- joint working
- implementation phases
- regular risk assessment
- utilising expertise
- outbreak management
- Legionella testing
- individual risk assessment for the workplace
This guidance has been developed in collaboration with industry and trade unions on the basis that both have essential roles to play in planning for restart. Protecting the health of workers at the heart of this joint approach which is fundamental to establishing shared confidence around the safety of returning to places of work and for visitors to feel assured it is safe for them to return. As mentioned above, engagement with your local authority is also recommended as important in enabling your activity to restart.
We understand that the workforce in the creative industries may not have a significant level of trade union membership in all areas. Where this is the case, organisations should engage with the workforce representatives in the way that they would engage with trade union representatives. There is Health and Safety Executive (HSE) guidance available on worker involvement.
Carrying out a robust risk assessment with studio users, building representatives where appropriate (including facilities managers in shared buildings), staff and trade unions will identify the practical measures that can be put in place to minimise the spread of the virus in studio environments. It is also important to make sure that risk assessment of the studio operator (if different) is shared and understood, so their expectations can be met. The assessment should include a phased implementation timetable, structured broadly as follows:
Plans to re-open a workplace and public areas 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 a restart that allows the organisation to trade while protecting employee health and well-being, and allows the organisation to fulfil its public purpose, should it have one.
Physical distancing, hygiene measures and risk assessment require work to be carried out before a restart and should also take into account anticipated access requirements of disabled visitors – for example screens, one-way systems, 2-metre zones, canteen re-arrangement, PPE provision if appropriate, hand sanitisers etc. Where changes to processes are required, then briefings and inductions into the new ways of working. These all take time and require resourcing and commitment.
Where premises have been empty due to lockdown and/or furlough, thorough safety checks should be conducted on gas and electrical installations, water cooler and ventilation checks, particularly regarding Legionella risks, and pest control checks should be conducted to avoid infestation problems.
These all take time and require resourcing and commitment. These are fundamental steps and their importance must not be under-estimated.
Experience confirms the value of trialling the new way of working before a fuller restart is attempted, so a limited-scale pilot to test systems, find weaknesses and make improvements before a fuller restart is recommended where practical. Pilots could include messaging to the public advising them that returning to a pre-COVID visitor experience will take time, or limited re-openings with very reduced numbers of visitors. We would encourage organisations to discuss good practice with others in the sector so that learning can be shared and processes improved.
A risk assessment or adoption of mitigation measures should not be a one off exercise. Rather it should be part of a regular and ongoing dialogue and feedback loop.Reviews of measures and risks should be frequent. The open and ongoing engagement between organisations and their workforce should enable adjustments to be made quickly and smoothly at the relevant stage. This may include potentially tightening restrictions in workplaces or public areas, or reducing numbers onsite if the dynamic risk assessments indicate this is necessary.
HSE has an example COVID-19 risk assessment which provides a general framework for all business sectors. HPS have provided additional guidance for general (non-healthcare) settings.
Studio providers should ensure their health and safety professionals and representatives have the skills, training and knowledge to understand the risks associated with COVID-19. Responsible parties should review specific guidance such as on the Scottish Government website and NHS inform. Where they 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.
For workplaces without union representation, union health and safety representatives will be available upon request to support the development of workplace risk assessments. Further information is provided in the Coronavirus (COVID-19): safer work places joint statement. For more information please contact email@example.com.
Studio providers should suspect an outbreak if there is either:
- two or more linked cases (confirmed or suspected) of COVID-19 in a setting within 14 days - where cross transmission has been identified
- an increase in staff absence rates, in a setting, due to suspected or confirmed cases of COVID-19
If a studio provider suspects a COVID-19 outbreak, they should immediately inform their local NHS board Health Protection Team (HPT). The organisation may be then contacted by them, as they may get information from NHS Test and Protect or other sources.
In the event of an outbreak:
- continue to follow the existing protection and control measures contained within this guidance
- the local Health Protection Team will undertake a risk assessment and conduct a rapid investigation. They will advise on the most appropriate action to take.
- staff who have had close contact with case(s) will be asked to self-isolate at home. In some cases, a larger number of other staff may be asked to self-isolate at home as a precautionary measure. Where settings are observing guidance on infection prevention and control, which will reduce risk of transmission, the local Health Protection Team will take this into account in determining whether closure of the whole setting will be necessary.
- depending on the risk assessment outcome, the Health Protection Team may establish an Incident Management Team (IMT) to help manage the situation
- the Incident Management Team will lead the Public Health response and investigations, and work with the organisation to put appropriate interventions in place
To control an outbreak the Health Protection Team and Incident Management Team will work with the organisation to put appropriate interventions in place. These will generally include ensuring that the preventive measures described in this document to prevent spread of COVID-19 are fully implemented. Other measures may include:
- cleaning in the setting: for cleaning and waste management, refer to guidance on cleaning in non-healthcare settings for maintaining hygiene
- consider wider testing of affected population and staff
- information: ensure that staff (and other relevant people) are aware of what has happened and the actions being taken
- closure: may be done following advice from the Health Protection Team and Incident Management Team or the business may make their own decision on closure ahead of this advice as a precaution or for business continuity reasons
The Health Protection Team or Incident Management Team will declare when the outbreak is over.
There is an increased risk of Legionnaire’s Disease when buildings have been out of use, or not running at full capacity. This is because water systems may become stagnant when not in use, increasing the risk of legionella within water supplies. Many public and office buildings have been closed during the COVID-19 crisis, making legionella a legitimate concern as lockdown restrictions are eased.
The HSE have published advice on the risk of Legionella in buildings which are closed or running with reduced occupancy during the COVID-19 crisis on the Royal Environmental Health Institute of Scotland (REHIS) website.
Building owners or operators should undertake a health and safety check of buildings, and deep cleaning prior to reopening where necessary, to mitigate risks. More information can be found on the HSE website.
If there are any concerns voiced about the controls put in place from the workplace assessment or if members of staff / manager have any concerns about individual vulnerability, then a risk assessment can be undertaken.
The guidance and accompanying tool allows anyone who wants to, to assess their risk of contracting coronavirus, using a comprehensive statistical tool developed using evidence from the epidemic so far. It is based on clinical and scientific evidence that takes into account personal characteristics including age, ethnicity, gender, BMI and health conditions, to assess as individual’s overall vulnerability to COVID-19.
This advice will help the employer and individual understand the workplace and individual risks, with the aim of reaching an agreement about how the employee may return to work if there are adequate controls in place to protect the employee.
Pregnancy is not included within the tool. We advise following the UK Government Coronavirus (COVID-19): advice for pregnant employees which is applicable in Scotland. Pregnant women of any gestation should not be required to continue working if it not supported by the risk assessment.
The Scottish Government’s safer workplaces joint statement with Police Scotland, Health and Safety Executive and local authorities makes clear that it is essential that organisations carry out a workplace COVID-19 risk assessment. The Health and Safety Executive’s short guide also provides advice of things employers can do to make workplaces safe.
If agreement cannot be reached then staff can seek further advice from their GP, Occupational Health Services, Health and Safety Professionals, Trade Unions, Infection Prevention Services, or the Advisory, Conciliation and Arbitration Service (ACAS).
For workplaces without union representation, union health and safety representatives are available upon request to support the development of workplace risk assessments.