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Post-lockdown return to work: what you need to think about to protect staff and customers

Keep your distance: CV19 changes working practices
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Keep your distance: CV19 changes working practices
Wayne Jeal by Wayne Jeal
Director - Wiser Safety Management

With the phased easing of lockdown underway, it’s time for business owners to start to address how they are going to get their staff back to their normal place of work.  Social distancing will remain the norm, and it’s vital that as a business owner you take robust steps to protect your staff, customers and suppliers from Covid-19. Wayne Jeal, of Wiser Safety Management , guides you through the key steps you need to consider to ensure you are fulfilling your legal and moral requirements.

It’s a difficult choice: stay at home forever and have economic Armageddon, or reopen the economy, knowing that we will continue to live with Covid-19 until there is an effective vaccine and therefore any increased social interaction carries a risk of infection rates starting to rise again. The health risks of the former strategy have been said by some to outweigh the risks from the coronavirus itself, so it’s understandable that politicians and the public are moving towards eased restrictions.

However, knowing that we are living with Covid-19 puts a new onus on business owners, which is going to require something of a balancing act. None of us can mitigate completely against the disease, but we have to be confident – and our staff, customers and suppliers need to feel confident – that we have done everything that is ‘Reasonably Practicable’ to make our work places as safe as possible for their return.

‘Reasonably Practicable’  means weighing a risk against the trouble, time and money needed to control it. For example, the cost of installing isolated oxygen tents for staff to work in might be considered as a grossly disproportionate to the benefits of risk reduction that would be achieved and would likely make business operation impossible.

Coronavirus puts new responsibilities on business owners

Any good employer will morally want to be confident that they have done everything so far as is reasonably practicable to be legally compliant and be able to demonstrate that they have:  

  • carried out a risk assessment for the control of Covid-19
  • demonstrated their competence to carry out a risk assessment (if you cannot, expert help may be advisable)
  • provided appropriate training for staff
  • certification to prove all of the above, signed as appropriate by relevant parties. For example, it won’t be enough to say you have provided training in your new working practices; your staff will need to sign to say they have received this training. Similarly, if you introduce daily checks, staff will have to sign a register each day to record their input.

Exactly what modifications you will have to make to your normal working practices will vary from business to business and location to location, but there are some common issues that you need to think about and identify. Working through these will provide a basis for implementing effective Covid-19 health and safety policy and procedures to protect everyone associated with your business.

For all businesses, staff will have to be re-inducted on their return to work to make sure they understand and adhere to your new policies.

Continued home working

The reopening of the economy is going to be a staggered affair, and there will be strong health and social reasons for some staff to continue to work from home, or to continue to work from home some of the time:

  • You may have staff who are vulnerable or who need to shield someone in their household who is vulnerable
  • You may want to stagger the hours/days staff are in the office to enable social distancing
  • Staff may want to maintain a more blended work week, working from home more often to maintain some of balance they’ve gained during lockdown
  • Staff may need to self-isolate for 14 days if they come into contact with someone who is diagnosed with Covid-19

If staff are working from home, you have legal duties to ensure they are working safely. This includes making sure they have a comfortable work environment, including appropriate office furniture, equipment, lighting, heating, broadband and phone system.   

In our rush to comply with lockdown, we largely adopted a make-do-and-mend approach to setting up our home offices , but as this becomes an established – and even routine – way of working, as business owners we are required to make sure that our existing policies and procedures are updated to cover staff working from home. You will need to implement the following, if you don’t already have them in place:

Step 1 of returning to work: Know your staff

Before you can begin to make sure you have the right safety measures in place to protect your staff as they return to your office, studio, workshop or shop, you need to have a clear picture as to their health so you know how vulnerable they are to coronavirus; a 60 year old who has undergone treatment for cancer is in a different position to a 25 year old with no underlying health conditions. So, your starting point is to consider the introduction of a health questionnaire to identify whether any of your staff have a health condition that puts them at increased risk if they contract Covid-19.

