On the 9th of May 2020, the Government published the Return to Work Safely Protocol. This sets out a number of measures that workplaces must take in order to help prevent the spread of COVID-19 in the workplace as we reopen our economy.
The Health Service Authority (HSA) has responsibility for ensuring that employers are following the protocol and preparing and putting systems and controls in place. They will also be carrying out workplace inspections to ensure the Protocol is being implemented. Their approach is very much supportive.
At 29 pages long, the Protocol is quite a comprehensive document and there is a lot to take in, particularly for a small employer. So, we’re breaking it down and pulling out the key points that you need to be aware of moving forward.
The Protocol sets out a number of steps for employers and workers to reduce risk of exposure to COVID-19 in the workplace.
Each workplace must appoint at least one lead worker representative, who along with management will have responsibility for ensuring that COVID-19 preventative measures are adhered to. The Protocol very much promotes collaboration between the employer and employees, and having a Lead Worker Representative is very much key to having everybody working off the same page. For transparency and openness, it is also recommended that you create a log of everyone in your business who has COVID-19 responsibilities – that might be for cleaning or dealing with suspected cases. Download Template: Lead Worker Representative Log
In order to create a COVID-19 Response Plan that is specific to your business, you will need to complete a risk assessment. Look at how and where the virus could be transmitted in your workplace, and from that, you’ll learn what control measures you need to take to minimise these risks. If there is a change to how work is being carried out in your workplace then you will need to review your Health & Safety policies.
The next mandatory point is that all workplaces must develop a COVID-19 Response Plan. This is best thought of as a comprehensive catch-all document that deals with all points of relevance relating to COVID-19 and the workplace in one place. The Protocol specifically sets out the information you must include in your Response Plan, and this includes:
Bright Contracts has been updated with a template COVID-19 response plan which has been written closely following HSA guidelines and checklists.
A pre-return to work form must be completed by employees at least 3 days before they return to work. There are a number of prescribed questions that must be answered. The form allows employees to self-certify that they do not have COVID-19 symptoms or have not been in close contact with any confirmed or suspected cases over the last 14 days. You can get a return to work form template from the HSA website.
In communicating with employees upon their return to work, it would also be advisable to establish whether or not they might be considered as a vulnerable worker. There is a HSE webpage that sets out who high risk groups are, you might consider sending this to employees and asking them to notify you if they fall into any of the categories. If they do fall into a vulnerable category you do have a duty of care to take extra precautions to protect that individual.
Upon returning to work all employees must be given COVID-19 induction training. At a minimum, this training should include:
The training doesn’t have to be overly complicated and you should consider giving this training yourself. If you have a well put together COVID-19 Response Plan, this could double up as your training material for staff. Be sure to keep a record that the training has taken place and note who has attended. If you have any new starters in the coming months, they also should be given the training.
You should keep a log of all close contact, group work and employee interactions that take place. The logic behind this initiative is to be able to assist with contract tracing, should it be required.
Finally, when you’ve done all of the above you may want to look at reviewing and updating some of your existing policies. For example your Sick Leave Policy should really be updated to reflect COVID-19 - the protocol specifically requires employers to review and revise their existing sick leave policies. You might also want to consider putting in place a Working from Home policy if that is the norm in your company, or updating the Annual Leave and Mental Health policies.
Interested in finding out more about Returning Staff to Work? Click here to watch our most recent webinar on-demand where we discuss the Return to Work Safely Protocol, common questions on the practicalities of bringing staff back to work and the payroll implications of returning staff to work.
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