Health and safety measures
Changing the workplace or venue environment to protect your workforce and the public
As a minimum we expect enhanced health and safety measures to be in place before staff are asked to return to work. These include:
- physical distancing as required
- good ventilation (also see HSE ventilation guidance)
- effective hand and respiratory hygiene
- advice on wearing face coverings
- appropriate risk assessment
- supporting staff to self-isolate
- supporting working from home and flexible working where possible
- safe workplace planning and communications
- enhanced hygiene
- cleaning auditoria
- handling goods, merchandise and other materials, and onsite vehicles
- Legionella testing
- physical distancing
- moving around buildings and workplaces
- workplaces and workstations
- common areas
- travel to work and work-related travel
- coming to work and leaving work
- Personal protective equipment (PPE)
- face coverings
- temperature checks
- COVID-19 symptoms in the workplace
- shift patterns
- dealing with emergencies
Regular and ongoing engagement between organisations and trade union or workforce representatives is vital to ensure a safe working environment and related workforce confidence. This engagement must start well before a planned restart, or ramping up of activity, to allow completion of the necessary risk assessment and then identification and implementation of the relevant mitigation measures.
It is important everyone understands the measures taken to establish the safe working environment, to improve workforce confidence and support a recovery in productivity levels.
Enhanced hygiene measures are key workplace-specific measures to create a safe working environment. These include, for example:
- sanitiser and hand-washing facilities at touch points, including on entry and exit points
- sanitiser and handwash facilities also in communal areas
- regular cleaning and sanitising of break out areas, including chairs and tables and other welfare facilities and touchpoints e.g. fridges, kettles, vending machines etc. The frequency of cleaning and disinfection should be based on risk assessment depending on the usage of the area
- composition of chairs in staff breakout areas should be reviewed to ensure they can be effectively cleaned
- providing regular reminders and signage to uphold hygiene standards
- setting clear use and cleaning guidance for toilets to ensure they are kept clean and physical distancing is achieved where possible
- public toilets, portable toilets and toilets inside premises should be kept open and carefully managed to reduce the risk of transmission of COVID-19 providing either paper towels or electrical driers for drying hands
Cleaning and disinfecting the workplace before reopening
To ensure workplaces which were closed or partially operated are clean and ready to restart, including:
- an assessment for all venues and premises, or parts of venues and premises, that have been closed before reopening or resuming activity
- cleaning procedures and providing hand sanitiser, before reopening or resuming activity, in line with any requirements for reopening after prolonged closure
- checking whether you need to service or adjust ventilation systems. Advice can be sought from your heating ventilation and air conditioning (HVAC) engineers or advisers
- opening windows and doors frequently to encourage ventilation, where possible. This does not apply to fire doors
- establishing new cleaning regimes for the venue or premises and determining how they will be delivered effectively
Keeping the workplace clean and disinfecting
To keep the workplace clean and prevent transmission:
- frequent, for example at least twice a day, cleaning and sanitising (with appropriate products) work areas and equipment between uses. Ensure regular detergent cleaning schedules and procedures are in place using a product which is active against bacteria and viruses
- frequent cleaning of objects and surfaces that are touched regularly (touchpoints) and making sure there are adequate disposal arrangements
- clearing workspaces and removing waste and belongings from the work area at the end of a shift, class, rehearsal or performance, or between use of desk/area
- wedging doors open, where appropriate, to reduce touchpoints. This does not apply to fire doors.
- maintaining good ventilation e.g. through fresh air or mechanical systems
- if you are cleaning and disinfecting after a known or suspected case of COVID-19 then refer to the guidance on cleaning in non-healthcare settings, this includes guidance on when PPE might be appropriate and how to dispose of waste
To minimise the risk of transmission in auditoria.
