As many businesses are preparing their return to work over the next few weeks it may be useful to compare the Working safely throughout COVID-19 arrangements with ISO 45001:2018 “Occupational health and safety management systems. Requirements with guidance for use.” The text below provides an overview of some of the issues likely to be considered.

This briefing can be used as advice regarding the potential questions a certification auditor may ask and also for an organisation to self-audit its arrangements. As this is a general overview it is hoped that when you apply these questions to your own workplace arrangements it will prompt deeper review of some aspects of your risk assessment and control arrangements.

Clause 4 Needs and expectations

  • Has COVID-19 needs and expectations been considered and if so, does this refer to:
    • Insurance requirements,
    • Contractor and supplier arrangements,
    • Employees, particularly vulnerable persons or those living with vulnerable persons
    • Customers
    • Regulators including PHE advice and guidance
  • Has organisation determined which needs and expectations should become compliance issues. 

Clause 5 Leadership and participation

  • Has a senior manager been nominated with responsibility and accountability for the working safely during COVID-19 arrangements.
  • Have resources been allocated
  • Does the H&S policy cover these arrangements or has a COVID-19 statement been prepared
  • Have worker representatives been consulted and participated in the preparation of the COVID-19 arrangements and policy statement.
    • Are there regular COVID-19 consultations 
  • Can workers freely report any concerns regarding the COVID-19 arrangements without risk of reprisal.

Clause 6 Risks and Opportunities.

  • Have the hazards associated with working through COVID-19 been identified including:
    • Start-up arrangements (Infrastructure issues legionella, MWF, Statutory inspections in date. Welfare arrangements and catering)
    • Organisation of work, (social distancing, partner teams, staggered start times, cleaning regimes)
    • Infrastructure, (inspection and test, restart requirements, impacts of reduced usage on inspection and test)
    • Human factors, (Wellbeing and support during isolation, anxiety of staff or family members, behavioural change)
    • Potential emergency situations (Local area lockdown Infection in workplace protocol, First Aid arrangements, Incident reporting, waste disposal)
    • People with access to the workplace (COVID-19 arrangements for persons with access)
    • Actual or proposed changes to work activity (Access & egress, separation, hours of work, homeworking no longer temporary)
    • Changes in knowledge and information. (HSE BOHS PHE and Government updates)
    • Do opportunities to adapt work to workers needs include:
    • Vulnerable worker ( or persons shielding) arrangements
    • Worker selection (fitness declarations,  Fixed partner teams)
    • Social distancing (area markings and designations)
    • Cleaning regimes
    • Isolation by barriers,  one way systems, designated work areas etc
    • Handwashing & sanitising
    • Exposure time constraints
    • Welfare arrangements (staggered breaks, distancing, packaged meals)
    • Mitigation by ventilation, side to side or back to back working
    • PPE  and face covering considerations
    • Do opportunities to eliminate COVID-19 hazards
    • Homeworking
    • Virtual meetings & remote working tools

Clause 7 Support

  • Competence
    • Can the nominated manager, risk assessors and employee representatives demonstrate an understanding of the COVID-19 arrangements relevant to their work.
  • Awareness
    • Have staff returning to work been advised of the issues of COVID-19, vulnerability factors, nature of controls in place, limitations of controls and their responsibility to support the arrangements and report any concerns.
    • Have staff had refresher training for relevant non-covid-19 issues. 
  • Communication
    • Is there effective communication of handwashing requirements, PPE arrangements, hand sanitiser requirements, reporting of concerns.
    • Has the risk assessment been communicated effectively.

Clause 8 Operational planning and Control

  • Has a COVID-19 protocol been prepared for work activities
  • If a multi-employer workplace has the arrangements been coordinated
  • Has the Hierarchy of control been applied
  • Procurement- Have COVID-19 requirements been added to procurement and outsourcing.
    • Do RAMS etc reflect this

Clause 8 Emergency Preparedness & Response

  • Have arrangements been prepared regarding a person suspected of infection in the workplace
  • Have arrangements been specified regarding testing and isolation of employees or other persons in the workplace
  • Have the First Aid arrangements been modified to reflect need to maintain social distancing and minimise generation of contaminated aerosol.
  • Have arrangements been prepared regarding any waste potentially contaminated with COVID-19

Clause 9 Performance Evaluation

  • Can the organisation show that the arrangements have been compared to the relevant guidance or requirements particularly PHE guidance.
    • Has organisation completed the Staying COVID-19 Secure in 2020 Notice
    • Has organisation published its risk assessment on its website.
  •  Is there regular documented inspection/review of cleaning, segregation and other workplace controls
  • Does the internal audit include COVID-19 arrangements
  • Is there evidence that updates to COVID-19 guidance from PHE, HSE etc are being sourced and incorporated into the management plan.

Clause 9 Management Review

  • Is there evidence that the senior management team have reviewed performance regarding working safely throughout COVID-19 and that they have considered relevant evidence from inspections, audits, complaints, non-conformances or suggestions.

    Clause 10 Improvement

  • Is there evidence that the incident or nonconformity reporting system is compatible with COVID-19 concern reporting
  • Have any incidents of NCs been raised regarding COVID-19 arrangements and if so, is there evidence that issues were addressed in a suitable and timely manner
  • Have any issues been reported outside of the organisation and if so, is there evidence that issues were addressed in a suitable and timely manner
  • Can the organisation demonstrate that it has improved or enhanced the management of COVID-19 in the workplace.

Useful guidance

https://www.gov.uk/guidance/working-safely-during-coronavirus-covid-19
https://www.hse.gov.uk/news/coronavirus.htm
https://www.gov.uk/government/collections/coronavirus-covid-19-list-of-guidance
https://iosh.com/more/news-listing/coronavirus-covid-19-iosh-information-and-links/
https://assets.publishing.service.gov.uk/media/5eb963fcd3bf7f5d39550303/staying-covid-19-secure.pdf

Read the guidance and watch the supporting webinars in determining the arrangements which suit your organisation best.

In summary

It is advisable for the employer to be able to demonstrate that:

  • Senior managers are nominated with responsibility for managing the working safely during COVID-19 arrangements.
  • The working safely throughout COVID-19 arrangements are compliant with current guidance
  • The arrangements are integrated within the existing occupational health and safety management system.
  • Managers periodically review and improve the COVID-19 arrangements to reflect changes in guidance.

Wishing you all a safe and healthy COVID-19 confinement and looking forward to us all being able to enjoy our freedoms again soon.

The SEL Group Team

SEL ISO 45001 Audit tool

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