With the UK now gradually reopening for business, organisations across the workplace health spectrum have been developing toolkits and resources to help occupational health professionals guide employers on safe return to work. Nic Paton looks at some of what’s now available.
“At the heart of the return to work is controlling the risk posed by the virus. Ensuring safe working practices are in place will help deliver a safe return to work and support businesses across the country.”
This comment by Health and Safety Executive chief executive Sarah Albon may, to an extent, have been stating the obvious. But her words at May’s launch of the government’s post-lockdown return-to-work guidance also encapsulate the central challenge facing occupational health as UK plc has gradually re-emerged over the past couple of months.
As we reported in May and June, the fear within the profession is that the sheer scale of the physical and mental health return-to-work challenges it will face, combined with the practicalities of getting workplaces back up and running safely and the complexities of continuing to provide “normal” OH activities in a socially distanced working world, could become overwhelming.
OH professionals will of course have little choice but simply to do the best they can in immensely difficult and complex circumstances – and the profession will undoubtedly rise to the challenge.
However, the good news is that, since the crisis began and certainly since thoughts have begun to turn to questions around returning to work, organisations across the workplace health, safety and wellbeing spectrum have been developing resources to help.
What this article therefore intends to do is to provide a snapshot – and this is in no way intended to be a definitive guide – of some of the useful toolkits, advice and guidance now available to OH practitioners wrestling with these complex questions. Inevitably, it will be up to practitioners themselves to sift and filter what is most relevant to the sector or organisations they are working with.
But, with so much information now out there (and being added to all the time), the hope is this will provide at least some useful food for thought, pointers to resources you may not have been aware of, and some practical assistance in terms of navigating this new return-to-work landscape.
The government’s ‘five steps’
The government in its Working safely during coronavirus (Covid-19) guidance set out five steps to working safely that should act as a baseline for organisations, employers and, within that, occupational health to build upon to ensure a safe and healthy return to work. The five steps are:
- Carry out a Covid-19 risk assessment. This should be in line with Health and Safety Executive (HSE) guidance, including consultation with workers or trade unions, and the results should be shared with workers or on the organisation’s website.
- Develop cleaning, handwashing and hygiene procedures. This should include encouraging people to follow the NHS’s guidance on hand washing and hygiene; the provision of hand sanitiser around the workplace, in addition to washrooms; frequent cleaning and disinfecting objects and surfaces that are touched regularly; enhancing cleaning for busy areas; setting clear use and cleaning guidance for toilets; and providing hand drying facilities – either paper towels or electrical dryers.
- Help people to work from home. Employers should “take all reasonable steps” to help people to continue to work from home by: discussing home working arrangements; ensuring they have the right equipment, for example remote access to work systems; including them in all necessary communications; and looking after their physical and mental wellbeing.
- Maintain two-metre social distancing, where possible. This should include putting up signs to remind workers and visitors of social distancing guidance; avoiding sharing workstations; using floor tape or paint to mark areas to help people keep to a two-metre distance; arranging one-way traffic through the workplace if possible; and switching to seeing visitors by appointment only if possible.
- Where people cannot be two metres apart, transmission risk should be managed. This should be achieved by considering whether an activity needs to continue for the business to operate; keeping the activity time involved as short as possible; using screens or barriers to separate people from each other; using back-to-back or side-to-side working whenever possible; staggering arrival and departure times; and reducing the number of people each person has contact with by using “fixed teams or partnering”.
On top of this, the guidance encompasses eight guides covering a range of different types of work. These include construction and outdoor work; factories, plants and warehouses; laboratories and research facilities; offices and contact centres; other people’s homes; restaurants offering takeaway or delivery; shops and retail branches; vehicles and mobile working.
Public Health England updates
Occupational health practitioners will inevitably need to keep fully abreast of the regularly updated information being published by Public Health England.
This includes collated guidance for the public, non-clinical settings, transport, adult social care, health professionals, infection prevention and control and sampling and diagnostics, among other areas.
It is also where the weekly Covid-19 surveillance report is published and the dashboard where you can track statistics on cases and deaths.
“Returning to the workplace after the Covid-19 lockdown” (SOM)
This SOM (Society of Occupational Medicine) toolkit is free to download from the society’s website and has been developed with help from the Advisory, Conciliation and Arbitration Service (Acas), the Chartered Institute of Personnel and Development (CIPD), Business in the Community (BITC), and mental health charity Mind.
It highlights the importance of organisations recognising that managing return to work in the “new normal” of post-Covid-19 will be as much about addressing social and emotional needs as medical concerns.
