Wednesday 27th May 2020

Risk Assessments, Procedures & Work Instructions – the Legal Bit

Clinic 9 of 11 Please mute

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Housekeeping

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Who are Right

Directions

• Right Directions (Management) Limited are a health and safety, food safety, environmental management, quality management, HR consultancy and provide training to a variety of sectors – mainly leisure.

• We support facilities and organisations with their operational management and we work in collaboration with industry specialists, NGBs and industry bodies, such as CIMSPA, Sport England, Swim England and IQL.

• Right Directions have grown organically over the last 16 years and support over 3000 facilities every year

Welcome to our Ninth

Clinic

Hosted by Caroline Constantine, Gill Twell and Ian Warren

• Aim

To stimulate thought and discussion on how risk assessments, procedures and work instructions related to Covid-19 are developed and are effective

• Key factors

• Ensure suitable and sufficient risk assessments are developed to reflect Covid-19 risks

• Procedures and work instructions are developed to ensure the processes and control measures required to manage Covid-19 risks are implemented

• Engage with other stakeholders (clients/landlords) to achieve / maintain a sustainable business model

Using our operational experience including our health and safety knowledge, we have developed a draft Reopening Mobilisation Checklist that may help your organisation and managers to ask themselves the right questions and implement appropriate action.

Please ask questions and please share any advice that you have. We will be

sharing the Q&A’s from each clinic

Quick recap!

• Business Continuity Plan

• Risk assessments for the facility to consider

customers, visitors & staff

• Risk assessment for vulnerable employees

• Response Plan and Team / Mobilisation /

Reopening Checklist

• Risk Assessments – general areas and

activities

• Cleaning & Maintenance best practice

• Staff Training

• Signage

• Staff Consultation

Keep it Simple:- Follow our 4

S’s

Follow the Right Directions 4S’s:

Writing your risk assessment(s) & developing your

plans

Risk Assessments, Procedures and Work Instructions

Ensuring suitable and sufficient risk assessments are conducted and work instructions and procedures developed, to control the spread of Covid-19.

• Utilise information discussed throughout these clinics, for example, admission control, control of customers, cleaning and activity areas

• Don’t reinvent the wheel, your current processes are probably well documented

• Consult with staff and consider their suggestions• Keep up-to-date with government, NGBs,

awarding bodies and industry guidance• Come and talk to us at Right Directions if you

need any support

Where do we start:

Points to consider – Legal position –

risk assessment

Objective: That all employers carry out a Covid-19 risk assessment (UK Government)

• Employers have a legal responsibility to protect workers and others from risk to their health and safety

• A risk assessment is not about creating huge amounts of paperwork, but rather about identifying sensible measures to control the risks in your workplace (HSE - INDG163(rev4))

• Under the Management of Health and Safety at Work Regulations 1999, the minimum you must do is:• identify what could cause injury or illness in your

business (hazards) • decide how likely it is that someone could be

harmed and how seriously (the risk)• take action to eliminate the hazard, or if this isn’t

possible, control the risk

Where do we start:

Points to consider – Risk assessment

Risk assessment – what to consider and include:

• All the things we have included in the clinics, including activities e.g. various control measures for different types of activities (fitness classes, trampoline sessions and swimming), social distancing, cleaning and signage

• Refer to government, NGB and other industry guidance. A lot of this outlines hazards and suggested control measures

• Ensure the likelihood and severity of the risks are proportionate to the hazard – a lot may change over the next month or so

• Impact on other risk assessments – think about other hazards that may be introduced when implementing the Covid-19 control measures

• Consider the types of people affected, for example, staff, customers, contractors and visitors, with particular regard to those especially vulnerable to Covid-19. The severity and likelihood may also differ dependant on the individuals affected

• Do you need to review your:• Fire risk assessment?• Legionella risk assessment?• COSHH assessments?• Stress and mental health risk assessment?• First aid risk assessment?

