Work Safely Protocol
The government’s COVID-19 national protocol for employers and workers, to keep the workforce protected
The Protocol requires employers to put the appropriate measures in place to prevent the spread of COVID-19 and highlights employees’ responsibilities to implement these measures.
The government have published a more recent Work Safely Protocol. This follows the same principles and puts further attention on the provision of masks, ventilation of workplaces and encourages the use of antigen testing and outlines what both employers and employees should do, if such testing is deemed necessary. Further details are here.
The November 2020 Work Safely Protocol came from the Health and Safety Authority, Dept of Enterprise Trade and Employment, the HSE and Department of Health. At all times decisions on who attends a workplace should be in done in compliance with Government and public health advice.
This protocol refers to further resources, particularly from the Health and Safety Authority (HSA) and will continue to be amended in view of how businesses are coping with the infection prevention and control. To date no specific inspection regime has been included.
Strong communication and a shared collaborative approach between employers and employees is key to protecting workplaces against the spread of COVID-19. The protocol recommends regular engagement between employers and workers on preventative measures, and employers are to provide information and guidance including the signs and symptoms of COVID-19, how it spreads, cleaning routines, advice on hand and respiratory hygiene, physical distancing, use of face coverings/masks and Personal Protection Equipment (PPE) and the importance of not attending work if displaying symptoms of COVID-19 or feeling unwell.
Each employer is required to appoint at least one lead worker representative whose role is to work collaboratively with the employer to assist in the implementation of these measures and monitor adherence. The number of representatives appointed will, ideally, be proportionate to the number of workers. This will be alongside the ongoing consultation with health and safety representatives required in every workplace.
The protocol covers workers, not just employees, so consider all contingent, agency, consultants, suppliers who may attend your workplace. It also advises on the measures that workers should follow when not at work, including safe travel and living accommodation. It places shared responsibilities on both employers and employees and addresses the central role of the Lead Worker Representative (LWR).
It demands a lot of preparation and a need to stay on top of changing government advice. It also requires induction, training and ongoing communications with employees across the organisation. The implementation of preventative measures will be resource intensive for organisations of all sizes. It encourages employees to remain working remotely as much as possible.
The people profession will be centre-stage in making such transitions successful, and a strategic organisational approach backed up by people-centred decisions at group and individual level will be key to instilling a positive working culture.
Working safely guidance
The Working Safely Protocol provides guidance and highlights the steps to be taken by employers and workers to reduce risk of exposure to COVID-19 in the workplace. It provides up-to-date evidence on how COVID-19 spreads in general and in the workplace, recognising that public health advice continues to evolve as new knowledge emerges.
It reinforces the need to keep 2-metre distance from other people to avoid catching or spreading the disease and how the disease can survive longest (72 hours) on plastic and stainless steel surfaces. It calls out the specific types of working environments where the spread of COVID-19 is more likely and have had more outbreaks of COVID-19 - closed space settings, such as meat processing plants, nightclubs, places of worship, restaurants, and workplaces where people may be shouting or talking loudly. In these high-risk environments, a greater level of adherence to the public health advice is required by employers and workers.
Keep the COVID-19 Response Plan up to date
The Protocol requires updating your business COVID-19 Response Plan and occupational health and safety risk assessments. Then employers have to address the risks associated with various workplaces and work activities, for example, where and how workers might be exposed, including the general public, customers, co-workers, communal spacing, entrance and exits. etc.
Consider individual risk factors of employees (for example, older workers, underlying medical conditions, English not their first language etc.) and how these can be mitigated. and plan contingency measures in case of a suspected case of COVID-19, increased absenteeism, changing work patterns, etc
It advises that these plans are developed in consultation with workers and communicated once finalised.
Implement policies and procedures for prompt identification and isolation of workers who may have symptoms of COVID-19
The prompt identification and isolation of potentially infectious individuals is a crucial step in protecting the worker involved, their colleagues, customers or others at the workplace. It is also a crucial step in preventing an outbreak in a workplace from moving into the wider community. Employers are to keep a log of contacts to facilitate contact tracing, maintain contact details of workers as well as displaying signs and symptoms of COVID-19, up to date information on public health advice and COVID-19 supports, and what to do if an employee develops signs and symptoms of COVID-19 while in the workplace.