While line managers will, naturally, be the first point of contact for employees returning to work, occupational health can play a key role in identifying and managing any specific obstacles to returning to work and agreeing a return-to-work plan where necessary or appropriate. The toolkit suggests a number of conversation starters, either for line managers or OH, along the lines of:
- How has life been?
- Are you OK about coming back?
- Do you feel safe coming back?
- How we can make your job better?
- Do you know who to talk with if any problems crop up?
If someone has existing common health problems, questions could include:
- Do you feel up to doing your usual job with your health problem?
- What parts of your job will you find difficult because of your health problem?
- What can we change to help overcome the difficulties?
Alongside this, the toolkit emphasises that all sides – employers, employees, HR and OH – will have a duty to understand how to make the workplace safe, their role in that process, and the need to be involved and work together in making those decisions.
Within this, OH is likely to have a key and ongoing role in risk assessment, for example advice on cleaning, disinfection, ergonomic and hygiene/ventilation systems and how “stringent social distancing” can be applied in the workplace. Issues such as what the first day back will be like, what to expect, the commute and workplace strategies to minimise risk will also need to be addressed.
When it comes to supporting mental health, the toolkit recommends employers providing and promoting access to mental health support, including awareness raising and tools and techniques to manage mental health, such as Mind’s Wellness Action Plans.
The toolkit highlights that there may be mental health challenges in particular around managing the transition for workers out of lockdown to being back at work, or partially back at work. It recommends using the HSE’s Management Standards for Work Stress framework to help assess the risks posed by new ways of working.
The toolkit can also be used in conjunction with a follow-up document published by SOM, Sustaining Work-Relevant Mental Health Post COVID-19 Toolkit, that has been developed with the Royal College of Psychiatrists and CIPD.
This outlines good practice around work-relevant mental health, guidance to support and reduce stressors in the workplace, and advice on detecting and preventing mental ill health.
Equally, it is important OH ensures line managers are aware of more general resources that may be helpful, with SOM citing the CIPD’s guide, Six steps to help your team thrive, and Acas’ Challenging conversations and how to manage them.
The toolkit includes a potentially valuable risk assessment template for assessing Covid-19 transmission within the workplace and examples of various situations and risk judgements.
When it comes to personal protective equipment (PPE), the guidance emphasises that employers should make clear whether PPE is mandatory or advisory, in other words have a clear policy and state consequences of non-compliance. As it states: “For customer-facing roles, this is not only a source of health and safety risks but also an issue that may cause considerable staff anxiety.”
Within all this, SOM recommends that OH (as well as occupational therapy, physiotherapy, vocational rehabilitation and others) can play a key role in terms of:
- Education and intervention around psychological wellbeing. This can include addressing the barriers to people staying connected with families, friends, work and their community and encourage engagement in meaningful occupations, physical activity and relaxation to promote wellbeing and reduce symptoms of mental ill health.
- Onward referral and collaboration where additional specialist input is required. For example, this could include cardiac, pulmonary, or psychological.
- Intervention and support around breathlessness and fatigue management. This could include education, intervention and review.
- Self-management techniques. This could include pacing, grading, prioritising, relaxation and sleep hygiene education.
- Facilitation of group/individual rehabilitation. This would be delivered by other competent professionals and referrals to social prescribing schemes and signposting to community organisations and welfare rights advice.
Resources from the Association of Local Authority Medical Advisers
The Association of Local Authority Medical Advisers (ALAMA) now has a range of tools and guides on its website, as well as links to various other resources, including the SOM toolkit above and the Faculty of Occupational Medicine’s risk reduction framework for NHS staff (and see later for more on this).
Importantly, it has developed a Covid-19 Medical Risk Assessment tool that provides information about personal vulnerability to Covid-19 according to age, sex, ethnicity and comorbidities.
This, ALAMA outlines, is based around an analysis of epidemiological data for the UK looking at the contributions to vulnerability from sex, ethnicity and some of the most common comorbidities among people of working age, and has then been summarised in terms of their equivalence to added years of age. In essence, it allows for the calculation of a person’s “Covid-age”, or a simple summary measure indicating the age of a healthy white male with equivalent vulnerability.
Given the growing recognition that Covid-19 is as much a disease that affects the blood as it is a respiratory illness, ALAMA’s Cardiovascular conditions and Covid-19 guide may also be useful.
IOSH ‘Returning Safely’ suite of advice
Another organisation that has been busy developing resources that may be useful to OH professionals is the Institution of Occupational Safety and Health (IOSH).
It has called for organisations to ensure new working arrangements factor in issues such as accessibility arrangements for all, example that people with disabilities have access to lifts, even if social distancing requirements now restrict their use.
