It is vital that measures are put in place by providers of community based learning activity to manage transmission risk to address aerosol, droplet and surface transmission.
In applying direction on when restrictions can be changed, CLD providers will consider a range of evidence on the progress of the pandemic in Scotland using the principles set out in Coronavirus (COVID-19): framework for decision making, the Strategic Framework and updated Strategic Framework and for protection measures and our commitment to fair work, which was set in the context of the current crisis in a joint statement with the STUC.
In implementing this guidance, CLD providers should consider the following:
- the local context of restriction measures for the local authority (level 0-4)
- the health, safety and wellbeing of learners, staff, volunteers, and the wider community will be the priority in decisions relating to the easing of COVID-19 restrictions across the CLD sector
- CLD providers will review their practice to ensure that there is the required flexibility in place to deliver high quality learning experiences which allows learning activities to take place safely
- CLD service providers will make appropriate changes to building layout and infrastructure in accordance – at minimum – with public health advice, including guidelines on physical distancing
- new arrangements put in place for CLD staff and volunteers should be tested and modified in agreement between employers, trade unions and employees
- CLD service providers will regularly review the welfare and mental health needs of CLD staff, volunteers and learners and take steps to ensure preventative measures are implemented, appropriate support is in place and all information is communicated as restrictions are eased.
- CLD service providers will regularly review their hygiene, waste disposal and cleaning protocols in all spaces, and adapt them in response to changing public health advice and risk levels, to ensure the safety of CLD staff, volunteers and learners.
- following a suitable and sufficient risk assessment, local authorities, third sector organisations, voluntary sector organisations and colleges will introduce measures to enable CLD service delivery to be carried out in a safe manner. Risk assessments are also required to consider the individual needs of CLD staff, volunteers and learners.
- CLD providers will engage with staff, volunteers, learners and trade unions to ensure a safe resumption of CLD services
- an implementation timetable should be developed with trade unions covering planning, preparation and pilots taking into account the challenges of maintaining physical distancing, and enabling hand washing, fair work principles and enabling a restart that allows service delivery while protecting health and wellbeing
- CLD providers will take a rights based approach as well as a risk based approach to protect health and safety of CLD staff, volunteers and learners. Trade unions, staff and volunteers will be fully engaged in this process.
Additionally, in planning for the use of facilities, CLD providers who own or manage community facilities should ensure that the following points have been considered before resuming face to face activities.
- the vulnerability of learners taking part in activities and how transmission of the virus could have wider implications on service provision.
- the availability of CLD staff, volunteers and learners’ that may be affected by public transport availability and restrictions
- availability of PPE, other equipment and/or face coverings appropriate to the activity or location
- the organisation of staggered breaks and other flexible working patterns to support physical distancing in accordance with government guidelines
- protocols to minimise the use of shared equipment, hot desks and other facilities to ensure safe usage
- supporting services required in increasing the number of individuals on-site and how they can be provided as safely as possible
- what measures, in addition to those that were in place during the lockdown phase and earlier phases will need to be in place to accommodate additional numbers (including additional cleaning measures and queue management systems where appropriate)
In aligning with these principles, this guidance does not supersede existing health and safety legislation and employers and service providers will continue to abide by these obligations, including the legal duty on employers to conduct risk assessments and engage with health and safety committees. Through all phases of emerging from lockdown, CLD services should have regard to general health and safety guidance and to the requirements for reporting cases.
Existing requirements under the Equality Act 2010 continue to apply and services must ensure that CLD staff, volunteers and service users with protected characteristics are treated fairly and not further disadvantaged as a result of COVID-19. The duty to make reasonable adjustments for disabled workers will continue to apply; CLD employers and service providers should consider whether any additional reasonable adjustments may be needed in the current circumstances.
In developing local protection measures, where guidance is provided by different agencies or policy interests overlap, employers and service providers should follow guidance that has been produced which offers the highest level of protection for employees and service users.