Where do we start:

Points to consider – Risk assessment

Risk assessment – sharing the results

• Collaborate with relevant staff

• Share the results with staff / clubs / landlords / clients

• Publish the results on your website – the government expects all employers with over 50 workers to do so (Covid-19 specific risk assessments)

• Review frequently, revise as necessary and keep website up-to-date

The HSE and Environmental Health Officers/Inspectors will be visiting businesses to check that appropriate measures are in place to protect workers and others from Covid-19, the HSE have additional funding

Where do we start:

Points to consider – Work

instructions

Work instructions – what to consider and include

To be developed to communicate control measures arising from Covid-19 risk assessments e.g. admission control, social distancing and cleaning/ touch points

• Keep them simple – use photos to support where necessary

• Refer to government, NGB and industry guidance

• Ensure all control measures identified in the risk assessment are included – no conflict or omissions

• Ensure there is no conflict with existing work instructions

• Use them for training staff

• Consider methods of communication, for example, presentations and videos as well as written documents

• Review and update as a result of risk assessment revisions

Where do we start:

Points to consider – Procedures

Procedures – what to consider and includeWhat procedures need to be developed or amended to incorporate Covid-19 measures?

• Consider writing ‘addendums’ to supplement your procedures, rather than making wholesale changes –maintain existing

• What supplementary policies and procedures may be required?

• Refer to NGB and industry guidance

• Procedures likely to be affected:• Pool / trampoline / facility normal operating procedure• Pool / trampoline / facility emergency action plan• Fire evacuation procedure (life safety priority – not

social distancing during evacuation process, changes to fire exit routes)

• First aid procedure (change in protocols, priorities and PPE recommendations)

• Others?• As with work instructions, use procedures to train

staff – this can be done during furlough

Where do we start:

Points to consider – Work

instructions and procedures

Work Instructions and Procedures – ensuring effectiveness

• Involve staff – ask for feedback

• Monitor - conduct inspections and audits to verify effectiveness

• Review and revise as required following risk assessment amendments

• ‘Test’ procedures (desk-top where necessary, for example, dealing with a pool incident) and review frequently

• Ensure all required records are maintained and completed fully (including staff training records) in order to support and evidence compliance

Employers have a duty under the Health and Safety at Work etc Act 1974 to provide information, instruction, training and supervision – CPD during furlough is allowed

What next…

• Please, if you haven’t booked onto future clinics, grab a slot now, as we only have limited numbers and they are getting booked up

• We are here to help, please let us know and we can support you with:• Writing risk assessments - STITCH (virtual / on site)• Writing your response plan / mobilisation reopening

checklist • Pre-opening inspection audits / Support Days• Post opening inspection audits• Reviewing your procedures to include Covid-19

• We are currently developing online ‘Frontline Staff Pandemic Awareness Training’ which will be available before facilities open

Questions and Best

Practice Tips

•Over to you

Questions and Best

Practice Tips

• Over to you • Question: Will there be a procedure template coming out from RD

• Response: Yes, there will be a procedure related to operational management during a pandemic. This will be available as soon as possible for Right Directions clients.

• Question: Doors open discussion - part of the reason for wanting doors open is to ensure cross flow of air while the activity is taking place.

• Response: It is important that fire doors are closed in the event of a fire. Options for keeping fire doors open include magnetic type devices that operate on fire alarm activation. If these devices aren’t used, doors to activity areas may be open during the activity, but you should ensure that instructors close them after the activity. Fire ‘escape’ doors may be open during activities, but staff should ensure they are closed when the area is not in use. Do not wedge doors open in non-staffed activity areas such as corridors

• Question: General question, how many folks are considering reducing their opening hours, as well as capacity, in order to meet the additional risks head on thus having more existing staff on extra duties, rather than additionally resource for extra staff on extra duties.

• Response: Reducing opening hours along with capacity could be a good way to gauge demand initially. We think it is important to take baby steps to assist in learning what works and to build customer confidence. Alternatively, having longer opening hours to spread out activity sessions may be a way of managing your facility initially, for example, to allow for additional cleaning. Considerations will also need to be given to what is financially viable.

