As businesses look to re-open following lockdown, the UK Government has published a set of guidance documents to assist a range of workplaces with advice on establishing safe operations. Gordon Tranter considers the updated advice given to people who work in or run factories, plants and warehouses.
Businesses restarting work in factories, plants and warehouses including industrial environments such as manufacturing and chemical plants, food and other large processing plants, warehouses, distribution centres and port operations need to make arrangements to ensure their works can work safely during the Covid-19 pandemic. To support the return to work of this type of business, the Government has published Working Safely During Covid-19 in Factories, Plants and Warehouses. The Government regularly updates this guidance.
An appropriate Covid-19 risk assessment
Before restarting work, employers need to carry out a risk assessment. Failure to complete a risk assessment which takes account of Covid-19, or completing a risk assessment but failing to put in place sufficient measures to manage the risk of Covid-19, could constitute a breach of health and safety law.
The risk assessment should identify the sensible control measures, in order of priority, necessary to minimise the risks to the health of workers and others, such as other employers or contractors sharing the workplace, from the Covid-19 virus. (The Coronavirus Return to Work Risk Assessment can be a good starting point.)
During the assessment, employers should realise that their legal duty to consult unions or workers can often be of value as the workers are likely to understand the risks and have ideas on how to work safely. The results of the risk assessment should be shared with the workforce. If possible, by publishing the results on the businesses website. All employers with over 50 workers are expected to do this. Businesses should demonstrate to their workers and customers that they have properly assessed their risks and taken appropriate measures.
The assessment should have particular regard to those workers who are especially vulnerable to Covid-19; see the Coronavirus Staff at Risk Assessment Template. From 1 August, clinically extremely vulnerable individuals (see the current NHS guidance for advice on who is in the clinically extremely vulnerable and clinically vulnerable groups), who were previously advised to shield at home, can go to the workplace as long as it is COVID-secure but should carry on working from home wherever possible. They should be involved in making decisions as to how to proceed. If extremely clinically vulnerable individuals cannot work from home, they should be offered the option of the safest available on-site roles, enabling them to maintain social distancing guidelines.
In drawing up a plan to manage the risks, employers should consider a gradual return to work to test the preventive measures in practice and ensure they can work with larger numbers before encouraging more of their workforce back.
Throughout the assessment, the security implications of any changes that are intended to make to the operations and practices in response to Covid-19 should be considered as any revisions may present new or altered security risks which may need mitigations.
Two routes of infection
The Covid-19 virus spreads from person to person through respiratory droplets produced when an infected person coughs or sneezes. These can land in the mouths or noses of people who are nearby or possibly be inhaled into the lungs. The droplets can also cause an infection if they land on a hand, or if a surface they have landed on is touched, and the face is touched with unwashed hands.
Transmission of the virus is more likely when people are in close contact with one another (within about 6 feet). Consequently, the main methods of preventing transmission is social distancing staying 2m (6ft) apart from other people and hygiene measures. The assessment needs to identify where and when these modes of transmission may occur and to do everything practical to manage the risk of transmission.
The first option for controlling risk is to make every reasonable effort to enable working from home. Managers need to keep in regular contact with employees who work at home, helping them stay connected to the rest of the workforce and to monitor their working arrangements including their welfare, mental and physical health and personal security.
Where employees cannot work from home, every reasonable effort to comply with the social distancing guidelines is set out by the Government. Where the social distancing guidelines cannot be followed in full, in relation to a particular activity, businesses should consider whether that activity needs to continue. If it is necessary, all the mitigating actions possible to reduce the risk of transmission between their staff should be taken.
If people must work face-to-face for a sustained period with more than a small group of fixed partners, then it will be necessary to assess whether the activity can safely go ahead. No one is obliged to work in an unsafe work environment.
Where the social distancing guidelines cannot be followed in full, the following mitigating actions should be considered.
Redesign of work areas and managing occupancy levels to enable social distancing.
Using back-to-back or side-to-side working (rather than face-to-face) whenever possible.
Keeping activity times as short as possible.
Using screens or barriers to separate people from each other.
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).
In the latest update to the guidance, an additional mitigating action has been added discouraging shouting/loud music. Loud speech and singing can lead to increased production of respiratory droplets. Steps should be taken to avoid people needing to unduly raise their voices to each other, including, but not limited to, refraining from playing music or broadcasts that makes normal conversation difficult and may encourage shouting.
It is important that 2m social distancing is maintained in the most demanding areas such as while:
arriving at and departing from work
travelling within the workplace and between sites
at their work stations
in break rooms and canteens and similar settings.
