Training and compliance
As a minimum we expect:
- training around processes and working environment expectations to be provided for all staff returning to 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 to production
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 staff 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 involved with the manufacture of essential goods 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 operating in a safe workplace while also reinforcing the importance of individual employee responsibilities.
Apprentices can return to work at the same time as their co-workers. For specific concerns regarding the safe return to work for apprentices, there is information and support on the Skills Development Scotland website 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.
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 firstname.lastname@example.org.
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.
Advanced Manufacturing Policy Team