• Question: Can you recommend a supplier for the door foot levers? Thank you

• Response: We cannot recommend a specific supplier for door foot levers; there are many suppliers. We suggest you Google ‘foot door opener’ or ‘foot door pull’.

Questions and Best

Practice Tips

• Question: Does displaying the risk assessments on the website apply in Scotland

• Response: In the Staying Covid-19 Secure guidance published to date for sectors permitted to re-open, the UK government says the results of risk assessments should be shared with the workforce and if possible, businesses should consider publishing the results on their website (and would expect all employers with over 50 workers to do so). However, the Scottish government does not state this and say businesses should ensure the results of the risk assessment are visible and communicated to employees. We recommend that facilities check the websites of devolved administrations to confirm requirements.

• Question: Can you recommend a supplier for free standing sanitiser stations? Thanks

• Response: We are unable to recommend a supplier for free standing sanitiser stations. We would suggest you contact your existing cleaning chemical supplier in the first instance. Be careful, they are secure, lots of sanitiser was stolen before centres were shut in March

• Question: Ian mentioned lifesaving in an emergency supersedes social distancing in an emergency, does this apply to a lifesaving emergency in the pool, for example unconscious casualties?

• Response: Please refer to the RLSS’s Guidance for Swimming Pool Operators -Managing Lifeguards during COVID-19. This gives details on how rescues of unconscious casualties should be carried out as safely as possible.

• Question: Please can you explain more about STITCH and how to access this?

• Response: STITCH is an online platform providing live reporting of accidents, incidents and near misses. It provides a live snapshot of KPIs, allowing management to monitor accident trends both locally and nationally. STITCH also contains a risk assessment module containing a range of templated assessments which can be utilised, whilst allowing site-specific assessments to be recorded and managed. Please contact us at info@rightdirections.co.uk for further information.

Questions and Best

Practice Tips

• Question: Is there any guidance about use of portable air fans or portable A/C units to circulate air in temporary gym / fitness class spaces i.e. issue of moving droplets from breath etc

• Response: Whilst there is some guidance published regarding air conditioning, there is still more information coming out. It is considered that air conditioning units that re-circulate air (without supplying fresh air or extracting air) will pose much more of a risk as airborne pathogens will be re-circulated in the space. We would also advise against using fans as they too will potentially be re-circulating droplets. Consideration should be given to not using any area for temporary activities that has insufficient air handling with no direct supply of outside air.

• Question: UK and Ireland government will have different guidelines?

• Response: Although UK guidelines and those of devolved administrations are broadly similar, we recommend you review and keep up-to-date with your government’s guidelines. If we note any ‘significant’ variations in advice, we will advise. In addition, as the virus progresses, it is possible that ‘regional’ restrictions or loosening of them, may impact on your arrangements.

• Question: You can't reduce hours. We are normally open 15.5 hours a day so now we are looking to book members for 60 minutes and then closing the gym for 30 minutes for cleaning.

• Response: Facilities may have different arrangements and opening hours depending on their building design/capacity, staff availability etc. Consideration will also be given to financial viability.

• Question: Re admissions of users - we know that people displaying symptoms should not enter. What are your views on admissions 'control' for people with pre-existing health conditions or similar predisposition to catching the virus?

• Response: In many cases, we would not know that someone has pre-existing health conditions or similar predisposition to catching the virus. People should take responsibility for their own health. In addition, we should not be discouraging customers to come to our facilities and exercise, as it will usually benefit their overall health. If any pre-existing conditions are disclosed, or are known (i.e. through a referral scheme) then customers should be advised to seek advice from their GP.

• Question: what would be the best approach to risk assessments - one covid19 RA with all control measures or add Covid19 line to each current RA?

• Response: We recommend that separate Covid-19 risk assessment(s) are produced, rather than amending all your existing risk assessments

Questions and Best

Practice Tips

• Question: Random question - If an average gym in an average leisure centre is around 100 stations in a 500sq metre room - what would the max occupancy be for that gym?