Steps that will usually be needed:
- cleaning auditoria frequently, typically between each performance, with particular attention paid to surfaces that hands of audience and staff are likely to come into contact with such as doors, seat arms and handrails
- scheduling performances to allow sufficient time to undertake necessary cleaning before the next audience arrives
To minimise the risk of transmission in changing rooms and showers:
- set clear use and cleaning guidance for showers, lockers and changing rooms to ensure they are kept clean and clear of personal items and that physical distancing is achieved as much as possible
- restrict number of people within the changing areas at any time
- enhance cleaning and sanitising of facilities regularly throughout the day
To reduce transmission from objects and vehicles at the workplace:
- implement cleaning and sanitising procedures for goods and merchandise entering the site
- implement cleaning and sanitising procedures for vehicles
- regularly cleaning and sanitising reusable delivery boxes
- introduce handwashing facilities/sanitiser for workers handling goods and merchandise
- restrict non-business deliveries
- ensure physical distancing and hygiene measures are followed when supplies, etc are delivered
- collect items in bulk to reduce the frequency of collections
- remove waste in bulk if possible
- implement enhanced handling procedures of laundry to prevent contamination of surrounding surfaces (do not shake linen on removal, do not place used linen on the floor or any other surfaces)
Water systems may become stagnant when not in use, increasing the risk of legionella within water supplies. To mitigate this risk ahead of re-opening public buildings or offices that may have been closed for an extended period during lockdown:
- consult Health and Safety Executive advice on the risk of Legionella in buildings which are closed or running with reduced occupancy during the COVID-19 crisis.
- undertake a health and safety check of buildings, and deep cleaning prior to reopening where necessary, to mitigate risks.
- review risk assessments and manage legionella risks when re-instating or beginning to use a water system again, or when restarting certain types of air conditioners – More information and guidance on this can be found on the HSE website.
Physical distancing remains one of the most effective methods to protect ourselves and others from getting COVID-19. However, it is only one tool in our toolkit to suppress COVID-19. Good hand and respiratory hygiene, the use of face coverings and enhanced ventilation in indoor spaces are also key for reducing the risk of infection. All of these things, together, form an extremely effective package of interventions in supressing COVID-19.
Physical distancing rules are set out in legislation at The Health Protection (Coronavirus) (Restrictions and Requirements) (Local Levels) (Scotland) Regulations 2020. These regulations legally require people responsible for businesses to ensure, as far as reasonably practicable, that:
- the required distance is applied to all parts of a workplace, including staff canteens, entrances and exits, break rooms, smoking areas, and similar settings
- the required distance is maintained between any persons either on or waiting to enter the premises
- they only admit people to the premises in sufficiently small numbers to make it possible to maintain that distance
Failure to comply with this requirement is an offence, and may result in a Fixed Penalty Notice being issued.
Health Protection Scotland (HPS) published guidance for general (non-healthcare) settings. In carrying out their regular risk assessments, workplaces should consult it and consider the list of measures suggested there, which are designed to ensure that physical distancing is maintained.
Some of the measures that businesses should be taking into account are as follows:
- rearranging the layout of the premises to promote physical distancing as required
- introducing signage with clear marking of physical distancing boundaries around the workplace and workstations and signage that reinforces expectations of workers at relevant points
- limiting access to parts of the workplace required by an individual to do their job as this will limit chances for interaction with others
- staggering break times and adjusting canteen arrangements to reduce larger numbers of staff and to ensure physical distancing as required between those interacting on a face to face basis
- splitting the workforce into teams to avoid cross-team contamination and provide a level of operational resilience in case someone in one team develops COVID-19 symptoms
Physical distancing should be maintained where possible whilst moving around buildings and workplaces. The following measures should be considered:
- discouraging non-essential trips within buildings and sites
- reducing job rotation, equipment rotation and location rotation
- implementing one-way systems on walkways
- reducing maximum occupancy for lifts, providing hand sanitiser for the operation of lifts and encouraging use of stairs
- making sure that people who are disabled are able to access lifts whilst maintaining physical distancing measures
- regulating use of high traffic areas including corridors, lifts, turnstiles and walkways to maintain physical distancing
- advice on wearing face coverings
Workstations should be assigned to an individual where possible. If they need to be shared, they should be shared by the smallest possible number of people and workstations should be cleaned between each user.
