As higher education providers plan for re-opening their operations they face a balancing act between safeguarding their employees, students and others affected by their activities and wanting to operate in functional buildings.
The Law and Guidance
The overarching requirements of health and safety law have not changed. The Health and Safety at Work etc. Act 1974 still requires employers to:
- Protect the health, safety and welfare of their employees and the health and safety of others whose may be affected by their activities, so far as is reasonably practicable;
- Manage the health and safety risks from workplaces under the employer’s control, the extent of which depends on the level of control.
The Management of Health and Safety at Work Regulations 1999 require a suitable and sufficient risk assessment to be undertaken for workplace activities. The key findings then need to be communicated to the workforce and implementation must be monitored closely.
Public health legislation and guidance introduced in response to Covid-19 also has health and safety implications, particularly regarding social distancing. The UK Government document, Higher education: reopening buildings and campuses is a key sector specific source of information.
Action required – Risk assessment
A robust and comprehensive overarching risk assessment is needed to ensure that appropriate control measures are put in place to eliminate the risks associated with Covid-19 or, where that is not possible, to minimise them.
It should include:
- The likelihood and consequences of exposure to Covid-19 associated with your activities; and
- The potential risks arising from a campus having been closed for a number of weeks to include those relevant to the safety of premises
The assessment can then be considered in the context of each building / workplace and adopted accordingly.
Risk assessments should be kept up-to-date and take account of any changes in law and relevant guidance.
Key education considerations checklist
- Signage and announcements
Workplace signs and regular announcements to remind people to maintain social distancing, to follow the guidance and to report symptoms of COVID-19 immediately.
- Limiting numbers
Consider limiting the capacity/occupancy of buildings, for example, staggered shifts, reduced attendance on specific days and consider flexibly extending period in which the workplace building can be accessed.
Consider appointing employees to monitor and ensure compliance with social distancing, particularly in those areas open/accessible to members of the public.
- Workplace access
Controlling access and egress points to/from and within the building to maintain social distancing and to avoid congregating.
Limit visitors and contractors to essential and business critical only. Provide them with necessary instructions/rules to follow when at the workplace in advance of their visit, and request confirmation that they are not exhibiting symptoms prior to being granted entry.
- Health questionnaires
Consider screening questionnaires on recent travel and health information for employees, students, visitors and contractors as appropriate. Ensure that any such questionnaires and the retention of answers recorded are compliant with data protection legislation.
- Workplace layout
Reassess the layout and positioning of work areas and take a realistic view of how many people can be accommodated.
- Work station allocation
Consider specific allocation of work stations/desks on a daily basis, particularly in agile working environments.
- Communal areas
Limiting the occupancy of communal areas. Implement seat spacing, floor markings and/or put certain seats out of use. Ensure clear signage is in place and consider the use of floor markings. Also consider staggering of break and lunch times.
- Use of lifts
Use signage indicating maximum occupancy.
- Toilet facilities
Consider the need for certain cubicles to be made out of use and a system to measure occupancy. If any toilets must be closed, employers should consider whether this has an impact on how many people may be on site at one time.
- Pedestrian traffic
Consider implementing one-way pedestrian systems and floor markings in corridors and other communal areas.
- Tasks/activities where it is not possible to maintain social distancing
First consider whether that activity needs to continue for the business to operate, if so, carry out a separate task/activity specific risk assessment using the hierarchy of control.
Cleaning and hygiene
- Cleaning prior to reoccupation
Consider whether a deep clean is necessary
- Hand washing
Instruct all entering the building to regularly wash their hands with soap and water for at least 20 seconds and to use hand sanitiser.
- Cleaning stations and sanitiser
Put in place additional hand washing facilities, cleaning stations, hand sanitiser and antiviral wipes; particularly in relation to those activities involving the handling of post and deliveries. Put up appropriate signage on the correct handwashing and sanitisation technique.
Remind employees, students, visitors and contractors to follow hand hygiene guidance with the use of appropriately placed signage.
- Additional cleaning
Enhanced and more regular cleaning throughout the building, and particularly of high-touch points Implement a cleaning check sheet for ease of monitoring.
Regular disinfecting of desks/workstations and at the start and end of every working day.
- Use of toilets
Consider instructing occupants to flush with a closed lid to minimise droplets and residue from plumes in the air.
Consider working hours and arrangements, including ways to limit the number of staff commuting at peak travel hours or staggering start and end times to minimise the risk of infection.
- Public transport
In light of UK Government guidance to avoid public transport, consider increasing capacity for bicycle storage and access to car parking facilities.
- Work related travel
Continue to reduce or cancel non-essential business travel and encourage employees to conduct meetings via videoconferencing software. Where this is not possible, provide additional guidance on essential business travel.
Types of Student
- Vulnerable /shielding
Where students need to attend campus you will need to have considered specific arrangements to cater for individuals
- International / self isolation
Students from overseas may be used to different rules / guidance on COVID-19. Also, procedures will need to be in place for those that exhibit symptoms of COVID-19.
Mental health and wellbeing
- Remember that employees and students may be concerned about their journey to campus and the new environment they will be facing. Ensure that you have support mechanisms in place for those that need them.
- Key topics will include air conditioning, management of water systems, fire safety, statutory examinations of plant (such as lifts, escalators, pressure systems and electrical systems) and duty to manage risks from Asbestos Containing Materials (ACMs)
And finally remember that all of this requires consultation and communication with those that will be affected.
Health and Safety Senior Manager for Pinsent Masons LLP
- On 16th July 2020