Step 4: General Guidance

The Department for Business, Energy & Industrial Strategy (BEIS), in collaboration with Public Health England (PHE) and the Health and Safety Executive (HSE) have now published comprehensive guidance for businesses as we transition to Step 4 of the Covid Roadmap. All of the guidance can be found here (https://www.gov.uk/guidance/working-safely-during-covid-19).

So in practical terms, what is required and is ‘Freedom Day’ a reality?

Well, not really. Freedom Day is a starting point, it is certainly not a finish to the Covid restrictions. There are still things that you will be required to do. These are:

1. Risk Assessment – you are still required to undertake a risk assessment which addresses the issues associated with Covid-19. You could do this as a hazard in your current suite of risk assessments however we would suggest that you continue with a separate document for the time being. The HSE are still checking workplaces and this will make your life easier if the inspector calls. The risk assessment will need to deal with safeguarding of those that previously were Clinically Extremely Vulnerable and those that may not be fully vaccinated. While we’re talking about vaccination, we would discourage you from using vaccination as a control measure as you might fall foul of disability, equality, or religious discrimination legislation.
2. Track and Trace – You are no longer required to check people in and out of venues. The government has, however, requested that you continue to display the NHS QR code. The use of the code isn’t enforceable and you don’t need to force people to use it if they do not wish to. Our view on this is that there’s no harm in you displaying the code to check in. It’s a public display of control to your staff and if they want to use it then the onus is on them, not you.
3. Working from Home – The ‘work from home wherever possible’ is no longer in place. Working from your normal workplace is now permissible even if working from home is entirely practicable. This allows companies worried about the loss of contact, mental wellbeing, and lack of communication, with employees to bring them back to office. The government is quite clear though that this should not be a mass rush to be back in the office: this should be a slow and gradual process. Your staff may be reluctant to return to the workplace due to the perceived hazards associated with mixing with others. By doing this gradually, and showing your employees the controls that you have in place, the reintroduction of the workplace is likely to be more successful.
4. Self Isolation – Despite all of the headlines to the contrary, the requirement for those with positive tests, and the close contacts of those persons, to self isolate for 10 days remains in place. The NHS app will still ‘ping’ close contacts and employers are encouraged to continue to participate with this programme at the present time. This makes the gradual reintroduction of the workplace even more of an essential step. If you rush back into the workplace, with no thought or controls, you’re likely to end up with your workforce isolating. Take your time and make sure that you have suitable controls in place.
5. Covid Notices – You are no longer required to display the Covid-Secure workplace sign, although we would suggest that you reissue this as soon as possible. It’s a great visual indicator to your workforce and visitors that you’re taking your responsibilities seriously. Re-dating the poster shows that you’ve thought about the requirements of Step 4 and have put reasonable controls in place. You are still required to show hand-washing, hygiene, and any other posters that you deem necessary, throughout the workplace. We would suggest that you rotate notices on a monthly basis as staff tend to become oblivious to them after a time.
6. Emergency Plan – You now need to have an emergency plan that details what measures you might reintroduce (home working, limited numbers, social distancing, PPE etc.) in the event of an outbreak. You also need to nominate a ‘Single Point of Contact’ (SPOC) to ensure that Public Health England (PHE) can deal with someone with authority to enact the plan if required.

The main controls that are expected by PHE or the HSE continue to be:

1. Ventilation
2. Use of outdoor space
3. Reduced contact with individuals – the government now talk about fixed cohorts (so team members or persons on the same shift staying together and not mixing), working side-to-side or back-to-back, use of screens, or face coverings in enclosed or crowded spaces
4. Regular Cleaning

Much of these you should already have in place. It’s because of the requirement to maintain these controls, and the need to reintroduce the workplace gradually, that we consider ‘Freedom Day’ to be a bit of a misnomer. These have been required since March 2020 and are still required now. The reality is that there’s no drastic difference between a workplace today to that of last week.

Keep doing what you’re doing. Document your decisions in your risk assessment. Above all, take small steps. Don’t rush into anything – the consequences could still be damaging!

ProAktive will continue to provide you with advice and please contact us for more specific advice about your particular workplace and requirements. You can reach our Team on 01302 341 344.