Training and compliance
As a minimum we expect:
- training around processes and working environment expectations to be provided for all staff and students/apprentices before starting work on-site
- organisations to establish measures, in collaboration with trade union or workforce representatives, to monitor compliance with relevant regulations, local restrictions and processes put in place to enable a safe operation
Every workplace should look and feel substantially different for employees, staff and students/apprentices. 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.
Training should also be in place for staff who undertake the cleaning of a premises.
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.
Apprentices can work on-site at the same time as their co-workers. For specific concerns regarding safe work for apprentices there is information and support and apprentices can speak to an advisor directly on 0800 917 8000.
It is important to ensure there is a functioning training infrastructure to support economic recovery and the sustainability of apprenticeship programmes. For those Training Providers and assessors that are providing continuity of contracted services for apprentices, learners and employers in the workplace during the pandemic must adhere to the applicable sectoral guidance and local restrictions.
The following guides from the Health and Safety Executive provide useful sources of information:
- working safely during the coronavirus outbreak - a short guide
- talking with your workers about working safely during the coronavirus outbreak
At all protection levels, working from home is the default position where possible.
Organisations may want to refer to the home working guidance.
As a minimum we expect:
- 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 safe working.
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 for workers 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 union or workforce representatives 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 through email@example.com.
This contact is not intended to be a reporting mechanism for potential breaches of legislation. To ensure appropriate enforcement action is taken when needed, any potential breaches of legal requirements must be raised with the Health and Safety Executive (HSE).
The regulator for health and safety at work, the Health and Safety Executive (HSE) is 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. HSE can and will use the Health and Safety Work Act to ensure physical distancing in the workplace in relation to workers. HSE can be contacted by phone on 0300 003 1647 or online at HSE contact form
Where HSE identifies employers who are not taking action to comply with the relevant public health guidance to control COVID-19 health risks to workers, HSE 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. A framework agreement between Police Scotland and local authorities supports the referral of complaints about lack of reasonable physical distancing at work.
Organisations may also want to use the compliance self-assessment tool to assess the effectiveness of COVID-19 control measures within the workplace.
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: