Coronavirus and Health and Safety – HSE reminds us of legal obligations
As we all change the way we operate across the food industry, from business closure to conversion to take-away and delivery services, and the implementation of social distancing rules, the HSE (Health and Safety Executive) has reminded us that there has not been any relaxation in health and safety regulations for businesses.
In particular, we must ensure that any actions we take due to the pandemic do not lead us to break these rules. One example is that the social distancing and staff protection strategies that some businesses are putting in place has implications for delivery drivers to premises. Food businesses may have decided to stop ‘non-employed’ staff from using these shared facilities in order to protect their staff. This is not permitted.
Delivery Drivers: The Law
Toilet and hand washing facilities must be provided for delivery drivers to ensure that they can carry out their jobs safely. You must continue to provide these facilities for delivery drivers. https://www.hse.gov.uk/news/drivers-transport-delivery-coronavirus.htm
Helpful Tip: Increase the frequency of the cleaning and sanitising of these shared areas and focus on hand contact points such as door handles, taps and soap and towel dispensers. Ensure signage is in place to remind everyone of the requirement to wash their hands for at least 20 seconds using warm water and soap and make sure that there are plentiful supplies of soap and paper towels. Do not allow people to gather or queue for toilet facilities (you could operate a one in one out system).
Equipment Testing: The Law – Provision and use of work equipment regulations (PUWER)
Even though a business may have closed temporarily, any routine equipment testing that is required to take place must still be carried out. For example, pressure systems must be examined by a competent person according to the written scheme of examination. Likewise if lifting equipment is used in your operation, you must continue to carry out checks at the different points e.g. monthly or quarterly inspection checks and the ‘thorough examination’ (under LOLER), that may take place once or twice a year by a competent person. If these checks and examinations become due during the shut–down period, these must still take place to ensure that the specified testing intervals and schemes of examinations are complied with.
Helpful Tip: Continue with your routine checks and plan to ensure that any equipment examinations are booked in with your competent contractors.
PPE/RPE, Risk at Work: Personal Protective Equipment
Employees are required to provide and ensure safe use of PPE in the workplace however we are aware that there is a shortage of some equipment particularly Respiratory Protective Equipment (RPE) such as face masks. You must continue to provide RPE. If you can no longer do this, you must consider whether other measures can be taken, e.g. reducing exposure to safe levels by installing local exhaust ventilation (LEV) otherwise this activity will need to stop. You must also continue to carry out any face fit testing where appropriate. However, anyone showing signs of Coronavirus symptoms must NOT attend a face fit test. Additional measures for fit testing masks to reduce transmission are given here https://www.hse.gov.uk/news/face-mask-ppe-rpe-coronavirus.htm
Helpful Tip: Ensure that your staff are using their mask for the duration of its effective life. It is possible to use a mask for repeated tasks and they may not have to be discarded each time if they are stored in a clean place and in good condition.
Many employees are now working from home to reduce contact across the population. A number of these workers will be working alone. You need to consider how you will keep in touch with them and also consider how to best manage their work environment to ensure that they stay healthy. This is an excellent HSE toolbox to guide you through these considerations: https://www.hse.gov.uk/toolbox/workers/home.htm
Helpful Tip: Arrange regular on-line ‘meets’ to check in with staff. It doesn’t always need to be about work and can be as a group or individually.
It is a legal requirement to manage risks presented by the growth of Legionella bacteria in man-made water systems. If the premises are closed and water outlets are not being used, then a complete disinfection of the water system should take place prior to opening.
Helpful Tip: Indicate on Legionella management documentation that the premises is closed and the outlets are not being used. In addition, when the system disinfection is completed, document this on your documentation.
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