covid-19 compliance and risk management for business 12

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ASL Consultancy Ltd COVID-19 Compliance and Risk Management for Business 12 May 2020 Stuart McGregor, Principal Consultant

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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

E: [email protected]

W: www.aslconsultancy.com