Employees must make themselves aware of the signs and symptoms of COVID-19, monitor their own well-being, not go to work if they or a close contact are displaying any symptoms, immediately report any symptoms that arise at work, and self-isolate at home and follow public health advice if they display any signs or symptoms.
Develop, update, consult, communicate and implement workplace changes or policies
As information about the virus is evolving, public health advice is being updated on a regular basis, and it is important for employers and workers to recognise that flexibility will be required in the measures to reduce its spread.
Employers are advised to review sick leave policies and consult and amend as appropriate in view of COVID-19. They should minimise rotation of staff across multiple settings and workplaces, particularly in relation to agency staff, agree any temporary restructuring of work patterns and provide information on how to receive illness benefits or other Government COVID-19 supports.
Where occupational health service is available, this should be used to help address worker concerns/anxieties and for communicating/training around good hand hygiene, respiratory etiquette and physical distancing. Alternatively, use the public health advice from the HSE and other sources as appropriate and involve the COVID-19 lead worker representative/s in communications. Agree any temporary restructuring of work patterns that may be required to implement the prevention measures.
Implementing the COVID-19 infection prevention and control measures
The guidance reinforces that the best way to prevent spread of COVID-19 in the workplace is to practice physical distancing, use proper hand hygiene and respiratory etiquette. Under its Resilience and Recovery 2020-2021 plan the government continues to recommend that working from home continues as much as possible.
Employers must ensure that appropriate hygiene facilities and hand sanitisers are in place and provide advice and training and posters on how to perform hand hygiene effectively. Employees must follow this advice particularly when they have faced a risk from a close contact, being in a crowded place or taking public transport or moving about. They must not share objects that touch their mouth, for example, bottles or cups and must use own pens for signing in.
On respiratory hygiene employers must provide advice, tissues as well as bins/bags for their disposal, provide advice on the proper use and disposal of face masks and empty bins regularly.
Employers must provide for physical distancing across all work activities, the current government recommended distance between people is 2 metres of separation.
- The protocol says this can be achieved in a number of ways, including implementing a no hand shaking policy, reorganising workspace to ensure physical distancing, organising workers into teams who consistently work and take breaks together and prevent gatherings of workers at the beginning and end of working hours. Teams should be as small as is reasonably practicable in the context of the work to be done. Meetings should be virtual as much as possible, and prolonged meetings avoided.
- Breaks and break areas should be organised in such a way as to facilitate maintenance of physical distancing, for example, placing tables and chairs far enough apart, staggering and extending serving times, using a queue management system with correct distance markings, and considering closing canteen facilities if public health measures cannot be facilitated.
- The protocol recommends one-way systems for access/egress routes in the workplace where practicable, adapting existing sign-in/sign-out measures and systems to ensure that physical distancing can be maintained. This distancing should also be implemented during any outdoor work activity. Those sharing collective accommodation should be in small fixed teams or pods consisting of those who also work together.
- Where 2 metre worker separation cannot be ensured alternative protective measures should be put in place, for example, installing physical barriers, such as clear plastic sneeze guards between workers, maintain at least a distance of 1 metre or as much distance as is reasonably practicable, and minimising direct worker contact and providing easy access to hand washing facilities, hand sanitisers, so workers can perform hand hygiene as soon as the work task is complete. PPE and face masks can be provided in line with public health advice and from 1 Dec 2020 this specifically covers crowded workplaces.
- Business trips and face-to-face interactions should be reduced to the absolute minimum and, as far as practicable, technological alternatives should be used. For necessary work-related trips, the use of the same vehicles by multiple workers is not encouraged. Where face to face meetings are absolutely necessary, the length of the meeting and the numbers attending should be kept to a minimum and participants must maintain physical distancing at all times. A system for recording visits to the site(s) by workers/others as well as visits by workers to other workplaces should be put in place.
Pre-return to work
Employers must issue a pre-return to work form for workers to complete at least 3 days in advance of the return to work. The worker must confirm that they have no symptoms of COVID-19 and also that they are not self-isolating or awaiting the results of a COVID-19 test.