It can developed resources under the banner “Returning Safely”. These cover areas such as people, workplaces, equipment, systems, legal obligations and risk assessments.
To look at just one, people, this includes a return-to-work after Covid-19 “factsheet” based around a four-point action plan, namely that organisations should:
- Introduce or revise their return-to-work policy.
- While workers are off work with illness, keep in regular contact with them.
- Take a tailored approach, including risk assessment of work tasks and return-to-work controls.
- Have a mechanism in place to review the plan.
It then outlines who should be involved within the return-to-work team (senior managers, managers, HR, union or staff representatives, occupational safety or health and/or OH). It sets out some advice on return to work following bereavement and, crucially, the role as it sees it of the occupational safety and health professional. This will include, IOSH recommends:
- giving advice on risk assessments;
- promoting the benefits of work to workers’ health and wellbeing; and
- focusing on what the worker can do and how barriers to their return to work can be removed.
ICO advice on data protection
In the scramble to get back to work and keep workers and workplaces safe the importance of maintaining data security and integrity can easily get overlooked.
But the Information Commissioner’s Office (ICO) has published potentially useful advice for employers and OH around the data protection ramifications they may need to be considering within any new Covid-19 workplace testing regimes.
The guidance, Workplace testing – guidance for employers is an FAQ-style document that runs through a range of key questions that employers may be likely to ask. For example, if an employer wants to carry out tests to check whether their staff have coronavirus symptoms, do they need to consider data protection laws?
The answer here very definitely is “yes”, the ICO points out. As it states: “You will be processing information that relates to an identified or identifiable individual, so, you need to comply with the GDPR and the Data Protection Act 2018. That means handling it lawfully, fairly and transparently.
“Personal data that relates to health is more sensitive and is classed as ‘special category data’ so it must be even more carefully protected. Data protection law does not prevent you from taking the necessary steps to keep your staff and the public safe and supported during the present public health emergency. But it does require you to be responsible with people’s personal data and ensure it is handled with care,” it adds.
But, to emphasise, for brevity’s sake this is just one of ten questions covered in the guidance.
Role of HSE inspections
The extent to which the Health and Safety Executive (HSE) will be able to carry out physical spot-checks to ensure workplaces are remaining “Covid-secure” remains a question of some debate.
Prime minister Boris Johnson in May said the HSE would carry out safety spot-checks in workplaces to ensure employers were complying with social distancing and infection control rules.
And, according to a poll by the union Prospect in June, nearly two-thirds (67%) of workers agree that random in-person checks should be carried out, compared with 9% saying phone checks would be good enough and 11% saying employers should be allowed to police themselves. Just 30% of workers said they would feel comfortable going into work if only telephone checks were taking place.
However, according to The Independent newspaper, and citing figures from the House of Commons library, HSE staff numbers have fallen from 3,702 to 2,501 since 2009, while the number of inspectors had dropped from 1,495 to 978. The agency had also suspended physical spot inspections during the pandemic to keep its staff safe.
Although Johnson has announced an extra £14m for the HSE to apply for, in the long term the executive’s funding has diminished, falling from £239m in 2009-10 to £135m in 2017-18, the newspaper added.
In a statement, HSE at the end of May said that it would “carry out work to check that appropriate measures are in place to protect workers from Covid-19”, including resuming “targeted proactive inspection work of high-risk industries”.
Faculty of Occupational Medicine guidance
The Faculty of Occupational Medicine has published a consensus document, Risk reduction framework for NHS staff at risk of Covid-19 infection, that has emerged from an expert working group led by Professor Kamlesh Khunti.
The group has been examining how best to protect the NHS workforce and develop a risk reduction framework based on the currently available evidence.
“General Workplace Safety Risk Assessment” (the CIPD)
This template form developed by the Chartered Institute of Personnel and Development (CIPD) – so predominantly for an HR audience – is for employers to use to help manage the return to work process.
It has emphasised that businesses need to ensure they can meet three key tests before bringing their people back to the workplace: is it essential, is it sufficiently safe, is it mutually agreed?
“Protecting workers’ health during the extended Covid-19 outbreak” (BOHS)
This document from the British Occupational Hygiene Society (BOHS) addresses a range of safety-critical issues, including biological infestation challenges such as legionella, the degradation of seals and others protections, corrosions and instability around chemical storage, and the accumulation of carcinogenic dusts.
Areas covered include taking a risk-based approach to restarting work, understanding the spread and control of Covid-19, cleaning, safe restart protocols, reviewing existing risks, and coping with a lack of PPE, among other areas.
