covid-19 compliance and risk management for business 12
TRANSCRIPT
ASL Consultancy Ltd
COVID-19 Compliance and Risk Management for Business
12 May 2020
Stuart McGregor, Principal Consultant
In the current Coronavirus pandemic, society and businesses are having to deal with one of the biggest and most intimidating hurdles they have ever seen.
Goal
To be able to approach the Health and safety compliance risks like we would with any other problem.
ASL Consultancy is made up of former HSE Inspectors with over 20 years experience in the area of risk management and health and safety.
We hope to be able to share our experience of compliance and the management of risk to help businesses get themselves in a place so they can confidently reopen and operate safely for their staff and customers.
• Compliance
• Work safely & efficiently
• Consistency with others across industry
• COVID-19 Management to fit easily within quality & safety management systems
• Simplicity - Avoid excess complexity & unnecessary record keeping
Where we are Where we want to be
How do we normally deal with compliance and risk for health and safety
How can we apply that thinking to this new risk?◦ Compliance – what would this look like?◦ Identify and close off risk gaps◦ Vulnerable workers / customers◦ Conflicts with existing H&S controls◦ How to document
Questions
PESTLE Analysis◦ Political
◦ Environmental
◦ Social
◦ Technological
◦ Legal
◦ Environmental
Kipling’s ◦ 6 Honest serving men
o Transfer of knowledge / technology from other industries
o New technologyo Health and Safety law / changeso Impact on health
What / Why / When / How / Where / Who
H&S Law / Regulations◦ E.g Work at Height Regulations 2005
Guidance◦ HSE / IOSH etc◦ Trade bodies e.g National Federation of Roofing
Contractors, Road haulage association, BritishIndependent Retailer Association etc
◦ Unions◦ Insurance providers
Identify and control risks Document our actions
Step 1 - Elimination
Step 2 - Substitution
Step 3 - Engineering controls
Step 4 - Administrative controls
Step 5 - Personal Protective Equipment (PPE)
Identify the hazards
Decide who might be harmed and how
Evaluate the risks and decide on precautions
Record your significant findings
Review your assessment and update if necessary
https://www.hse.gov.uk/risk/controlling-risks.htm#
How do we apply the thinking we are familiar with to help us manage the unique challenges and health and safety risks posed by COVID-19
?
Law◦ Health and Safety at Work Act 1974◦ Regulations – none [yet!] specifically for COVID-19
Guidance◦ HSE◦ Local Authorities◦ Trade bodies/representatives◦ Unions
Insurance Requirements◦ Requirements◦ Advice
NoteCOVID-19 is new, so guidance and advice will be rapidly changing
General duties of employers to their employees:
‘It shall be the duty of every employer to ensure, so far as is reasonably practicable, the health, safety and welfare at work of all his employees’
This means you are responsible for the H&S for those you employ
General duties of persons concerned with premises to persons other than their own employees:
‘It shall be the duty of every employer to conduct his undertaking in such a way as to ensure, so far as is reasonably practicable, that persons not in his employment who may be affected thereby are not thereby exposed to risks to their health or safety’
The means you are also responsible for the H&S for those you do not employ i.e. customers, visitors etc.
Get risks ‘as low as reasonably practicable’◦ Reasonably practicable means doing what you are
reasonably able to do to ensure the H&S of your employees and visitors
Ensure you apply available guidance relevant to your business◦ HSE, Local authorities
◦ Trade bodies / representatives
Insurance◦ Ensure you follow the guidance offered
Examples of guidance later
HSE, Local Authority and Government Trade bodies / representatives◦ Institute of Occupational Safety & Health◦ Chamber of Commerce◦ National Federation of Roofing Contractors
Insurance◦ Association of British Insurers◦ QBE Insurance◦ Zurich Insurance
Unions World Health Organization
A gap or difference between what you are doing and what is required or advised
If a gap is identified this must be closed as quickly as possible
The magnitude of the gap signifies the quantity of non-compliance
Enforcement authorities, customer auditors, insurers etc look for risk gaps to identify non-
compliance.
What controls need to be applied?
Risks need to be “ALARP” make as low as reasonably practicable
e.g. face masks, barriers, separation, new way of working, new cleaning regimes etc
Different categories
Respirators e.g. FFP2, FFP3 and N95◦ RPE [Respiratory Protective Equipment]
◦ High level protection [94 – 98% filtration]
◦ Primary function is to protect the wearer
◦ Fitment critical
Face masks / coverings◦ Primary function is to protect others from the
wearer
Please be mindful - medical masks are in short supply and we are advised should be kept for care/NHS
Practical guidance from one of the worlds largest insurers
COVID-19 Topics include:◦ Home working H&S (First time)
◦ Mothballing a construction site
◦ Commercial motor vehicles
◦ Supply chain
◦ Cyber security
How to deal with the vulnerable, whether it be employees or customers
These have been identified by the government
If in doubt seek advice from an Occupational Health provider
Guidance on shielding and protecting people who are clinically extremely vulnerable from COVID-19
Conflicts between COVID-19 controls and other existing policies, procedures and controls may present themselves.
Don’t forget about other Health and Safety requirements.
Government advice is to use a chlorine based cleaning product
Some bleaches contain chlorine – Caution!
Chlorine products are:◦ Generally avoided as a workplace cleaning product◦ Harmful to health◦ Understood to kill coronavirus
Be careful – we may now be using higher or different risk cleaning products
Alternative? ◦ If not, review COSHH and control requirements and
update the risk assessments
See www.cleaning-matters.co.uk
Flash Burn from hand gel
Employee cleaned hands and touched metal surface before the hand gel evaporated
Static – spark – ignition
Source◦ Institute of Power Engineers, Safety bulletin
◦ We can learn from other industries, countries
◦ Gassco employee, reported in Canada
Learning, includes◦ Use only if soap/water is not available
◦ Use small amount
◦ Ensure evaporated before going near any ignition source
◦ Read and follow instructions on safety data sheet or container for product
◦ No smoking, sparks or flames anywhere nearby!
What documentation should you keep?
e.g. risk assessments, operating procedures, COSHH
Review and amend current procedures rather than rewriting documents
Treat like any other hazard Use many sources of information, e.g.◦ Enforcement – HSE / Local authority◦ Trade bodies – IOSH / sectors representatives◦ Insurance providers◦ Your competitors◦ Other industries
Can you control risks / close risk gaps◦ If no, do you need specialist advice to progress
Document your actions and controls Review
Don’t forget conflicts!
Thank you for listening
Stuart McGregor
Principal Consultant, ASL Consultancy Ltd
T: 01577 542042
W: www.aslconsultancy.com