The government has stated the conditions that make people clinically vulnerable from coronavirus, which is a sensible starting point for a health questionnaire, which we recommend that all staff should be asked to complete and sign on a daily basis (as some conditions can change), in conjunction with the working safely during Covid-19 guidance and advice from Public Health England . Included in this list of clinically vulnerable conditions are being pregnant and having a BMI of  40 or more. 

Given the legal obligation to take reasonable steps to protect employees’ health, even though obesity and pregancy are potentially sensitive subjects, the government guidance suggests that it is reasonable for an employer to ask staff to confirm in writing whether they fall into either of these categories.  Having a standard health questionnaire for all staff will reduce potential discrimination and embarrassment, however this is new for all of us and experts in all fields are reviewing the emerging guidance and trying to interpret it sensibly, and it has to be pointed out that there are data protection and privacy issues to be considered here as well.

But if an employee signs that they are not pregnant and don’t have a BMI of over 40 when they do, you arguably cannot be expected to take steps to shield them and they arguably have chosen to accept responsibility for withholding that information from you. If they prefer not to answer these questions, it would be sensible to take HR advice to understand how you should best proceed.

If any of your staff is in a vulnerable category, or if someone in their household has a condition that makes them vulnerable, it is reasonable to ask them not to return to the workplace. In such circumstances, ideally you can make provision for them to continue to work from home; if this is not possible, you may need to seek HR advice as to your options.

Step 2 of returning to work: Help your staff travel to work safely

Before your staff arrive at work, they have to get to your office, shop, studio or workshop. Part of your Covid-19 health and safety policy should involve discussions and training with them about best-practise and precautions to minimise their risks on their way to and from work.

If possible, staff should be encouraged to avoid public transport; walking, cycling and private car are all deemed to be safer options. But if staff routinely carpool with someone other than a member of their household, they should avoid this for the foreseeable future.

If workers have no option but to share car journeys to and from work, they should introduce the following controls:

  • Only share the journey with the same individuals and do not allow new car passengers
  • Restrict vehicle occupants at any one time
  • Sanitise hands before entering and upon exiting the vehicle
  • Ensure that there is good ventilation by driving with windows open
  • Face away from one another
  • Consider wearing a face mask or face covering
  • Introduce a regular cleaning regime, ensuring that touch points in the vehicle are cleaned/sanitised, i.e. door handles inside and out and other surfaces that passengers may have touched.

If you have company pool vehicles, you will need to address how these are cleaned between journeys to reduce the risk of infection among co-workers. Further guidance in connection with driving at work can be found here .

If your staff have to use public transport, you will need to advise them on the steps they should take to minimise the risk of infection. Workers will need to know that they are required by law to wear a face mask or face covering when using public transport.

They will need to observe social distancing guidelines and you should also discuss with them whether it is possible for them to work different hours, so they travel at less busy times. On their way to and from work, they should also take steps can they take to minimise contact points, for example:

  • Can they download a parking app, instead of putting coins into the pay-and-display machine?
  • Can they prepay for tickets/use contactless payment methods?
  • Can they choose a route with fewer contact points?

Step 3 of returning to work: Keeping Covid-19 out of your workplace 

This is going to be impossible to achieve 100% – otherwise we would have reduced the famous R rate to zero already – but there are steps you can take to minimise the risk. It is reasonable to ask staff to sign a daily register to confirm they are not displaying any of the recognised symptoms and they have not been in contact with anyone with Covid-19, and it is also reasonable to ask staff to take their temperature every day as they arrive – and to be expected to go home again if their temperature is raised.

It’s important not to make a hasty decision if a worker’s temperature is raised; try to understand the reason for a raised temperature to make an informed decision about the best course of action. This can be achieved by asking questions such as:

  • Are you feeling unwell?
  • Are you hot to touch on your chest or back?
  • Have you recently undertaken any exercise, activity or work that may cause your temperature to be high?
  • Do you have any known medical condition that may cause your temperature to be high?
  • Do you have a new, continuous cough? This means coughing a lot for more than an hour, or three or more coughing episodes in 24 hours (if you usually have a cough, it may be worse than usual).
  • Are you experiencing a loss or change to your sense of smell or taste? This means you've noticed you cannot smell or taste anything, or things smell or taste different to normal.