“Back to business: supporting disabled employees post-lockdown” (BDF)
This guidance from the Business Disability Forum brings together advice from the government, Equality and Human Rights Commission and others to offers practical advice for businesses on planning their back to the workplace strategies, in the context of their employees with disabilities.
Topics covered include guidance on: the general post-lockdown environment, commuting and travelling for work, the office environment, psychological and social considerations, monitoring compliance and behaviours, preparing for a potential second wave, and employees waiting for NHS treatment and procedures.
“Working safely during coronavirus (COVID-19)”, May 2020, Department for Business, Energy and Industrial Strategy, https://www.gov.uk/guidance/working-safely-during-coronavirus-covid-19
Coronavirus (COVID-19): guidance, Public Health England, https://www.gov.uk/government/collections/coronavirus-covid-19-list-of-guidance
“Managing risks and risk assessment at work”, Health and Safety Executive, https://www.hse.gov.uk/simple-health-safety/risk/index.htm
“How to wash your hands”, NHS, https://www.nhs.uk/live-well/healthy-body/best-way-to-wash-your-hands/
“Returning to the workplace after the COVID-19 lockdown – toolkits”, https://www.som.org.uk/return-to-work/
“Sustaining Work-Relevant Mental Health Post COVID-19 Toolkit”, SOM, https://www.som.org.uk/Sustaining_work_relevant_mental_health_post_COVID-19_toolkit.pdf
“Covid-19 Medical Risk Assessment”, ALAMA, https://alama.org.uk/covid-19-medical-risk-assessment/
“Cardiovascular conditions and Covid-19”, ALAMA, https://alama.org.uk/covid-19-medical-risk-assessment/cardiovascular-conditions-and-covid-19/
“Returning Safely”, Institution of Occupational Safety and Health, https://iosh.com/resources-and-research/our-resources/communicable-diseases/coronavirus/returning-safely/
“Planning an individual’s return to work after illness with Covid-19”, Institution of Occupational Safety and Health, https://iosh.com/resources-and-research/our-resources/communicable-diseases/coronavirus/returning-safely/people/planning-an-individuals-return/
“Workplace testing – guidance for employers”, ICO, https://ico.org.uk/global/data-protection-and-coronavirus-information-hub/data-protection-and-coronavirus/workplace-testing-guidance-for-employers/?fbclid=IwAR0aEafb861oTtPdMdn345uja_lgAF3_KcCuX7T8xNdOOt3LYi7oyoJGz8k
“Prospect poll finds 67% of workers want in person spot-checks to ensure that workplaces are safe”, June 2020, Prospect, https://prospect.org.uk/news/prospect-poll-finds-67-of-workers-want-in-person-spot-checks-to-ensure-that-workplaces-are-safe/
“Coronavirus: Majority of British workers want watchdog spot checks to keep them safe from Covid-19”, Independent, June 2020, https://www.independent.co.uk/news/uk/politics/coronavirus-workers-watchdog-spot-checks-a9541176.html
“Risk Reduction Framework for NHS staff at risk of COVID-19 infection”, Faculty of Occupational Medicine, https://www.fom.ac.uk/wp-content/uploads/Risk-Reduction-Framework-for-NHS-staff-at-risk-of-COVID-19-infection-12-05-20.pdf
“General Workplace Safety Risk Assessment”, CIPD, https://www.cipd.co.uk/Images/general-workplace-safety-risk-assessment-example_tcm18-77042.pdf
“Protecting workers’ health during the extended Covid-19 outbreak”, BOHS, http://www.bohs.org/wp-content/uploads/2020/05/BOHS-COVID-Return-to-Work-Guidance-7-May-2020.pdf
“Back to business: supporting disabled employees post-lockdown”, Business Disability Forum, https://businessdisabilityforum.org.uk/covid-19/back-to-business-considerations-for-employers-supporting-disabled-employees-post-lockdown/
Mind, Wellness Action Plans, https://www.mind.org.uk/workplace/mental-health-at-work/taking-care-of-your-staff/employer-resources/wellness-action-plan-download/
“Six steps to help your team thrive”, CIPD, https://www.cipd.co.uk/Images/help-your-team-thrive-at-work-1_tcm18-55932.pdf
“Challenging conversations and how to manage them”, Acas, https://archive.acas.org.uk/conversations
Management Standards for Work Stress, Health and Safety Executive, https://www.hse.gov.uk/stress/standards/
“Coronavirus: will it be occupational health rather than the NHS that is overwhelmed post-lockdown?”, May 2020 (print June 2020), Occupational Health & Wellbeing, https://www.personneltoday.com/?p=252272