Objective: That all employers carry out a COVID-19 risk assessment.
You must make sure that the risk assessment for your business addresses the risks of COVID-19, using this guidance to inform your decisions and control measures. A risk assessment is not about creating huge amounts of paperwork, but rather about identifying sensible measures to control the risks in your premises. Your risk assessment will help you decide whether you have done everything you need to.
Transmission of COVID-19 is most strongly associated with close and prolonged contact in indoor environments. The highest risks of transmission are in crowded spaces over extended periods and Physical distancing is an important mitigation measure. Where a situation means that 2 metre face-to-face distancing cannot be achieved it is strongly recommended that additional mitigation measures including (but not limited to) face coverings and minimising duration of exposure are adopted.
The diagram below illustrates the potential transmission routes for COVID-19.
- Infected individual
- Susceptible individual
- Large particles or droplets
- Large droplets settle to ground in a few seconds
- Medium particles or droplets
- Risk of transmission through direct exposure to respiratory droplets and contact with surface
- Small droplets and aerosols
- Small droplets evaporate to become aerosols (droplet nuclei) in this zone
- Aerosols carried in air currents for minutes to hours
Selecting prevention and mitigation measures should use a “hierarchy of control” approach which considers all the potential transmission routes and are bespoke to each setting and activity.
Risks should be reduced to the lowest reasonably practicable level by taking preventative measures, in order of priority. This is what is meant by a hierarchy of control. The list below sets out the order to follow when planning to reduce risks you have identified in your workplace. Consider the headings in the order shown, do not simply jump to the easiest control measure to implement.
- Elimination – Redesign the job or substitute a substance so that the hazard is removed or eliminated.
- Substitution – Replace the material or process with a less hazardous one.
- Engineering controls – for example use work equipment or other measures to prevent falls where you cannot avoid working at height, install or use additional machinery to control risks from dust or fume or separate the hazard from operators by methods such as enclosing or guarding dangerous items of machinery/equipment. Give priority to measures which protect collectively over individual measures.
- Administrative Controls – These are all about identifying and implementing the procedures you need to work safely. For example: reducing the time workers are exposed to hazards (eg by job rotation); prohibiting use of mobile phones in hazardous areas; increasing safety signage, and performing risk assessments.
- Personal protective clothes and equipment – Only after all the previous measures have been tried and found ineffective in controlling risks to a reasonably practicable level, must personal protective equipment (PPE) be used. For example, where you cannot eliminate the risk of a fall, use work equipment or other measures to minimise the distance and consequences of a fall (should one occur). If chosen, PPE should be selected and fitted by the person who uses it. Workers must be trained in the function and limitation of each item of PPE.
An illustration of what these proposed measures to reduce risk of exposure would do is available from the Institute of Occupational Health.
There are interactive tools available to support you from the Health and Safety Executive (HSE) at Managing risks and risk assessments at work.
Risk assessments must reflect the current Welsh Government legislation and guidance.
Your respective local authority can provide advice to support risk assessments. Public protection departments have the role of supporting businesses as well as enforcement action and advice for the public as consumers. Council officers can provide risk assessment templates, guidance notes and checklists.
Everyone needs to assess and manage the risks of COVID-19. As an employer, you also have a legal responsibility to protect workers and others from risk to their health and safety. This means you need to think about the risks they face and do everything reasonably practicable to minimise them, recognising you cannot completely eliminate the risk of COVID-19.
The risk assessment will help inform decisions and control measures. Guidance and examples of risk assessments are provided by the HSE.
Employers have a duty to consult employees on health and safety. Workers should be involved in assessing workplace risks and the development and review of workplace health and safety policies in partnership with the employer, supported by their trade union or other representative organisation where appropriate. If the workforce aren’t unionised, you must consult with a representative chosen by workers. As an employer, you cannot decide who the representative will be.
Employees should be encouraged to identify, speak up and feedback on risks and control measures, so they can be adapted.
When thinking about risk, some key principles include:
- The need to demonstrate a formal, consistent, and pro-active approach to assessing risk and taking appropriate action.
- Risk assessments should be ‘live’ documents and regularly reviewed.
- Assessing risks should consider harms to both the physical and mental health of staff, volunteers and customers.
- Minimising the need for work related journeys and face-to-face contact.
- How you need to take into consideration the age profile of the workforce.
- A need to consider the minimum safe level of staffing – for example to maintain the specific COVID-19 protocols or in the event of a member of staff or volunteer becoming unwell, or needing to isolate repeatedly. This may determine customer capacity on site.