• Response: We are unable to answer this as it would depend on a number of factors, for example, what equipment you have, entrances/exits and circulation areas (with consideration for fire escape routes), air quality/ventilation etc. You may need to consider greater space around CV equipment where there is more movement/breath exerted.

• Question: Thoughts on using pool Lockers?

• Response: We recommend you consider how pool lockers can be used in your risk assessment. For example, it may be that areas of lockers are isolated for cleaning, whilst others are in use, then once used, the ‘cleaned’ lockers are used whilst the others are then cleaned. You may also consider having spray sanitiser available for customers to use. Think about locker keys too and how these can be sanitised between use.

• Question: Why is the social distancing guidance not being followed in pools?. Isn`t there still a risk with general breathing from users. Can we control how users are breathing in the pool?

• Response: We recommend you refer to the Swim England guidance that is due to be published on 15th June. This will provide further details on social distancing in the pool and on poolside.

• Question: Regarding stairs where people cross and you cant have a safe social distance. What would you suggest? Traffic light system?

• Response: A traffic light system could be an option, but may be expensive. Ideally, and if possible, you could have one staircase for going up, and another for coming down, or, where the staircase is wide enough, having up and down one-way systems on the same staircase. Signage at the top and bottom of the stairs advising users to keep their distance and wait for others to come up/go down may also be advisable, although more difficult where the top/bottom of the staircase cannot be seen.

Questions and Best

Practice Tips

• Question: Assessing the risk for employees who continue to work from home and undertake training whilst working from home.

• Response: The HSE has some guidance on home working – please see: https://www.hse.gov.uk/toolbox/workers/home.htm Our Clinic 8 on Staff Consultation and Information discussed staff training whilst working from home or furloughed.

• Question: With the current Government guidance do you feel the school / summer holidays will happen this year? when do we actually feel the centres will be allowed to reopen?

• Response: Whilst we hope the summer holidays will happen, it will be dependent on the R rate and government guidance. Similarly, the date leisure facilities will be allowed to re-open will depend on this. This may also vary from country to country and possibly region to region. The UK government has said that this will not be before 4th

July. It’s important facilities are prepared for when a date is announced.

• Question: If doors have to be locked (e.g. gym offices which have sensitive data and valuables inside) how would you recommend employees open these doors or unlock them safely?

• Response: We would recommend that staff are advised to wash their hands or sanitiser is available so staff can sanitise their hands after locking or unlocking the doors. We also recommend keys, handles and keypads are sanitised regularly.

• Question: My place of work is a one level site with one primary corridor running throughout. This can perhaps manage one way traffic with spacing.

• For the purposes of helping socially distancing customers where do we stand being allowed to utilise some fire escape routes and external fire doors as alternate routes and exits to help people leave the building safely via outdoor routes?

• Response: The use of fire escape routes and external fire doors may be an effective way to manage social distancing. However, we recommend you review your fire risk assessment and also consider any potential security issues when keeping external doors open.

Thank you –we hope you

found the clinic useful

• Please email any questions that you wanted to ask but didn’t to info@rightdirections.co.uk

• The recording will be on social media and our website if the quality and content is good enough

• Please click here to leave feedback

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Useful websites • Government UK Guidance for employees, employers and businesses here

• UK Government/Public Health England Advice here

• NHS Advice here

• Health Protection Scotland Advice here

• Public Health Wales Guidance here

• Public Health England Useful Resources here

• Guidance on Expectant Mothers here

• Guidance on Cleaning and Disinfecting, including contaminated areas here

• HSE: Latest Information and Advice here

• CIPD Advice here

• IOSH Guidance here

• Pool Water Treatment and Advisory Group (PWTAG) Advice here

• The RCUK and RLSS UK guidance on teaching and performing CPR can

be sourced at: here

• Ofqual recognised Awarding Organisation, manikin hygiene information here