If it is not possible to physically distance workstations, and those workstations are business critical, then extra attention needs to be paid to equipment, cleaning and hygiene to reduce risk:
- reviewing layouts to allow workers to work further apart
- using floor tape or paint to mark areas to aid physical distancing
- using screens to create a physical barrier between people allowing staff to work safely and communicate with colleagues at adjoining workstations
- using a consistent pairing system if people have to work in close proximity
It is important to maintain physical distancing in common areas by:
- staggering break times to reduce pressure on break/eating areas
- using safe outside areas for breaks
- encouraging workers to bring their own food
- providing packaged meals to avoid opening staff canteens
- using workplace areas that have been freed up by home working
- reconfiguring seating and tables to maintain spacing
- using protective screening for staff in public facing areas
- regulating use of locker rooms, changing areas and other facility areas to reduce concurrent usage
- encouraging storage of personal items and clothing in personal storage spaces, for example lockers, during working hours
- considering use of physical distance marking for areas such as toilets, showers, lockers and changing rooms and in any other areas where queues typically form
- minimizing measures in congested areas in your premises such as narrow corridors, staircases, doorways and storage areas
To reduce or eliminate transmission due to face-to-face meetings:
- use remote working tools to avoid in-person meetings
- only absolutely necessary participants should attend meetings and should maintain physical distancing throughout
- avoid sharing pens or other objects
- provide hand sanitiser in meeting rooms
- hold meetings outdoors or in well ventilated rooms
- use floor signage to help people maintain physical distancing
Further mitigating actions which complement but do not substitute physical distancing include:
- increasing the frequency of hand washing and surface cleaning
- maximising the distance between people as much as possible
- using screens or barriers to separate people from each other while ensuring they do not become touchpoints
- reducing the number of people each person has contact with by using ‘fixed teams or partnering’ (so each person works with only a few others)
- if people must work face-to-face for a sustained period with more than a small group of fixed partners, then you will need to assess whether the activity can safely go ahead. No one is obliged to work in an unsafe work environment
- those who are deemed high risk should not be asked to work in areas where mitigation measures identified in the risk assessment are compromised
Physical distancing applies to all parts of a business, not just the place where people spend most of their time, but also entrances and exits, break rooms, smoking areas, canteens and similar settings. These are often the most challenging areas to maintain physical distancing in and may require clear communication and supervision to ensure mitigation measures are followed.
Following the physical distancing guidance will help to mitigate against the risk of staff being identified as a ‘close contact’ of a colleague who tests positive for coronavirus, and would have to self-isolate at home.
Public Health Scotland has provided COVID-19 information and guidance for general (non-healthcare) settings stating people should not travel if they exhibit any COVID-19 symptoms. The PHS advice and any subsequent safe travelling advice should be factored into company decisions on planned returns to work.
Transport Scotland have produced guidance to assist the public to travel safely during the coronavirus (COVID-19) pandemic. It is important that the latest version is read.
The advice is to avoid unnecessary work-related travel with an emphasis on keeping people safe when they do need to travel between locations:
- minimise non-essential travel – consider remote options first
- minimise the number of people travelling together in any one vehicle, using fixed travel partners, increasing ventilation when possible and avoiding sitting face-to-face
- ensure drivers and passengers maintain good hygiene and wash their hands regularly
- clean shared vehicles between shifts or on handover
- where workers are required to stay away from home, centrally logging the stay and making sure any overnight accommodation meets physical distancing guidelines
The Coronavirus (COVID-19): Scotland’s Strategic Framework includes travel and transport arrangements. Employers and employees should note what applies to their areas, including any differentiation across different relevant areas.
Please refer to COVID-19 Protection Levels for up to date guidance in your area.
The following measures should be considered:
- if you are travelling in a vehicle (or other forms of transport) as part of your job or business, safe operation of workplaces applies, therefore please refer to advice on car and vehicle sharing and advice on how to travel safely and your employer
- staggering arrival and departure times to reduce crowding into and out of the workplace, taking account of impacts on those with protected characteristics and caring responsibilities
- defining process alternatives for entry/exit points where appropriate, for example, deactivating pass readers or keypads at turnstiles in favour of showing a pass to security personnel at a distance
- reducing congestion, for example, by increasing entry/exit points
- providing handwashing facilities, or hand sanitiser where not possible, at entry and exit points
- using markings and introducing one-way flow at entrances/exits
- providing additional parking or facilities such as bike racks to help people walk, run, or cycle to work where possible
- limiting passengers in corporate vehicles
- providing more storage for workers’ clothes and bags
PPE protects users against health or safety risks at work. It can include items such as safety helmets, gloves, eye protection, high-visibility clothing, safety footwear and safety harnesses. It also includes face masks and respiratory protective equipment, such as Respirators.