It is necessary to provide induction training for all workers on their return to work, to include the latest up to-date advice and guidance on public health; what to do if they develop symptoms of COVID-19; how the workplace is organised to address the risks; an outline of the COVID-19 response plan; points of contact for the employer and the workers; and any other sector specific advice that is relevant. A useful resource is the HSA’s free online course Return to Work Safely Induction, which employers can use.
Workers are required to inform the employer if there are any circumstances related to COVID-19 that impact their safe return to work, including if they are in the very high-risk category. They must stay at home if displaying any signs or symptoms of COVID-19 or if feeling unwell and contact their doctor and restrict their movements as required.
Employers are expected to have a response plan to respond to a suspected case in the workplace. This should identify who is responsible, the designated isolation area away from other workers and how the worker will be supported to contact their doctor or travel home/ to hospital as required.
Working from home
Generally, office work should continue to be carried out at home, where practicable, and a working from home policy should be developed. The HSA has provided Guidance on working from home, to support employers and employees, including risk assessments. At Risk/Vulnerable Workers should work from home and if not, they are preferentially supported to maintain a physical distance of 2 metres.
Cleaning and PPE
Customer facing roles
Many of the measures advised for workers equally apply to work activity that involves direct customer or visitor contacts. Employers must eliminate physical interaction between workers and customers as much as is reasonably practicable through revised working arrangements, for example through online or phone orders, contactless delivery or managed entry. They should also install physical barriers and clear markings to ensure that contact between workers and customers is kept to a minimum and ensure that queues do not form between customers as they wait to be served.
Workers are expected to follow public health advice and guidance, as well as any specific direction from the employer. They should also adopt good hygiene practices, such as frequent hand washing, respiratory etiquette and physical distancing to protect themselves and their work colleagues and should seek professional healthcare advice if unwell. If a worker has any symptoms of COVID-19, they should not attend work.
Workers are encouraged to travel alone in a car and wear face masks and follow physical distancing in using public transport. They should not congregate outside of work and practice the same prevention measures and follow government guidance in the community.
Occupational Health and Safety measures and recommendations
All existing Occupational Health and Safety provisions continue to apply (see Health and Safety Authority website). Where a risk of exposure to COVID-19 is identified in the COVID-19 Response plan above, an occupational health and safety risk assessment should also be completed. The protocol advises that public health and occupational health and safety measures should be developed in consultation with workers and/or Trade Union and safety representatives, and be communicated to all at the workplace.
On reporting requirements if a worker contracts COVID-19, there is currently is no requirement for an employer to notify the HSA if a worker contracts COVID-19. However it is a reportable disease by a medical practitioner. The amended The Biological Agents Regulations (2013 and 2020) and associated Code of Practice sets out additional requirements for protection of workers from risks related to exposure to biological agents such as VOVID-19 at work.
As often when first aid is required, it may not be possible to maintain a distance of 2 metres. Workers with a specific role in acting as first responders should be provided with updated training on infection prevention and control principles including performance of hand hygiene and appropriate use of personal protective equipment when delivering first aid.
On ventilation, opening windows and doors (not safely doors) can help fresh air to circulate. Where air conditioning units just heat, cool and recirculate the air, it is important to check ventilation systems to ensure that there is an adequate supply of fresh air from a clean source and that recirculation of untreated air is avoided.
On mental health and well-being, employers are expected to put in place support for those who may be suffering from anxiety or stress. When people return to work, they may have gone through traumatic events such as the serious illness or death of a relative or friend, or be experiencing financial difficulties or problems with their personal relationships. Those returning after a period of isolation are likely to have concerns about the risk of infection or changes to their job due to the measures to prevent the spread of COVID-19. Employers are advised to should provide information on publicly available sources of support and advice and information about the prevention and control measures taken to reduce the risk of infection, and to ensure workers are made aware of and have access to any Employee Assistance Programmes or Occupational Health service.The HSA has a range of supports, resources and advice on dealing with stress as a result of COVID-19 and a free online risk assessment tool for addressing work related stress WorkPositive.