Health and Safety Executive
HSE Head of Strategy, Media and Campaign
Merton Road, Bootle,
Thank you for your response to my letter on behalf of the Hazards Campaign dated 30.3.20.
I am encouraged that you state ‘HSE will consider a range of actions to improve control of workplace risks’, ranging from the provision of specific advice to employers through to issuing enforcement notices’.
However, our concern about ‘non-essential’ organisations which are still working and unable to comply with social distancing remains unanswered. Surely the risks associated with this far outweighs the ‘indeed it is important for business to carry on’ message in your ‘Social distancing, keeping businesses open and in-work activities during the coronavirus (COVID-19) outbreak’ document?
In addition, many of the organisations which struggle to comply with social distancing also fail to comply with enhanced cleaning of tools and equipment, personal welfare facilities and even in offices, warehouses and manufacturing there is a lack of appreciation about the spread of the virus.
This seems to be in direct conflict with the government Public Health Guidance for trying to control the spread of COVID-19, and with the HSE’s Mission statement – HSE’s mission is to prevent death, injury and ill-health in Great Britain’s workplaces.
The government document says that if a ‘member of staff has helped someone who was taken unwell with a new, continuous cough or a high temperature, they do not need to go home unless they develop symptoms themselves’ and that the advice is for them ‘wash their hands’. This is totally ridiculous, will continue the spread of the virus, put more workers at risk and again appears to be in conflict with government Public Health Guidance about self-isolating to reduce risk of transmission of COVID-19.
As previously stated, we continue to receive reports from workers – those who have insufficient PPE, are not trained in the use of the PPE or have the incorrect PPE in essential and non-essential work. This can be the difference between being protected from a deadly virus or not and therefore there needs to be greater emphasis on the importance of PPE – its specification for different jobs and risks, and the quantity required to fully protect workers.
The HSE document ‘Research: review of personal protective equipment provided in health care settings to manage risk during coronavirus outbreak (COVID-19) is contradictory at best. Surely if FFP3 respirators are required, FFP2 respirators will be inadequate for AGP work with known or suspected patients, when exposure to high viral load is great, or at the very least should only be used only for a short period of time with strict guidance? And what evidence is being collected about ‘passed a face fit test’ and when will this be audited. We would also say that eye protection is essential in all settings, where workers have to be closer than the minimum guidelines of 2m.
There has got to be a recognition that many of the workers who will have the most concerns, will be in workplaces where they are on precarious contracts and not in a trade union organised and supported workplace. In these workplaces it will be impossible for them to resolve issues ‘through speaking with their employer or trade union’ first. They risk losing their jobs. There must be an alternative approach available. The HSE helpline or an alternative option must be available for worried exposed workers.
We welcome your statement about looking to provide a ‘clear message about what you expect employers to do in the current situation’ and that must include reviewing and assessing the risks of the job, controlling them effectively and the consequences to workers health if they fail to do this. When deciding on control measures where possible, this must include the option of work being carried out at home and providing workers with the equipment and tools to do it. After also consulting with safety reps.
- If the work cannot be carried out safely within the public health rules, then it should stop. No-one should be being placed at risk in non-essential workplaces and the HSE must be able to close down unsafe workplaces to protect workers, their families and the wider public health.
- There must be a recognition that vulnerable workers need to be able to contact the HSE regardless of having reported it to their employer first.
- In critical essential employment, workers must have the appropriate PPE, in adequate supplies, necessary to keep them safe and healthy and if not, they must be able to stop work until it is available.
We recognise these are unprecedented times, but all the risks workers are facing, are foreseeable and preventable and we believe it is the HSE’s duty, more than ever in such times, to ‘prevent death, injury and ill-health in Great Britain’s workplaces’ by taking a far more proactive role.
With best wishes
On behalf of Hazards Campaign
Chair of Hazards Campaign/ Coordinator of GMHC