- On staffed sites, what arrangements need to be put into place in the event of someone becoming unwell whilst on the premises?
All risk assessments should recognise that communication, training, and appropriate equipment are significant factors in reducing risk.
Where the enforcing authority, such as the HSE or your local authority, identifies employers who are not taking action to comply with the relevant public health legislation and guidance to control public health risks, they will consider taking a range of actions to improve control of workplace risks. For example, this would cover employers not taking appropriate action to ensure physical distancing, where possible. The actions the HSE can take include the provision of specific advice to employers through to issuing enforcement notices to help secure improvements.
How to raise a concern:
- Contact your employee representative, if your workplace has one.
- Contact your trade union if you have one.
- Use the HSE form
- Contact HSE by phone on 0300 003 1647
3.1 Managing risk
Objective: To reduce risk to the lowest reasonably practicable level by taking preventative measures, in order of priority.
Operators in the visitor economy have a duty to reduce workplace risk to the lowest reasonably practicable level by taking preventative measures. All risks must be assessed, with meaningful discussion with staff and/or their recognised trade union, before re-commencing work. Risk assessments should include those working from home. If you are required by law to have a written risk assessment (where there are five or more employees) then significant findings must be written down and control measures put in place.
In the context of COVID-19 this means working through these steps in order:
- In every workplace, increasing the frequency of handwashing and surface cleaning.
- Businesses and workplaces in the visitor economy should so far as is reasonably practicable, enable working from home. Where working from home is not reasonably practicable, employers must comply with the physical distancing duties.
- There may be a very limited number of work circumstances where measures cannot reasonably be taken to ensure 2 metres distance between people. If it is genuinely essential that the operation should continue then other measures need to be introduced. Where the measures cannot reasonably be taken, in relation to a particular activity, businesses should consider whether that activity needs to continue for the business to operate, and if so, take all the mitigating actions possible to reduce the risk of transmission between their staff and all those who may be on the premises.
- Consider how people get to and from work. If employees are spending significant time on crowded public transport, this increases the risk of the virus entering the workplace. You should show flexibility on this issue, including allowing workers to work from different locations where possible, looking at different start and finish times, and supporting workers getting to and from the workplace.
Further mitigating actions include:
- Increasing the frequency of hand washing and surface cleaning including disinfection of high footfall areas or common touchpoints.
- Keeping the activity time where physical distancing cannot be maintained as short as possible.
- Using screens or barriers to separate people from each other.
- Using back-to-back or side-to-side working (rather than face-to-face) whenever possible.
- Reducing the number of people each person has contact with by using ‘fixed teams or partnering’ (so each person works with only a few others).
Finally, if people must work face-to-face for a sustained period with more than a small group of fixed partners, then you will need to assess whether the activity can safely go ahead. No one should be forced to work in an unsafe work environment.
In your assessment you should have particular regard to whether the people doing the work are especially vulnerable to COVID-19. Risk assessments are a legal requirement for pregnant women, no matter the size of the business. More information can be found on the Royal College of Obstetricians and Gynaecologists website in the COVID-19 virus infection and pregnancy publication.
You should also consider the security implications of any changes you intend to make to your operations and practices in response to COVID-19, as any revisions may present new or altered security risks which may need mitigations.
The recommendations in the rest of this document are ones you should consider as you go through this process. You could also consider any advice that has been produced specifically for your sector, for example by trade associations or trade unions. E.g. UK Hospitality Cymru has further information on many parts of the visitor economy that may help with this process: including hotels and other guest accommodation, restaurants, pubs and bars, amusement parks and holiday parks.
If you have not already done so, you should carry out an assessment of the risks posed by COVID-19 in your workplace as soon as possible. If you are currently operating, you are likely to have gone through a lot of this thinking already. We recommend that you use this document to identify any further improvements you should make.
You should consider the security implications of any changes you intend to make to your operations and practices in response to COVID-19, as any revisions may present new or altered security risks or issues with accessibility which may need mitigations. Sections 4 and 8 outline the key security considerations and advice.
Whilst the risk to health from COVID-19 is at the forefront of everyone’s minds, the threat of terrorism nonetheless remains substantial. It is essential that businesses and other organisations remain cognisant of these threats as they look to adjust their operations, ensuring that security measures are proactively adapted to support and complement other changes.
3.2 Sharing the results of your risk assessment
You should share the results of your risk assessment with your workforce. If possible, you should consider publishing the results on your website, a dedicated employee website or employee communications portal (and we would expect all employers with over 50 workers to do so). There may also be other industry standards or marks that you can use to demonstrate to any visitors, guests and customers that you have thought carefully about risk.