygiene and fixed teams or partnering, not through the use of PPE. Wearing a face covering will be optional in most businesses. If worn, employees must wash their hands before putting them on and taking them off. If PPE is required, the employer must cover the cost.

Who should go to work

The Guidance on Working Safely states that:

  • Clinically extremely vulnerable individuals have been strongly advised not to work outside the home.
  • Clinically vulnerable individuals (i.e. those who are shielding) have been asked to take extra care in observing social-distancing and should be helped to work from home, either in their current role or in an alternative role.
  • If clinically vulnerable (but not extremely clinically vulnerable) individuals cannot work from home, they should be offered the option of the safest available on-site roles enabling them to stay 2m away from others
  • Government guidance on self-isolation remains. Individuals who have symptoms of COVID-19 as well as those who live in a household with someone who has symptoms should not physically come to work.

Travel to and from work

In Our plan to rebuild, the Government indicates that when travelling everybody (including critical workers) should continue to avoid public transport wherever possible. If they can, people should instead choose to cycle, walk or drive, to minimise the number of people with whom they come into close contact during their commute to work.

How we can help

We are currently updating our FAQs and Back to Business Pack to reflect the new guidance and to provide advice about how the new guidance interacts with existing employment law and health and safety duties.

For further information about how to carry out a risk assessment or for support in introducing social distancing measures in your workplace, contact us on 0808 168 5874.

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