SPECIAL FEATURE


drain TRADER


COVID-19 inspections: what do you need to know?


The UK continues to grapplewith COVID-19 in theworkplace,whether that’s reopening bars, restaurants and gyms, or adapting food manufacturing operational practices to fall in linewith COVID-secure guidance.


With guidance and regulation dictated by central government, part of the responsibility for ensuring businesses are COVID-secure lies with the Health & Safety Executive (HSE). Following the Government’s announcement on its return towork strategy inMay, the HSE stated it had begun proactive inspections, and in July, reiterated that “all sectors and businesses of all sizes are in scope for inspections” to ensureworkplaceswere COVID-secure.


It laid out five steps that businesses should be meeting tomeet the latest guidance, including:


1. Carrying out a COVID-19 risk assessment in linewith HSE guidance


2. Developing increased cleaning, hand washing and hygiene procedures


3. Taking all reasonable steps to help peoplework fromhome


4. Maintaining social distancingwhere possible


5. Managing transmission risk,where social distancing is not possible


Industry specific concerns


Whilst these steps appear relatively simple, the ever-evolving Government guidance – whether itwas amove of social distancing from2mto 1m+, or enforcing thewearing of face coverings in enclosed spaces –means that some inwastemanagement could understandably struggle to ensure the workplace ismeeting themost up-to-date guidance. Further, for some it is proving costly to put newprocedures in place, only for the guidance to then change oncemore.


There are also some concerns that the jurisdiction a business has over ensuring COVID guidance is followed has not been properly clarified. Consider staff interactions – howcan you ensure social distancing is being followed in off-site smoking areas, for example?


Thewastemanagement sector had to contend with a vast shift in operational practices as the pandemic unfolded.Whilst the overarching rules regarding PPE, increased hygiene and


social distancing apply, the industry had its specific set of concerns regardingworkplace safety.


The Government issued guidance on how waste collectionmust be prioritised during the pandemic tomitigate the risk posed to health of staff and residents. For example, at a local authority level,waste collection dateswere adapted dependent on the health risks each refuse type posed,with household and food waste considered high and dry recyclables considered low. Further,wastemanagement teamsworkingwithin clinical or care home settings could be at higher risk of coming into contactwith COVID contaminated refuse; the importance of carrying out a full, 360-degree risk assessment is therefore paramount.


Howcan I prepare for a COVID inspection?


So far, the HSE appears to be carrying out the majority of its inspections as random‘spot checks’, including phone calls and on-site visits. Interestingly there have been cases where the HSE has attended on-site to investigate a reported incident and the inspector has extended their investigation to include a COVID assessmentwhilst present. Requests have also beenmade by Inspectors to provide COVID-19 procedures and a copy of the COVID-19 risk assessment prior to the visit taking place.


It’s therefore vital to ensure your business is following COVID-secure guidance and is mitigating necessary risks ahead of time, as you are unlikely to receive notice that an inspection is upcoming. Reasonably practicablemeasuresmust be taken – and clearly demonstrated – tominimise the risk of COVID-19 transmission.


Having documentation to evidence the reasonably practicablemeasures that have been put into place tominimise the risk of COVID-19 transmission is key. Equally, evidence of thesemeasures being communicated toworkers and any associated additional training provided is critical to support and protect an organisation’s position A business should therefore document the risk assessment process ( recording any changes made in response to further advice fromthe government and regulator) and associated actions such as safe systems ofwork, training and communications so that if questioned at a


14 drain TRADER | October 2020 | www.draintraderltd.com Peter James


later date, the organisation can demonstrate the assessment carried out, justify the measures taken and satisfy the HSE that the guidance and developments had been kept under review.


A chronology of compliance set against government and industrywide advice and guidance is critical. Advice and information is continually evolving in respect of COVID-19 so it is important to be able to give clear evidence onwhat policies and procedureswere in place at the time of an incident and be able to draw a comparisonwith the available information at that time, demonstrate howandwhen this has been updated since andwhy, particularly after any newcases of COVID-19 being reported.


As part of the inspection, be prepared to answer questions concerning risk assessments, systems ofwork and training, handling possible outbreakswithin theworkforce and measures in place to enforce and oversee the newmeasures. Documents to support this and demonstratewhat is in place should also be pulled together in preparation for this. And remember that the HSEwill not just look at what the organisation has implemented at management level; expect inspectors to speak to affectedworkers to gather evidence of their understanding of themeasures and the level of compliance on the ground.


If your business operateswithin a location affected by local or partial lockdown, be aware


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