Hazards Campaign – Going Back to work safely or not at all!
No easing of the Lockdown until seven pre-conditions are met
What we need at work to Go Back and Move Forward!
There is no conflict between economic recovery and health because a healthy economic recovery requires healthy workers and people. The SARS-CoV-2 Virus causes the disease Covid -19.
“ The COVID-19 pandemic has made the links between occupational health and safety and wider public health very stark indeed. Workers Health is Public Health. It has also highlighted the fact that not only the health and safety of health, social and emergency workers is critical to fighting the pandemic but so too is the health and safety of key workers in the service, retail , transport, distribution and manufacturing etc sectors. If you do not protect the workforce in a pandemic you do not protect the public.” Professor A. Watterson
Relaxing the lockdown and going back to work must follow the Precaution, Prevention, Protection and Participation approach.
Precaution is needed as we still do not know enough about the virus or its transmission in various built and open environments. Recent research shows that airborne spread may be important not just droplet contamination of surfaces, and that people can spread the virus although asymptomatic or even pre-symptomatic.
Prevention of work-related COVID-19 infections must be the aim and top priority for employers, regulators and government in all workplaces, essential and non-essential, and it must be enforced rigorously by a properly funded and empowered Health and Safety Executive and Local Authority Environmental Health Officers, EHOs. The Hazards Campaign supports the ILO call for COVID-19 to be recognised as an occupational disease.
Protection of all workers must be achieved using the health and safety law control hierarchy, the highest standards of occupational health, safety and hygiene at work, and measures to protect workers from infection by the public.
Participation of workers and trade unions all levels – not safe unless workers say it is.
It is essential that relaxation of lockdown is done safely so it prevents an immediate and exponential rise in the COVID-19 infection rate that would create a second peak of illnesses and deaths and risk of overwhelming the NHS, which would lead to emergency lockdown again. To avoid this requires national testing, tracing, isolation, with reports and records of infections and deaths provided in an open, transparent regionally and locally accountable manner, capable of rapid alerts to identify local and workplace hotspots which can be acted upon swiftly.
No easing of Lockdown until these Seven Pre-conditions are met:
1. Proven sustained low level of COVID-19 infections and deaths.
This must use all available national and regional data for infections, illnesses and deaths in all setting, such as ONS figures, including excess death comparisons with previous 5 year averages.
2. Testing, Tracing, Isolating via a demonstrably effective intelligence gathering system for infection rates. An open and transparent, locally situated public health system of testing, tracing and isolating for those with COVID-19 infection, with all results made public. This must include:
- easily accessible testing facilities – drive through and mobile testing for all who need it
- providing test results rapidly and directly to individuals tested, publicly and to national and local health services
- ensuring COVID-19 infections and deaths of workers are fully recorded by occupation and workplace in the national testing scheme, and also recorded by employers, reported as notifiable diseases, and reported to HSE through RIDDOR for tracing of transmission and infection mechanisms related to work
- baseline testing available to all workers before they return to work, and a rapid response to increases in infection rate geographically, sectorally and by workplaces. For example when cases start to rise or cases are reported in workplaces, then there should be an automatic ‘stop’ work’ step until the reasons for the rise are explained and action taken. National lockdown should be resumed if widespread infection rate appears to be increasing exponentially again.
- All testing results and statistics relating to COVID-19 must be dis-aggregated by sex, ethnicity and occupation
3 . Hospital, Care and Residential settings have proven capacity and ability to cope with normal demand of all illnesses and injuries plus COVID-19 infections without being under excessive pressure
4. Strict maintenance of social/physical distancing rules of 2 metres minimum in public spaces backed up by hand washing, sanitisers and cleaning of surfaces
5. Safe for workers to use public transport and public spaces including:
- highest level of shielding, screens and distancing protection for workers in places of public congregation like public transport, shops, schools, hospitality etc., plus appropriate PPE where 2 metre physical distance cannot be guaranteed at all times. On public transport there is a need for screens, shields, gloves, alternative payment methods such as cashless cards for protection of workers as passengers and as operators.
