Training and compliance
As a minimum we expect:
training around processes and working environment expectations to be provided for all staff before restarting work
organisations to establish measures, in collaboration with trade union or workforce representatives, to monitor compliance with relevant regulations and processes put in place to enable a safe return to operation
Every workplace should look and feel substantially different for employees, staff and students. Physical distancing and enhanced hygiene will change how workplaces operate. Training will therefore be essential to build a common understanding of requirements within the new working norm, instilling confidence that changes put in place contribute to a safe workplace.
Training methods should ensure effective delivery of relevant overarching and organisation-specific measures and expectations of staff while on-site, in a way which maintains physical distancing. Organisations should consider, as part of their risk based planning, how training can be safely delivered, especially if elements are normally outsourced to third parties. Visual aids may be required as part of the training and for ongoing guidance and communications. Some organisations have initiated a universal induction process covering their new, enhanced hygiene and physical distancing measures. This induction process can help demonstrate organisations are taking the COVID-19 risks seriously, building confidence amongst the workforce that they are returning to a safe workplace while also reinforcing the importance of individual employee responsibilities.
Employers should also put in place, with trade union or workforce representatives, robust local arrangements to monitor compliance with new operational arrangements. Remedial actions should flow from that monitoring, and be augmented by advice, guidance and support from external enforcement authorities.
It is vital during restart for workers, staff and students to have confidence in the steps being taken by their employers. Employers should look to establish processes to allow employee feedback on physical distancing and safety protocols, enabling employees to input on areas of concern and for employers to act upon these concerns.
A single point of contact has also been established for trade unions or workforces to help the Scottish Government understand how all COVID-19 workplace guidance is being implemented, and to help shape and refine that guidance based on the real experience of workers in the workplace. The mailbox can be contacted at: firstname.lastname@example.org.
This contact is not intended to be a reporting mechanism for potential breaches of legislation.
Under the Health and Safety at Work, etc. Act 1974 (HSWA), the Health and Safey Executive is the relevant enforcing authority for worker safety. The HSE can be contacted by phone on 0300 003 1647 or online at HSE contact form.
Local authorities also have powers under public health legislation, for example, covering whether businesses should be operating, the requirement to take all reasonable measures to maintain 2 metre distancing, or to ensure your workers, staff and students in the shielded category can follow the NHS advice to self-isolate for the period specified.
The HSE and Environmental Health Services have agreed to maintain the way they allocate different businesses for enforcement according to existing health and safety law for the purposes of workers’ health and safety.
Where the enforcing authority identifies employers who are not taking action to comply with public health guidance to control COVID-19 health risks to workers, they will consider a range of actions to improve control of workplace risks including the provision of specific advice to employers through to issuing enforcement notices or even prosecution.
The interpretation and use of any guidance should be considered in line with normal protective security operations and practices. Organisations should consult with and involve their security departments in the interpretation and implementation of the guidance. In particular, security should be considered in any revised risk assessment.
Under no circumstances do we advise the removal, or alteration of, or reduction in, existing protective security measures without providing clear recommendations (e.g. from the National Technical Authority or police counter-terrorism specialists) on how to maintain effective protective security.
This should extend to measures not primarily intended to provide a protective security benefit, but nonetheless doing so, for example removal of street furniture that could make moving or queueing pedestrians more vulnerable to vehicle-as-a-weapon attacks. Security staff should remain focused on security duties. Where COVID-19 creates additional staffing requirements, e.g. for queue management, employers should ensure additional suitable staff resource is made available. Employers should ensure security staff feel safe, e.g. having access to appropriate PPE and hand-washing facilities, and that they are able and confident to raise any concerns.
Read further detailed guidance on security: