Many questions have emerged on how best to align workplaces to provide a safe working environment to protect against COVID-19 for employees and workers, and their customers.

Similar to the start of the COVID-19 pandemic, as the number of employees attending the workplace slowly increases decisions need to be people-centric, in order to create safe, healthy, and positive workplaces. At all times, communication, consultation, compassion and flexibility are key. 

Below is an outline of key steps to take in your organisation’s response.

How do I develop a COVID-19 response plan?

Return to the workplace has to start with assessing what needs to be addressed to provide protection against COVID-19 and creating a response plan. This is quite difficult for many companies to do, particularly SMEs.  Further guidance on the detailed actions required to comply with the government’s Return to Work Protocol have not been easily available, yet companies are having to invest in the required materials to protect employees. Over 40% of respondents to CIPD Ireland’s COVID-19 survey in June 2020 identified the Risk assessment and COVID-19 response plan as one of the biggest challenges in the steps in the Protocol.

To action this, it is beneficial to draw in employees, employee representatives, occupation health and safety advisors, etc, in compiling the COVID-19 risk assessment of your workplace/s and work activities.  Where occupational health service is available, this should be used to help address worker concerns/anxieties or, alternatively, use the public health advice from the HSE. Employers are expected to appoint at least one lead COVID-19 worker representative who can support the implementation and monitor of protection measures to prevent the spread of COVID-19 in the workplace.

As information about the virus evolves, public health advice is updated on a regular basis, and it is important recognise that flexibility will be required in adopting the measures to reduce its spread.

  • Start by assessing the occupational health and safety risks in your workplace from returning to work at this point in time, taking account of the different types of activities that happen and different locations.

  • Assess where and how workers might be exposed to COVID-19, including the general public, customers, co-workers, contractors.  Assess the environment including physical distancing capacity, need for screens, hand hygiene, face masks, communal spacing, entrance and exits, washrooms,  as well as general hygiene, cleaning, etc. The use of the word worker reflects the need to not just address the protection of employees, but also other contractors, suppliers, etc, who may be at your workplace.

  • Consider individual risk factors of employees (for example, older workers, underlying medical conditions, previous working patterns, equality accommodations etc.) and how these can be mitigated.

  • Plan contingency measures in case of a suspected case of COVID-19, increased absenteeism, changing work patterns, etc.
     
  • In consultation with employees, create an action plan to mitigate the risks so you can produce a COVID-19 response plan and occupational health and safety assessment.

  • Communicate once finalised, and update with learnings and changes as you go along, so you have one version of your workplace’s response plan.

Below are links to a number of sources to help carry out a COVID-19 risk assessment and document your plan:

What happens if an employee has symptoms of COVID-19?

New procedures are required for identifying and isolating employees who may have symptoms of COVID-19. The prompt identification and isolation of potentially infectious individuals is a crucial step in protecting the person involved, their colleagues, customers or others at the workplace.

Once employees start to return to the workplace, you will need a mechanism to help contract tracing, the purpose of which will need to be communicated to all employees:

  • Develop a log so you will know and have a list of who is on-site at each point in time, and what work unit/group they are part of, and where they should be located.

  • Provide clear instructions on what a worker has to do if they develop signs and symptoms of COVID-19 while in the workplace. Make sure the urgency of this is reinforced so workers know to take immediate action and who they should contact. While isolation rooms must be provided where workers live in shared accommodation, these are being put in place in many organisations where facilities allow.

  • Develop an alert mechanism to report any breach of the two metre physical distancing rule, and review any breaches daily so the appropriate action is taken. In some companies this is a specific monitored email address.

  • Clearly display and communicate signs and symptoms of COVID-19, staying up to date with information on public health advice, such as the circumstances for the use of screens and face masks. 

Employees should be reminded that they must: 

  • make themselves aware of the signs and symptoms of COVID-19 
  • keep the required physical distance
  • monitor their own wellbeing
  • immediately report any symptoms that arise at work, and follow instructions. Self-isolate at home and follow public health advice including if they display any signs or symptoms while at home

Communicating these details is not a once off activity, as both employees and customers will forget the details at certain times. So constant visual reminders in the workplace will be necessary.

What new policies and procedures do I need?

There are many changes expected in how people will work while COVID-19 is with us. Identify the issues/policies which will need to be realigned in view of how the business operates in a COVID-19 context. Communication and consultation with employees are necessary around these changes. At all times, employers should demonstrate empathy and acknowledge the difficulties and concerns of employees. Now is a time to produce principled-based people policies, targeted at supporting good practice.

New policies on good hand hygiene, respiratory etiquette and physical distancing will be instrumental in your communication and training plans. Consider the following policies and how they need to be revised to reflect current business requirements. Prioritise and tackle those of most immediacy.

Working hours and patterns

Consider if you will have staggered start and end times, operate different opening and closing times, have extended access/opening times to reduce the number of workers onsite. Business are identifying different working patterns to keep risks of infection to a minimum. Consider where you need to split work groups into tag teams who are on the premises at different times, having blended working with days on-site and days not working or working from home Agree any temporary restructuring of such work patterns with relevant employees. Where employees are working remotely, let them know the extent of flexibility of working hours.

Absence management

As a priority, update your absence policy to reinforce that employees must immediately report any COVID-19 symptoms that arise at work, who this report must be made to, and use of the isolation room. They must immediate self-isolate at home. If they display any signs or symptoms when at home, they must immediate follow public health advice let the employer know, and self-isolate as advised.

Clearly articulate how you will manage co-workers if a colleague has COVID-19 symptoms, or is later diagnosed.  Use the contact log to track those who have been in closer contact with the person so they can immediate follow public health advice and may need to isolate. Brief any external contacts. 

Update your policy about how you are managing the absence of those with COVID-19 and how it fits with your sick pay policy (both those ill and self-isolating with COVID-19 will be entitled to the governments COVID-19 illness payment.

Reaffirm notification and management of normal sick absence. Clarify the boundaries for those working from home, that being at home does not mean working while ill, and all illness should still be called in and recorded. Be alert to stressor or indicators of an illness pattern or mental health concerns. 

Mental health and well-being

Under the Protocol, 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 personal issues. Those returning are likely to have concerns about the risk of infection, transport and child care issues along with changes to their job and work environment. The Protocol advises employers to provide information on publicly available sources of support and advice, much of which is available freely and ensure workers are aware of and have access to any Employee Assistance Programmes or Occupational Health service.

Remote working

Remote working is advised for all who can through all the phases of reopening the economy.  Develop a policy on remote working, ideally expressing a willingness to allow people the flexibility to work remotely at this point in time and to consider it for the future. Require managers and leaders to re-examine all roles which they claim have to be done in the workplace. Research is indicating that for many people, a blended approach with some time spent in the workplace and some working remotely could be the preferred solution.  A full analysis of work and roles should be carried out before individuals are refused opportunities to work from home. 

In the longer term, the sustainability of remote working will require a range of new virtual approaches including induction, development, team building, communications, performance management, etc.

Annual leave

Articulate how you expect annual leave to be managed in 2020.  With travel restrictions, most employees will not be able to travel abroad for holidays, however employees still need time off  for rest and relaxation and to relieve some of the pressure of recent months.

Requiring employees to take a certain amount of leave per quarter or the majority by a specific date in the autumn is becoming common. Employers do retain the right to specific when employees have to take leave, and in such circumstances, must provide a month’s notice. Ensuring all employees take the legal minimum requirement of 20 days (or pro rata amount) has to be managed, for both compliance and operational reasons. Be careful to avoid having large amounts of carry-over days which may creating difficulties in early 2021.

Compliance

Identify any particular compliance concerns and risks as a result of new ways of working, and these will need to be reviewed and communicated.  Consider your GDPR policy and guidance, what additional risks may have emerged with online and remote working and new tools and systems that are now in use.

What COVID-19 prevention measures have to be in place?

At the start of the COVID-19 pandemic, a wide range of people-centric decisions were made by employers.  As we go through the process of reopening our workplaces, again a people-centric approach is needed to take the actions to create safe, healthy, and positive workplaces.

Normal occupational health and safety provisions continue to apply (see the Health and Safety Authority website) with employers responsible for providing a safe working environment, and employees expected to act in safe ways. After completing the risk assessment, the Government’s Return to work safely protocol provides a number of areas for specific action in the COVID-19 response plan to reduce the risk of infection. Information on business supports are available from the Department of Business Enterprise and Innovation.

Pre-return to work

Employers need to clarify and communicate exactly who is returning to the workplace. Unless it is essential, employees are expected to stay home and for many it will be a phased return, with office staff expected to be last. For some this could be 2021. Where there are decisions about who returns to the workplace and when, these must be carried out in a fair and equitable manner. The primary business issue is which roles have to be carried out in the workplace to be performed effectively.

Those who cannot work from home for whatever reason, such as parenting, mental health, physical surroundings, poor access to technology, etc, should then be given consideration. With the increasing personalisation of the employment relationship, employers should take account of individual preferences for place of work wherever possible. This aftermath of COVID-19 is likely to include a lot more remote working than in the pre-COVID-19 days, with the emergence of blended working involving periods/days of remote working and other days onsite. (See the Remote working pulse survey 2020).

Where a business reopens, employers must issue a pre-return to work form for those returning to work to complete at least three days in advance of their return. 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. 

Under the Protocol, each worker has to answer the following questions and if they say Yes to any of them, they should be advised to follow medical advice before returning to work:

  • Do you have symptoms of cough, fever, high temperature, sore throat, runny nose, breathlessness or flu like symptoms now or in the past 14 days?
  • Have you been diagnosed with confirmed or suspected COVID-19 infection in the last 14 days?
  • Are you a close contact of a person who is a confirmed or suspected case of COVID-19 in the past 14 days (that is, less than  two metres for more than 15 minutes accumulative in one day)? 
  • Have you been advised by a doctor to self-isolate at this time?
  • Have you been advised by a doctor to cocoon at this time?
  • Are there any other circumstances relating to COVID-19, not included in the form, which needs to be disclosed to allow your safe return to work?

The CIPD recommends that communication in advance of return to the workplace should go beyond the Protocol recommendations below. Employers should:

  • check availability to return to work, as some individuals may not be in the country,
  • identify any childcare and transport barriers or concerns,
  • understand any individual health or mental health risks,
  • identify whether the employee are covered by the HSE’s high risk group so that added precautions can be taken,
  • collect preferences around remote working for the future.

Induction training

The protocol requires that employees undergo induction training prior to return. This is an important safety action to reduce health risks, as the workplace employees come back to will be quite different from what they left. Many organisations are providing this induction training on-line in advance of the return date, and employees have to complete it to be allowed to return.  It should include:

  • the latest up to-date advice and guidance on public health measures to prevent the spread of COVID-19
  • how good hand hygiene, respiratory etiquette and physical distancing and other safety features will be required
  • what to do if they develop symptoms of COVID-19 and who to contact
  • an outline of the COVID-19 response plan and how the workplace is organised to address the risks
  • how entrances, exits, communal areas such as food areas, wash rooms, lifts will be managed
  • points of contact for the employer and the workers
  • any other sector specific advice that is relevant

This and any other communications should give employees a clear sense of their new working environment, the new safety procedures and the different way of working. It should allay any fears that employees have about the safety of the workplace and inform them how their voice will be heard as measures are reviewed and improved.

Newly appointed COVID-19 employee representatives may need additional training. Remember to update the induction module after some employees return and plans get revised.

Many employers are also advising employees of the need to bring in their own cups, cutlery, pens, etc, to avoid sharing such items. At this time, consider what policy changes need to be communicated, but be careful not to overload individuals with information.

Returning to a different workplace

The Return to Work Protocol reinforces that the best way to prevent person-to-person spread of COVID-19 in the workplace is to use proper hand hygiene, respiratory etiquette and practice physical distancing. Health and safety legislation requires that the necessary controls identified in the risk assessment to prevent the spread of COVID-19 are put in place in every workplace. From the induction, employees should be well informed that they are returning to a different workplace.

Hand and respiratory hygiene

Employers must ensure that appropriate hygiene facilities are in place and provide advice and training and posters on how to perform hand hygiene effectively. Employees must wash their hands regularly and have access to facilities to support hand hygiene, including hand sanitiser/hand wipes and hand washing facilities). They must not share objects that touch their mouth, for example, bottles or cups and must use own pens for signing in. The Protocol advices that cleaning of work areas must be conducted at regular intervals (see ECDC advice) and employees should have essential cleaning materials to keep their own workspace clean. 

On respiratory hygiene employers must provide advice, tissues as well as bins/bags for their disposal, and empty bins at regular intervals.

Physical distancing

Employers must provide for physical distancing across all work activities as this is the most important measure to protect against the transmission of COVID-19. The current government recommendation is two metres of separation. At risk and vulnerable workers should work from home and, if not, ensure they are preferentially supported to maintain a physical distance of two metres.

  • The two metre distancing has to be achieved in a number of ways including implementing a no hand shaking policy, 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.

  • Breaks and break areas have to 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.

  • One way systems are needed for access and exit routes as much as practicable, and measures to capture signing-in/signing-out are needed. This is part of the contact logging and tracking mechanism to have a list of who is on-site at each point in time, and their work unit/group, and where they should be located.

  • Face-to-face interactions should be reduced to the absolute minimum and, as far as practicable, technological alternatives should be used to conduct meetings. 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.

  • Where two 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; maintaining at least a distance of one metre or as much distance as is reasonably practicable; minimising direct worker contact; and providing easy access to hand washing facilities or hand sanitisers so workers can perform hand hygiene as soon as the work task is complete. Face masks provided by the employer should be used in line with public health advice where physical distance is less than two metres, though they can make communication difficulty. Temperature checks are not recommended, and according to the Chief Medical Advisor, Dr Tony Holohan, they do not work.

  • While correctly using PPE – Personal Protective Equipment can help prevent some exposures, it should not take the place of other preventative measures as outlined. Examples of PPE include gloves, goggles and respiratory protection. Use of PPE may already be required in many workplaces to address occupational health and safety risks, for example, exposure to hazardous chemicals such as asbestos. In the context of COVID-19 risk, employers should check the HPSC website regularly for updates regarding its recommended use. 

Travel may be a point of concern, and face masks must be used by any employees while on public transport. Encourage cycling, promote the cycle to work scheme and facilitate private cars as much as necessary. For necessary work-related trips, the use of the same vehicles by multiple workers is not encouraged. 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.

The real risk is expected to be behaviour patterns, where individuals 'forget' the advice provided and breach guidance. Constant communications and visibility of signs will be key messages to reinforce.

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