- PPE for the public to protect workers, based on the latest research on airborne droplets and transmission, alongside information and training plus provision of specific sourcing of PPE for the public which does not compete with health care and other essential workers
6. In all workplaces the prevention of work-related COVID-19 infections must be the enforced goal.
- This must be top priority for employers, regulators and government, explicitly stated in health and safety policies and practices, and rigorously enforced by the HSE and Local Authorities.
- The 2 metre rule should apply unless it has been demonstrated the work is essential and there is no alternative. Then high-level engineering controls, systems of work, appropriate PPE and other alternative measures must be used and approved by the workers and regulators.
- All health and safety measures must be backed up by employers showing demonstrable safe systems of adapted work organisation and workplaces to ensure safe and healthy working is practical, possible and will be enforced.
- All risk assessments reviewed to a precautionary level of control to prevent all exposure to COVID-19 with specific attention to risk for those groups of workers who are disproportionately represented in illness and deaths figures. Although men are more at risk of death from COVID19 in every age group, black and minority ethnic and women workers are becoming ill and dying at a disproportionate rate and reducing their risks at work must be specifically taken into account.
7. Complete closure of all non-essential workplaces for at least 3 weeks before easing of the lockdown
- to enable employers to plan, consult with union reps, workers’ reps and health and safety regulators, to develop and implement plans to ensure their workplaces and job organisation meet the highest level of ordinary health and safety plus compliance with additional public health guidance, and
- to give the gradual easing of lockdown the best chance of success.
Going back to work– Moving forward
Workplaces must be demonstrably safe or remain closed. Prevention of work-related COVID-19 infections must be the explicit top priority for all employers, regulators and government, stated in health and safety policies and practices and rigorously enforced. If the workforce is not protected then the public will not be protected.
All employers must demonstrate that in consultation with union safety reps or workers representatives, union officers or health and safety inspectors, that they have reviewed existing risk assessments including generic pandemic planning and made new COSHH risk assessments, then established safe systems of work, training for workers and constant monitoring. They must use the COSHH hierarchy of control to prevent exposure to SARS CoV-2 by adapting work organisation and workplaces to ensure safe and healthy working is practical, possible in all circumstances, and will be enforced. If it is impossible to adapt workplace to meet health and safety requirements including the additional public health guidance for COVID-19 then workplaces cannot reopen.
1. Ensure consultation and involvement of trade unions safety reps, workers’ reps, trade union officers and where possible HSE inspectors or LA EHOs and health and safety officers, to ensure the safety and health of the workforce and of the public.
2. Review all risk assessments in light of the continuing health risks of the COVID-19, make new risk assessments and develop safety systems of work which are fully consulted on and agreed, approved by health and safety regulators, and for which training and monitoring are organised. Pay specific attention to risk for those groups of workers who are disproportionately represented in illness and deaths figures such as BAME and women workers. Although men are more at risk of death from COVID19 in every age group, BAME and women workers are becoming ill and dying at a disproportionate rate and reducing their risks must be specifically taken into account.
3. Review safety of premises and equipment, checking ventilation, electrical, mechanical, structural, fire and other relevant safety issues after weeks of lack of use and daily checks during ‘lockdown’ and their appropriateness to be used with the COVID-19 threat.
4. Deep clean work premises before work is reopened and then maintain high standards of cleanliness and hygiene Full COSHH risk assessments for cleaning staff provided with highest level of PPE, safe products and methods of cleaning. After this to maintain high standards of cleanliness of accommodation, safe working with others including public and personal hygiene to be maintained.
