Returning to work: risk assessment

Reducing workers' exposure to coronavirus to keep us all safe & healthy

Updated: Friday 11 December 2020 

Employers must carry out a risk assessment, looking specifically at risk of exposure to Covid 19, before anyone returns to work. They must use this to take steps to reduce the risk of employees catching this virus to as low as possible. Risk assessments must be carried out by a ‘competent’ person – someone who knows and understand both the workplace and the work.

In GMB recognised workplaces, we expect Safety Reps to be consulted on any risk assessment carried out.

Examples of steps that can be used to reduce COVID 19 risk are:

  • Putting measures in place to allow a 2 metre distance between colleagues, e.g. floor markings and taped off workstations
  • Adding extra hygiene facilities such as hand sanitiser stations
  • Keeping doors open where safe to do so
  • Staggering start, break and finish times
  • Providing PPE for job roles where workers have to be less than 2 metres apart
  • Keeping windows and doors open and turning off air conditioning that re-circulates air from inside or adapt it so that it takes air from outside.

These measures must be put in place and tested before workers return to the workplace.

The law requires employers to do this, the Health and Safety at Work act 1974 and the regulations that sit under it are there to keep us all safe at work.

This law covers not only direct employees but also anyone carrying out work for the employer (e.g. contractors and agency staff) and anyone affected by the work activity of the employer.

The Management of Health and Safety at Work Regulations 1999, also known as the Management Regs, detail what employers are required to do to comply with the Health Safety at Work Act. Regulation 3 states that the employer must perform a suitable and sufficient risk assessment.

This risk assessment must identify hazards and evaluate the risk then put effective controls in place to eliminate or reduce the risk and manage the work process so that it is safe. Risk assessments must identify hazards that could cause both physical or mental harm.

A hazard is something with that could cause harm or injury.

The risk is how likely harm or injury can be caused by a hazard.

Any risk assessments carried out must be recorded and stored by the employer and reviewed whenever more workers return to work; work processes are restarted; or cases of Covid are suspected or confirmed.

Employees must also work in a safe manner, complying with health and safety control measures, such as wearing PPE and taking part in training.

They must also inform the employer of any serious and imminent danger or any potential hazards (i.e. near misses).

What is a Risk Matrix?

The HSE risk matrix multiplies the likelihood of harm by how severe the harm could be. These can be subjective so they should be agreed with the GMB safety rep. After the risk matrix has been calculated the risks can be prioritised.  

(Click image to expand - HSE.gov.uk/risk/faq, 2020)

Employers should then use the hierarchy of control approach to eliminate or reduce the risk of Covid-19. The most common risk matrices are 3 x 3, as in the graphic, or a more detailed 5 x 5 matrix. Either is acceptable, so long as there is clear escalation of risk – the more likely and harmful, the greater the risk.


What is the Hierarchy of Controls?

Employers are required to adopt a hierarchy of control approach which is set out in Regulation 4, Schedule 1 of the Management of Health and Safety at Work Regulations 1999.

Employers must first see if it is possible to remove the risk altogether, if it is not possible then the risks should be controlled using principles in the following order:

(Click image to expand - Safety+Health Magazine, 2018)

Safety Reps and Safety Committees Regulations 1977 (SRSC)

These regulations state that Safety reps should be involved in the process of risk assessment from the start.

The SRSC regs are sometimes referred to as the ‘Brown Book’. These regulations also give safety reps the right to carry out inspections, attend safety committees and then report back to colleagues.

Checklist of issues to be addressed in a risk assessment to prevent covid-19 transmissions:

1. Re-establishing work:

  • Is a deep clean of the workplace needed before work restarts?
  • Have lifts, escalators and lifting equipment been inspected and maintained?
  • Have all potential sources of legionella, such as air conditioning systems, showers and water cooling towers been inspected and maintained?

2. Access:

  • Reduce and control contact between:
    • Worker and worker
    • Public and public
    • Worker and public
  • Deliveries- how will they be controlled
  • Use of PPE in public areas for all

3. Cleaning/welfare:

  • Handwashing facilities/sanitiser station
  • Enhanced cleaning of all touch points
  • Enhanced cleaning at end of day, regular cleaning during day etc.
  • PPE availability, storage, guidance on use, disposal
  • Cleaning stations to enable safe waste disposal
  • Controlled use of toilet facilities, including access and reducing safe system of flushing toilets with seats down to reduce aerosol spread of Covid-19 infection
  • Controlled use of canteen/rest areas
  • Staggered breaks
  • Review of catering facilities and food preparation and distribution j. Review of first aid including update on training
  • Isolation area identified
  • Temporary removal or restriction on use of shared equipment
  • Review of COSHH assessments for all cleaning chemicals and appropriate PPE
  • No hot desking

4. Maintaining Social/physical Distancing:

  • Review of all work activities to ensure social distancing
  • Signage increased
  • Route markings for one way system around work premises?
  • Supervisor enforcement
  • Operation of lifts – reducing numbers individuals who need to use them
  • Introduce screens/barriers
  • Marking floors for work areas
  • Close some workstations/desks
  • Appropriate PPE for risks that cannot be eliminated or controlled to safe levels as a last resort

5. Work areas

  • No hot desking
  • Desks, floors and signage to maintain social distancing
  • Max number of people allowed in rooms
  • Minimise number of people in workspaces

6. Support for workers

  • Review of stress risk assessments and mental health support
  • Regular communications
  • Is there any requirement for additional training or mentoring?
  • Staffing levels/workloads need to be monitored and temporary replacement of workers who are sick or in self-isolation
  • Workers self-isolating may need support to maintain skills, contacts, training and communication
  • Homeworkers need equipment provided and DSE checks
  • Review need for additional supervision/security in public areas
  • Review of all lone-working

7. Emergency

  • How will an emergency evacuation be carried out safely, maintaining social distancing
  • Review and training of all emergency roles  - first aid, fire warden etc.

8. RIDDOR Reporting

  • Deaths of workers with Covid-19 who may have contracted the disease through work should be reported under Riddor
  • Covid-19 illness should be reported under Riddor if the disease was likely to have been contracted through work

9. Travelling safely to and from work

  • Consideration needs to be made on safety of public transport, including use of PPE, changing and showering/cleansing facilities on arrival at work
  • Availability of carparking for workers

10. Occupational Health

  • What health and medical support is in place?
  • How will testing be carried out?
  • Are there facilities to check temperatures?
  • Systems to report symptoms / illness, and isolation areas for any workers who develop symptoms?
  • What about phased return to work for those off?
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