Training and compliance
As a minimum we expect:
- training around processes and working environment expectations to be provided for all workforce before restarting work
- companies 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
Every workplace should look and feel substantially different for employees. 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 company specific measures and expectations of workforce while onsite, in a way which maintains physical distancing. Companies 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 companies have initiated a universal induction process covering their new, enhanced hygiene and physical distancing measures. This induction process can help demonstrate companies 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. Where PPE is used specific training on its use should be carried out.
Employers should also put in place, with trade union or workforce representatives, robust local arrangements to monitor compliance with new operational arrangements. These should be fed into the wider event debrief to seek continuous improvement. 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 to have confidence in the steps being taken by their employers. Employers should look to establish processes to allow employee feedback on social distancing and safety protocols, enabling employees to input on areas of concern and for employers to act upon these concerns. A resolution process should be implemented so reporting lines are clear.
The co-regulators for health and safety at work, the Health and Safety Executive and Local Authority Environmental Health services, are constantly applying their expertise to ensure people at work are protected, utilising the powers at their disposal under the Health and Safety at Work Act 1974. HSE is treating COVID-19 as a workplace health issue with regard to the protection of workers from infection. Both regulators can and will use the Health and Safety Work Act to ensure physical distancing in the workplace in relation to workers.
Where both regulators’ identifies employers who are not taking action to comply with the relevant public health guidance to control COVID-19 health risks to workers, both regulators 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. These actions will be taken under existing health and safety law (HSWA). A framework agreement between Police Scotland and local authorities supports the referral of complaints about lack of reasonable physical distancing at work to the relevant local authority. Local authorities will ensure that those complaints relevant to HSE are referred quickly through the normal route.