Step 4 of returning to work: Managing social distancing within your workplace

Operating a workplace successfully to minimise the risk of spreading coronavirus is going to require a rethink of many of the things that we routinely take for granted. The most obvious is the requirement to maintain safe social distancing and to eliminate any skin-to-skin contact. You may be able to move desks, install screens between desks,  or stagger the hours your staff work; you may need to think about introducing control measures (such as marks on the floor) to indicate where they, or customers, should stand.

But you also need to think beyond the obvious workstations and consider all the places where people routinely pass one another on the premises. For example, if you have narrow stairs with a blind spot, can you install a mirror so people can check ahead before going up or down? If the toilet has a narrow wash area, can you put up an ‘occupied’ sign so only one person goes in at once?

Step 5 of returning to work: Reducing points of contact

You will also need to look to reduce as many points of contact as possible within the workplace and making unavoidable points of contact as

safe as possible. Steps to consider include:

  • Providing PPE (Personal Protective Equipment) where appropriate
  • Sanitising work equipment and appliances
  • Limiting the number of people using the kitchen or canteen at any one time
  • Removal of tables and seating within canteen/rest areas
  • Rather than use a communal kitchen, staff may consider bringing their own thermos of tea of coffee and packed lunches that they eat at their desks or outside
  • Using disposal cups
  • Rethinking processes to reduce work/papers being passed among colleagues
  • Foot-operated door pulls

Alongside this, you will, of course, have to install sanitising equipment.

Step 6 of returning to work: Establishing responsibility and maintaining your paper trail

This is important, so although we covered this at the start, it’s worth repeating again: as a business owner, it’s not simply enough to get everything right, you need to have an effective audit trail to prove this. You will need to introduce documentation such as Covid-19 Policy and Procedures, Risk Assessment and a Self-Assessment to help you to identify employees that are either vulnerable themselves or living with persons that are vulnerable. It is sensible to appoint a Covid Responsible Person and a Deputy, so you always have someone on duty to make sure your policies are being adhered to and to act if something unforeseen arises. You will need to communicate your Covid-prevention measures to your staff effectively with a return to work induction and/or briefing. This should be documented with a signature from employees to acknowledge the induction or briefing. Other supplementary documents could include a daily register of any health conditions and temperature checks.

Step 7 of returning to work: What you need to do in the event of coronavirus

Covid-19 is a reportable disease under the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 (RIDDOR ). The reporting requirements relating to cases of, or deaths from, COVID-19 under RIDDOR apply only to occupational exposure, that is, as a result of a person’s work.

What to report

You should only make a report under RIDDOR when one of the following circumstances applies:

  • An accident or incident at work has, or could have, led to the release or escape of coronavirus (SARS-CoV-2). This must be reported as a dangerous occurrence .
  • A person at work (a worker) has been diagnosed as having COVID-19 attributed to an occupational exposure to coronavirus. This must be reported as a case of disease
  • A worker dies as a result of occupational exposure to coronavirus. This must be reported as a work-related death due to exposure to a biological agent

If an employee is diagnosed with Covid-19, you will have to assess what exposure other members of the team had to them and whether they are now required to self-isolate for 14 days; this should be something you have anticipated and planned for in your COVID-19 Policy and Procedures.

Getting staff back to work safely is going to be a steep learning curve for many business owners. If you have serviced offices, your office provider should have considered how to minimise the risk of coronavirus in communal areas and will be able to advise you on best practise within your own work unit. At Capital Space, we are working closely with all our customers to enable their safe return to work – please contact your business centre manager to discuss local policies and how they will apply to you and your team.


Wayne Jeal runs Wiser Safety Management , a health, safety, training and compliance consultancy, set up to provide

clients with sensible and pragmatic support, guidance and assistance in all aspects of health, safety, training and compliance.


To find out how  Capital Space  virtual offices or business premises

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