HPS guidance for general (non-healthcare) settings offers advice on the use of PPE, confirming organisations should continue to use any PPE required as per local policies (business as usual) and in line with measures justified by a risk assessment. Both the Scottish Government and the Health and Safety Executive (HSE) recommend a risk based approach focused on a hierarchy of control which seeks to eliminate risks, combat risks at source, adapt workplaces to individual needs, ensure adequate staff training around processes to manage the risk and then use PPE where required. Where PPE is deemed necessary, an adequate supply and quality must be maintained which is provided free of charge to workers and which must fit properly. Note that face coverings are not considered PPE.
It is important to note the difference between face masks and face coverings. Face coverings are not classified as PPE. Face coverings are instead largely intended to protect others, not the wearer, against the spread of infection because they cover the nose and mouth, which are the main confirmed sources of transmission of the virus that causes COVID-19.
We have issued guidance on the personal use of face coverings, which includes exemption cards.
Face coverings are mandatory in performing arts venues, including theatres, concert halls, music venues and comedy clubs, unless the person is exempt for health, disability or other reasons or is performing, presenting, addressing a public gathering, making a speech or being a panel member, where:
- there is a partition between the person and other persons, or
- physical distance is maintained between the person and other persons
Consult the up to date advice on wearing face coverings as this may change with each review stage.
We do not recommend the use of temperature checking employees as a means of testing for COVID-19 due to the low efficacy rate of this method.
Further information about the reliability of temperature checking as a test for COVID-19 can be found on the MHRA website.
Workers and visitors to the workplace have a responsibility to ensure they adhere to overall COVID-19 advice which says people with symptoms should remain at home and self-isolate or if a member of their household has symptoms then follow the household isolation guidance (stay at home). Organisations, workers and those identified through other means as having contact or being a COVID case (even if asymptomatic) should remain in regular communication throughout any period of self-isolation.
If an individual develops symptoms consistent with COVID-19, you should help them arrange to be tested by directing them to NHS Inform or having them call 0800 028 2816.
As part of risk assessments, organisations should explore with trade union or workforce representatives how to respond should anyone develop symptoms while at work, including whether it is possible to identify any particular parts of the site the individual may have accessed or equipment used while symptomatic. Consideration should be given to how best to monitor health of all individuals in a workplace.
Organisations may develop plans to change shift patterns to protect the workforce and optimise productivity. This could include reducing the need for travel at peak times and opportunities for flexible working patterns. This will require negotiation with trade union or workforce representatives if it involves a change in terms and conditions.
Emergency, evacuation and accident response processes need to be considered to ensure effective arrangements, which meet physical distancing requirements, are in place. Everyone onsite should be familiar with new processes.
The interpretation and use of guidance should be considered in line with normal protective security operations and practices. Organisations should 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/police CT 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 at risk of 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, organisations should ensure additional suitable staff resource is made available. Organisations 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.
Organisations that conduct physical searches of people and/or their bags, should consider how to ensure safety of those conducting searches while maintaining security standards and following guidance on managing security risks
Scientific studies indicate that it is the cumulative aerosol transmission from both those performing in and those attending indoor events that is likely to create risk. Adequate ventilation is therefore critical within performing arts venues.
Steps that will usually be needed:
- employers should check whether you need to service or adjust ventilation systems, for example, so that they do not automatically reduce ventilation levels due to lower than normal occupancy levels
- where systems serve multiple buildings or you are unsure, advice can be sought from your heating ventilation and air conditioning (HVAC) engineers or advisers (or via the landlord in the case of shared premises)
- undertaking a risk assessment of a ventilation system may require advice from competent persons, such as professionally registered engineers who are Chartered or Incorporated Engineers registered with the Engineering Council
- systems should be adjusted to use outside air rather than recirculating air from within the building, and windows and doors should be opened frequently to encourage ventilation, where possible
- ventilation of empty buildings is recommended but at a reduced rate/speed
See HSE guidance on Air conditioning and ventilation during the coronavirus outbreak and the most recent CIBSE COVID-19 ventilation guidance for more details.