5. Review staffing levels and work-loads
These cannot return to normal as fewer workers will be permitted in given workspace to achieve 2m minimum physical distancing. This means lower workloads, targets and work rates which need to be assessed to ensure this is manageable, and that sufficient numbers of staff are available to support work safely. Consider staggered or alternating shifts with no hot desking. Temporarily replace people who are sick or self-isolating
6. Review safe travel to and from work
The safe use of public and private transport needs to be considered includes varying hours, length of days, PPE required for travel including safe disposal of and changing facilities for clothes and welfare provision for cleaning/showering at the beginning and end of shift
7. Support for the mental health for all workers
Review stress risk assessments and take account of new work-stress factors – fear of catching COVID-19 at work or on commute, fear of infecting the family, increased anxiety due to the pandemic, grief in workers who have experienced bereavement from COVID-19 etc which will be exacerbated by returning to work. All workers and especially new workers must be provided with more support, supportive supervision and mentors. Training will need to be regularly reviewed.
8. Provide supportive occupational health services and health surveillance.
This should include access to health and medical surveillance, temperature and other observations. All COVID-19 sickness and deaths of workers need to be recorded by employers, reported to public health authorities as notifiable illness, reported to HSE under RIDDOR, and investigated to establish work-related causes. Immediate action must be taken in the workplace to protect workers and public where cases occur or start to rise locally. If cases are reported in workplaces, then there should be an automatic ‘stop’ work’ until the reasons for the rise are explained and action taken.
9. Ensure no disciplinary consequence or detriment for taking sick/caring leave/self-isolation
10. Provide mental and physical disability/ill health support
Risks assessments must take account of workers with underlying conditions, including pregnancy. These and workers returning from sick leave will need reviews to support reasonable adjustments where necessary, including phased return to work.
11. Provide additional measures in higher risk essential workplaces to ensure the safety, health and welfare of workers in specific essential occupations arising from risk of COVID-19 exposure:
- Health Setting Workers – review of control measures to risks including sufficient quantities and precautionary approach to highest protective levels of PPE
- Teachers and teaching settings –is it possible to maintain social distance, use of PPE and safe systems of work, reduction of pupil/student numbers
- Retail Distribution – welfare provisions, cleanliness
- Transport – protection from of contact with public, 2 metre social distancing and PPE for workers and public
- Retail – strict maintenance of 2 metre social distancing and PPE for workers and public
- Cleaners – review of COSHH assessments for all cleaning chemicals and appropriate PPE
- Social care – review of safe systems of working with several clients, in care homes. This needs to include minimum wages and sickness conditions, safety of sleep overs, public transport, access to and disposal of PPE
- Postal workers – availability of PPE and safe systems of work
12. Wider worker protections that must be ensured:
- Income protection for those who are sick or self-isolating at regular level of income
- All workers must be made aware of their legal rights to refuse work they feel exposes them to danger. This right should be made an enforceable explicit right to refuse work, return to work, or continue to work where safety and health are felt to be at risk, without any immediate or deferred detriment..
- Protection from victimisation and unfair dismissal where workers or reps have been whistle-blowers, carried out inspections of the workplace, raised issues about concerns with enforcing bodies, or taken sick/caring or self-isolation leave.
- Direct access to enforcement officers by safety reps via a help- line to raise concerns, obtain advice and help from HSE Inspectors or Local Authority EHOs
- All COVID-19 sickness and deaths of workers must be reported under RIDDOR to provide intelligence of patterns of exposure at work and possible negligence
- COVID-19 to be recognised as an occupational disease
Useful Information and sources
Hazards Magazine: http://www.hazards.org/index.htm Exposed Coronavirus issue 149
Hazards Campaign: http://www.hazardscampaign.org.uk/ Briefings, statements on CV19
Hazards Campaign Detailed briefing on Risk Assessments for CV19 (coming soon).
TUC Risk Assessment: https://www.tuc.org.uk/research-analysis/reports/risk-assessment-guide-safety-reps
TUC Preparing for return to work outside the home https://www.tuc.org.uk/research-analysis/reports/preparing-return-work-outside-home-trade-union-approach
HSE https://www.hse.gov.uk and special email for union safety and other reps to report concerns at work about Covid19: Union.Covidconcerns@hse.gov.uk
Hazards Campaign Twitter: @hazardscampaign
Facebook: We didn’t vote to die at work email: firstname.lastname@example.org