The new Return to Work Safely Protocol from the Health and Safety Authority, HSE and Department of Health provides government guidance for employers and workers on the measures required to prevent the spread of COVID-19 in the workplace. At all times decisions to re-open a workplace should be in done in compliance with Government and public health advice.
As challenges change, this cross-sectoral protocol may be supplemented by further guidance, and amended in view of how businesses are coping with the new way of working. To date no specific inspection regime has been included, and a high-level consultative stakeholder forum will be established to oversee this transition.
Strong communication and a shared collaborative approach between employers and employees is key to protecting workplaces against the spread of COVID-19. The protocol recommends regular engagement between employers and workers on preventative measures, and employers are to provide information and guidance including the signs and symptoms of COVID-19, how it spreads, cleaning routines, advice on hand and respiratory hygiene, physical distancing, use of Personal Protection Equipment (PPE) and work equipment where relevant.
Each employer is required to appoint at least one lead worker representative whose role is to work collaboratively with the employer to assist in the implementation of these measures and monitor adherence. The number of representatives appointed will, ideally, be proportionate to the number of workers. This will be alongside the ongoing consultation with health and safety representatives required in every workplace.
The protocol covers workers, not just employees, so consider all contingent, agency, consultants, suppliers who may attend your workplace.
It demands a lot of preparation and a need to stay on top of changing government advice. It also requires induction, training and ongoing communications with employees across the organisation, in essence daily. The implementation of preventative measures will be resource heavy and expensive for organisations of all sizes. It encourages employees to remain working remotely as much as possible, and the maintenance, where possible, of social distancing once workplaces re-open.
The people profession will be centre-stage in making such transitions successful, and a strategic organisational approach backed up by people-centred decisions at group and one to one level will be key to instilling a positive working culture.
Getting Back to Work guidance
The Protocol provides Getting Back to Work guidance and outlines the key steps summarised below for both employers and employees to reduce the risk of exposure to COVID-19 in the workplace.
Develop and/or update the COVID-19 response plan
The Protocol requires updating your business COVID-19 response plan and occupational health and safety risk assessments. Then employers have to address the risks associated with various workplaces and work activities, for example, where and how workers might be exposed, including the general public, customers, co-workers, communal spacing, entrance and exits. etc. Consider individual risk factors of employees (for example, older workers, underlying medical conditions, etc) and how these can be mitigated. and plan contingency measures in case of a suspected case of COVID-19, increased absenteeism, changing work patterns, etc. It advises that these plans are developed in consultation with workers and communicated once finalised.
Develop or amend policies and procedures for prompt identification and isolation of workers who may have symptoms of COVID-19
Employers are to keep a log of contact/group work to facilitate contact tracing, as well as displaying signs and symptoms of COVID-19, up to date information on public health advice and what to do if an employee develops signs and symptoms of COVID-19 while in the workplace. Employees must make themselves aware of the signs and symptoms of COVID-19, monitor their own well-being, immediately report any symptoms that arise at work, and self-isolate at home and follow public health advice if they display any signs or symptoms.
Develop, consult, communicate and implement workplace changes or policies
As information about the virus is evolving, public health advice is being updated on a regular basis, and it is important for employers and workers to recognise that flexibility will be required in meeting the measures to reduce its spread.
Employers are advised to review sick leave policies and consult and amend as appropriate in view of COVID-19. Where occupational health service is available, this should be used to help address worker concerns/anxieties and for communicating/training around good hand hygiene, respiratory etiquette and physical distancing. Alternatively, use the public health advice from the HSE and other sources as appropriate and involve the COVID-19 lead worker representative/s in communications. Agree any temporary restructuring of work patterns that may be required to implement the prevention measures.
Implementing the COVID-19 prevention and control measures to minimise risk to workers
Employers must issue a pre-return to work form for workers to complete at least three days in advance of the return to work. The worker must confirm that they have no symptoms of COVID-19 and also that they are not self-isolating or awaiting the results of a COVID-19 test.
It is necessary to provide induction training for all workers, to include the latest up to-date advice and guidance on public health; what to do if they develop symptoms of COVID-19; how the workplace is organised to address the risks; an outline of the COVID-19 response plan; points of contact for the employer and the workers; and any other sector specific advice that is relevant.
The guidance reinforces that the best way to prevent person-to-person spread of COVID-19 is to use proper hand hygieneand respiratory etiquette and practice physical distancing and provides further details on dealing with suspected cases.
Employers must ensure that appropriate hygiene facilities are in place and provide advice and training and posters on how to perform hand hygiene effectively. Employees must not share objects that touch their mouth, for example, bottles or cups and must use own pens for signing in. The Protocol advices that cleaning of work areas must be conducted at regular intervals (see ECDC advice) and employees should have essential cleaning materials to keep their own workspace clean.
On respiratory hygiene employers must provide advice, tissues as well as bins/bags for their disposal, and empty bins regularly.
Employers must provide for physical distancing across all work activities, the current government recommendation is two metres of separation:
- The protocol says this can be achieved in a number of ways, including implementing a no hand shaking policy, organising workers into teams who consistently work and take breaks together and prevent gatherings of workers at the beginning and end of working hours. Teams should be as small as is reasonably practicable in the context of the work to be done.
- Breaks and break areas should be organised in such a way as to facilitate maintenance of physical distancing, for example, placing tables and chairs far enough apart, staggering and extending serving times, using a queue management system with correct distance markings, and considering closing canteen facilities if public health measures cannot be facilitated.
- Where two metre worker separation cannot be ensured alternative protective measures should be put in place, for example, installing physical barriers, such as clear plastic sneeze guards between workers, maintain at least a distance of one metre or as much distance as is reasonably practicable, and minimising direct worker contact and providing easy access to hand washing facilities, hand sanitisers, so workers can perform hand hygiene as soon as the work task is complete. Face masks can be used in line with Public Health advice.
- At Risk/Vulnerable Workers should work from home and if not, they are preferentially supported to maintain a physical distance of two metres. Generally, office work should continue to be carried out at home, where practicable, and a working from home policy should be developed.
- Business trips and face-to-face interactions should be reduced to the absolute minimum and, as far as practicable, technological alternatives should be used. For necessary work-related trips, the use of the same vehicles by multiple workers is not encouraged. Where face to face meetings are absolutely necessary, the length of the meeting and the numbers attending should be kept to a minimum and participants must maintain physical distancing at all times. A system for recording visits to the site(s) by workers/others as well as visits by workers to other workplaces should be put in place.
- The protocol recommends one way systems for access/egress routes in the workplace where practicable, adapting existing sign-in/sign-out measures and systems to ensure that physical distancing can be maintained.
While correctly using PPE - Personal Protective Equipment can help prevent some exposures, it should not take the place of other preventative measures as outlined. Examples of PPE include gloves, goggles, respiratory protection. Use of PPE may already be required in many workplaces to address occupational health and safety risks, for example, exposure to hazardous chemicals such as asbestos. In the context of COVID-19 risk, employers should check the HPSC website regularly for updates regarding use of recommended PPE, and implement temperature testing in line with Public Health advice.
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