Involving the workforce in a risk based approach
As a minimum we expect:
- a risk based approach to be followed to protect health and safety of employees and ensure the longer-term economic viability of the business and
- employees to be fully engaged in that process, through trade union or workforce representatives
This guidance has been developed in collaboration with industry and trade unions on the basis that both have essential roles to play in planning safe operations for restart. Companies that have successfully been able to maintain or increase production of essential goods during the COVID-19 crisis have highlighted the importance of joint working. Protecting the health of employees has been at the heart of this joint approach, which is fundamental to establishing shared confidence around the safety of returning to places of work and supporting a recovery in productivity. Use of the accompanying operational checklist should aid this process, though the specific circumstances of individual businesses needs to be considered.
Manufacturing businesses and employees are familiar with a risk based approach to managing work and onsite activity. Carrying out a robust risk assessment with full workforce involvement (of recognised trade union safety representatives or relevant employee safety representatives) will identify the practical measures that can be put in place to minimise the spread of the virus at a workplace level. The assessment should include a phased implementation timetable, structured broadly as follows:
Plans to operate a workplace should be developed in consultation with the workforce and updated on an ongoing basis. That planning must be based around risk assessments and safe systems of work - physical distancing, hand washing, and fair work principles and be designed to enable safe operation that allows the business to trade while protecting employee health and well-being.
Physical distancing and hygiene measures require work to be carried out before a restart – for example screens, one-way systems, 2- metre zones, canteen re-arrangement, PPE provision, hand sanitisers etc. Then briefings and inductions into the new ways of working. These all take time and require resourcing and commitment.
Experience confirms the value of trialling the new way of working before a fuller restart or scale-up of activity is attempted, so a limited-scale pilot to test systems, find weaknesses and make improvements is essential.
A risk assessment or adoption of mitigation measures should not be a one off exercise, rather part of a regular and ongoing dialogue and feedback loop between employers and trade union or workforce representatives to identify what measures are working, where refinements are possible and any gaps remaining. Reviews of measures and risks should be frequent, with daily assessments of progress initially not unusual. The open and ongoing engagement between trade union or workforce representatives should enable adjustments to be made quickly and smoothly at the relevant stage, including potentially tightening workplace restrictions or reducing numbers onsite if the dynamic risk assessments indicate this is necessary.
Implementing physical distancing measures across all areas of the business
COVID-19 is a new risk that must be incorporated into workplace risk assessments, and employers must therefore carry out a COVID-19 risk assessment if they have not already done so. It is critical that risk assessments cover all parts of the business where there may be a risk of COVID-19 transmission between staff and/or customers.
It is therefore important for all staff to understand that these risks do not apply only to production areas. Careful consideration must also be given to other parts of the workplace where there is scope for people to congregate in groups and physical distancing and hygiene measures will be needed to prevent the virus from spreading.
Employers will need to assess the high risk areas that apply to their own circumstances, taking account of arrangements for transporting staff to the workplace, and communal spaces on site such as toilet facilities, staff and changing rooms, canteens, smoking areas and hygiene stations. These are all areas where there are opportunities for staff to congregate and it is therefore essential for employers to ensure these are considered in the development of plans for controlling the spread of COVID-19.
Companies should ensure their health and safety professionals and representatives have the skills, training and knowledge to understand the risks associated with COVID-19. Where companies and their workforce do not have access to these skills in-house they should together explore external support options to put in place appropriate mitigation measures, for example through their trade association, health and safety consultancies or trade union health and safety representatives. All can help companies understand the risks associated with different activities and situations within individual companies and offer the support managers and workers may require.
Understanding the risks, building confidence, supporting wellbeing
Returning workers may have some level of apprehension about how safe they may be and they may require reassurance and demonstration that measures recommended in workplace risk assessments have been put in place to ensure safety. Employers should ensure that communication with staff on COVID-19 risks and measures for preventing transmission are refreshed to take account of any updates to guidance and ensure levels of knowledge and understanding are maintained and that messages are not becoming stale. Updates should be provided at team meetings (weekly is suggested), and reinforced through all available channels for staff communications (e.g. TV screens/digital signage, intranet and newsletters).
Language is a critical factor when communicating with employees the importance of COVID-19 controls. It is important to ensure language is not a barrier. Simple, clear messaging should be used to explain guidelines using images and clear language, with consideration of groups for which English may not be their first language and those with protected characteristics such as visual impairments. Posters, leaflets and other materials are available online which can be used to reinforce these messages throughout the workplace. NHS Inform also provides general advice on COVID-19 in a range of translated formats which will help to support employees for whom English is not their first language.
A clear message from employers and trade unions is that building and maintaining employee confidence is vitally important and a challenge that should not be underestimated.
Advanced Manufacturing Policy Team