Arriving and leaving work
The following steps can be used when coming to and leaving work to maintain social distancing wherever possible:
staggering arrival and departure times at work to reduce crowding into and out of the workplace
having more entry points to the workplace to reduce congestion
using markings and introducing one-way flow at entry and exit points.
More information is available in the guidance, Coronavirus (Covid-19): Safer Travel Guidance for Passengers.
Travel through the workplace
Maintaining social distancing while people travel through the workplace can be achieved by reducing movement by:
discouraging non-essential trips within buildings and sites, eg restricting access to some areas and encouraging use of radios or telephones to replace the trips
introducing one-way flow through the building
reducing maximum occupancy for lifts and encouraging use of stairs wherever possible
regulating use of high-traffic areas including corridors, lifts, turnstiles and walkways.
It is preferable to use digital meetings and conferencing systems to avoid person-to-person meetings. Only participants whose presence is essential should attend meetings.
Steps that can be employed to maintain social distancing in meetings include:
having floor signage in areas where regular meetings take place to help maintain social distancing
holding meetings outdoors or in well-ventilated rooms whenever possible.
It is against the law to gather in groups of more than 30 people in private homes (including gardens and other outdoor spaces). Businesses following Covid-19 secure guidelines can host larger groups. This is also the case for events in public outdoor spaces that are organised by businesses, provided they take reasonable steps to mitigate the risk of transmission, in line with Covid-19 secure guidance and including completion of a risk assessment. Any other gathering in an outdoor space must not be any larger than 30 people.
There is growing evidence that wearing a face covering in an enclosed space helps protect individuals and those around them from Covid-19. The Government has updated Working Safely During Coronavirus (Covid-19) in Factories, Plants and Warehouses to recommend that face masks and other face coverings (such as home-made cloth masks or scarves) are now widely used as one public health measure to limit the transmission of Covid-19. The Government has made it a legal requirement to wear face coverings in shops and public transport.
A face covering is something which safely covers the nose and mouth. Reusable or single-use face coverings can be purchased. Scarves bandanas, religious garments or hand-made cloth covering can be used, but must securely fit round the side of the face.
Employers should support their workers in using face coverings safely if they choose to wear one. Workers using face coverings should be instructed on how to use face coverings safely. This includes:
washing their hands thoroughly with soap and water for 20 seconds or using hand sanitiser before putting a face covering on, after removing it and at regular intervals
avoiding touching their face or face covering, as this could contaminate them with germs from their hands
changing their face covering if it becomes damp or if the wearer has touched it
changing and washing the face covering daily
if the face covering material is washable, washing it in compliance with the manufacturer's instructions; if it is not washable, disposing of it
practise social distancing wherever possible.
Remember that face coverings are an additional protection and not a replacement for the other ways of managing risk.
The Covid-19 virus can be spread by respiratory droplets landing on a surface and contaminating the surface then transferred by people's hands. If someone's hand is contaminated and they touch their eyes, nose or mouth, this can introduce the virus into their body.
The preventive measures require cleaning, handwashing and hygiene procedures. This should include:
increasing the frequency of handwashing and surface cleaning
making handwashing facilities readily available at all times particularly at entry/exit points
providing hand sanitiser where handwashing facilities are unavailable, eg outside lifts and in meeting rooms
regularly cleaning handwashing facilities and checking soap and sanitiser levels
providing suitable and sufficient rubbish bins for hand towels and tissues, with regular removal and disposal
avoiding transmission by not sharing tools and other implements.
Signs and posters should be used to build awareness of good handwashing technique, the need to increase handwashing frequency, to avoid touching the face and the need to cough or sneeze into a tissue which is binned safely, or into your arm if a tissue is not available. There should be regular reminders to maintain hygiene standards.
Before the restart of any site or location that has been closed or partially operated must be made clean and ready to restart. An assessment of all parts of the site should be carried out before restarting work.
This will include checking whether there is a need to service or adjust ventilation systems, particularly to ensure they do not automatically reduce ventilation levels due to lower than normal occupancy levels.
Cleaning procedures need to be put in place and hand sanitiser provided before restarting work.
Once the workplace is open, the workplace must be kept clean and transmission by touching contaminated surfaces must be prevented. This will involve:
frequent cleaning of work areas and equipment between uses
frequent cleaning of objects and surfaces that are touched regularly, such as door handles, pump handles and work equipment
the provision of disposable wipes together with adequate disposal arrangements so that commonly used surfaces can be wiped down by workers themselves
clearing workspaces and removing waste and belongings from the work area at the end of a shift.
If it is necessary to deep clean after a known or suspected case of Covid-19, refer to the specific guidance Covid-19: Cleaning of Non-healthcare Settings.
Handling goods, merchandise and onsite vehicles
Procedures should be put in place to reduce transmission through contact with objects and vehicles that come into the worksite. These procedures will usually include:
cleaning procedures for the parts of shared equipment tools and vehicles, eg pallet trucks and forklift trucks, after each use
encouraging increased handwashing
ensuring there are handwashing facilities, or hand sanitiser where this is not practical, for workers handling goods and merchandise.
Prevention steps for specific areas
Certain specific areas or activities will require specific steps to be taken to implement social distancing and to prevent respiratory droplets landing on a surface being transmitted to the face via the hands.
The following steps should be considered to maintain 2m social distance between individuals when they are at their workstations.
Changing layouts, line set-ups or processes to allow people to work further apart from each other.
Using floor tape or paint to mark areas to help workers keep to a 2m distance.
Where it is not possible to move workstations further apart, arranging people to work side-by-side or facing away from each other rather than face-to-face.
Where it is not possible to move workstations further apart, installing screens to separate people from one another.
Using a consistent pairing system if people have to work in close proximity, for example, during two-person working, lifting or maintenance activities that cannot be redesigned.
The way shift work is organised needs to be changed to create distinct groups and reduce the number of contacts each worker has. This can be achieved by:
as far as possible, where workers are split into teams or shift groups, arranging these teams or shift groups so that where contact is unavoidable, it is between the same people
identifying areas where people have to directly pass things to each other, such as job information, spare parts, samples, raw materials, and finding ways to exclude direct contact, such as through the use of drop-off points or transfer zones
assisting the test and trace service by keeping a temporary record of staff shift patterns for 21 days and assisting NHS Test and Trace with requests for that data if needed (see NHS Test and Trace: Workplace Guidance).
The assessment should take into account visitors to the premises and should identify ways to minimise the number of unnecessary visitors and ensure they are protected when on site. These can include:
encouraging visits via remote connection or remote working for visitors where this is an option
limiting the number of visitors at any one time
determining if schedules for essential services and contractor visits can be revised to reduce interaction and overlap between people, eg carrying out services at night
maintaining a record of all visitors, if this is practical.
Guidance should be made available and explained to ensure visitors understand the actions they need to maintain safety (use the Contractor and Visitor Covid-19 Guidance as a template). These will usually include:
providing clear guidance on social distancing to visitors, eg inbound delivery drivers or safety critical visitors; when possible, this should be done before arrival, eg by phone, on the website, by email, signage or visual aids
establishing host responsibilities relating to Covid-19 including providing any necessary training for people who are to act as hosts for visitors
reviewing entry and exit routes for visitors and contractors to minimise contact with other people
co-ordinating and co-operating with other occupiers for those working in facilities shared with other businesses including with landlords and other tenants.
Inbound and outbound goods
Steps should be taken to maintain social distancing when goods enter and leave the site. Considerations include:
methods to reduce frequency of deliveries, eg by ordering larger quantities less often
where possible and safe, having single workers load or unload vehicles
where possible, using the same pairs of people for loads where more than one is needed
encouraging drivers to stay in their vehicles where this does not compromise their safety and existing safe working practice.
Incident and emergency procedures should be reviewed to ensure they reflect the social distancing principles as far as possible. The security implications of any changes to the emergency procedures should be considered in terms of whether they present new or altered security risks which may need mitigations.
In an emergency, for example, an accident, fire, or break-in, people do not have to stay 2m apart if it would be unsafe.
Those involved in providing assistance to others should pay particular attention to sanitation measures immediately afterwards, particularly washing hands.
Covid-19 outbreak in the workplace
The risk assessment should include an up-to-date plan in case there is a Covid-19 outbreak. The plan should, where possible, include a single point of contact (SPOC) who should lead on contacting local Public Health teams. If there is more than one case of Covid-19 associated with the workplace, the local PHE health protection team should be contacted to report the suspected outbreak. If the local PHE health protection team declares an outbreak, they will ask for records of details of symptomatic staff and ask for assistance with identifying contacts. The plan should therefore ensure that records are kept up to date. PHE will provide information about the outbreak management process, which will help the implementation of control measures, assist with communications to staff, and reinforce prevention messages.