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Covid-19 Risk Assessments and Return-to-Work plans
The ‘Risk-Adjusted Strategy’
The South African government has engaged into a risk adjusted strategy in efforts to leverage optimised economic activities during the phased implementation of return to work, whilst combating the spread of the Covid-19 virus. The Department of Corporate Governance and Traditional Affairs (COGTA) has developed and released a system of ‘alert levels’ in order to determine which sector industry categories (SIC) are allowed to operate at each level and under what conditions.
The ‘alert levels’ can be viewed as below:
Each level is evaluated by four major criteria:
- The value of the industry sector to the economy.
- The impact that the sector industry category can suffer due to continued lockdown
- The level of transmission risk within these industry sectors and organisations, which includes their ability to implement mitigation factor concerning covid-19 management
- The ability of the sector to promote the well-being of communities and livelihood of the most vulnerable
The factors, as per COGTA, that can affect the risk of transmission include:
- The nature of the business
- The location of the business
- The geographic location of the workforce
- The profile of the workforce
- Practical mitigation measures
- The feasibility of mitigation measures
The following considerations were provided for the first phase of easing restrictions and can be used as guidelines to set the objectives for the phased return to work:
This provides a clear objective for the risk management approach that all organizations should adopt and as we know, effective risk management requires strategy to be reflected within the risk assessment process. Therefore, the risk assessment provides the foundation for the implementation of return-to-work plans as required in Regulation 47(1)(b) in the Alert level 3 lockdown regulations, 28 May 2020 and Clause 17.2 of the Consolidated Covid-19 Direction on Health and Safety in the Workplace, 04 June 2020.
An organization should align their risk criteria according to the criteria for the ‘alert levels.’ Formal risk resilient Return-to-Work (RtW) plans should be developed and implemented by organisations that reflect the achievement of these risk objectives. This in turn should encourage a swift ‘ease of restrictions.’
What is a Return-to-Work Plan?
These plans would certainly differ according to size and scale of organizations, however, all are equally important and would include:
- the control measures to facilitate the phased return to work of employees
- the arrangements made for vulnerable workers and work from home
- the arrangements made for screening and healthcare
- the measures for social distancing
- arrangements for serving the public where relevant
- the details of the COVID -19 compliance officer
Furthermore, to enable South African businesses to open their doors and participate in a risk compliant atmosphere, the Consolidated Covid-19 Direction on Health and Safety in the Workplace, 04 June 2020, issued by the Minister in terms of Regulation 4(10) of the National Disaster Regulations, includes specific measures for employers with less than ten employees in clause 46 of the Directive.
How do Covid-19 Risk Assessments apply to me?
For organizations with more than 500 employees, a Covid-19 risk assessment record and policy statement must be submitted to their Health and Safety Committees and the Department of Employment and Labour.
These risk assessments should by default indicate the implementation of the hierarchy of controls throughout all lockdown levels, as listed under ‘Annexure B’ of the said Direction and will be strictly enforced by the inspectorate with implications of closure of business and / or criminal charges as ‘making examples of offenders’, according to Minister of Employment & Labour, Mr Thulas Nxesi on Sunday the third of May 2020. He further emphasized that these measures are required to be in place before commencing work. The inspections that have already been conducted have resulted in an average of nine prohibition notices per day.
But I am a one-man band…
All businesses are required to establish and implement Covid-19 risk assessments and to make it available to the respective inspectorate and healthcare workers. This is no different from the required risk assessment record arrangements in Regulation 9 of the Hazardous Biological Agents Regulations.
“The OHSA further requires employers, to ensure, as far as is reasonably practicable, that all persons who may be directly affected by their activities (such as customers, clients or contractors and their workers who enter their workplace or come into contact with their employees) are not exposed to hazards to their health or safety. This obligation also applies to self-employed persons (for example, plumbers or electricians) whose working activities bring them into contact with members of the public.” Clause 6 of the Consolidated COVID-19 Direction on Health and Safety in the Workplace
Risk Resilience
It is important for organisations and employers to understand the necessity of self-regulation which refers to taking absolute responsibility, initiative and going the extra mile to transcend the compliance obligations, as it is key to continuous improvement. It requires the understanding, provision and support of the resources required to ensure a collective effort.
The success of the Return-to-Work plans rely significantly on the effective allocation and execution of roles and responsibilities, including those of the Health and Safety Representatives and Health and Safety Committees.
Additional Covid-19 designations include:
- Covid-19 Compliance Officer
- Compliance Employee for every business premises
- Compliance Official for retail stores and institutions
- Covid-19 Management Representative
Employers are required to educate their employees on the Covid-19 virus, its impacts on society and the role of each person in the fight against the world-wide pandemic. This also means to understand the influence of fake information and the importance of discerning the truth. Employees are required to be conversant and to comply with the relevant Return-to-Work requirements, which will include the prompt reporting of signs and symptoms and making use of allocated communication channels.
Several efforts have been made to provide guidelines and templates for risk assessments from the:
- Department of Employment and Labour
- National Institute of Occupational Health
- National Department of Health
- National Health Laboratory Services and
- National Institute for Communicable Diseases.
These guidelines contain vital information and criteria for the qualitative and quantitative research and evaluation of risks and activities to enable proactive action plans against Covid-19.
How to apply the free Covid-19 Risk Assessment procedure:
Now that we have a clearer picture on the context and objectives, we can discuss the application of the risk assessment procedure to gain the holistic view on its role in a tailored Return-to-Work plan.
The risk assessment procedure guides the risk assessment process to comply to the Covid-19 compliance obligations and guidelines, while allowing for compatible integration with organisational processes, management systems and standards. The goal is to provide evidence-based risk assessments and viable action plans to achieve the organisation-specific objectives in the context of Covid-19 management.
In plain English it means that whether the business standards are aimed at basic legal compliance or at world’s best practices, they all affect the SIC, the economy and the social environment and therefore, the risk assessment should be flexible to be applied to any relevant standard.
The procedure provides a clear process to be followed with emphasis on the planning and preparation steps. Once properly established, any future changes or amendments can be implemented with minimal interruption.
In hazard analysis, especially in the Covid-19 contexts, the specifics are absolutely cardinal in determining the root cause and / or the source of the problem. The more specific the risk assessment allows the information to be, the more certainty we gain and the more likely we are to accurately prevent the existence of the hazard in the first place.
Risk management is about making informed decisions about uncertain factors.
Critical Task Analysis and Life Cycle Analysis
The effective application of a critical task analysis in the movement of the workers and relevant supply chain in all the operations, processes and activities can generate valuable details even before the traditional hazard identification. Though the life cycle approach is generally applied in environmental impact studies, such as resource conservation in cyclical economies, a simplified integration can reveal insights that are usually overlooked regarding the persons involved in the entire life cycle of all the processes and activities.
This will also create the opportunity for employers to provide the statutory support, required for contact tracing.
What is contact tracing?
The National Department of Health have established a covid-19 tracing database, which is used in collaboration with the Department for Communicable Diseases as a reactive model in attempts to trace and contain the spread of the Covid-19 virus (SARS-Cov2). This requires early identification, isolation (whether by provided facilities or self-isolation) and monitoring of persons who have had possible contact with infected persons.
Travelling and Transport
The information regarding travelling employees should be clear as directions and regulations could differ from area to area due to the risk of transmission levels that fluctuate. It should also be considered that the ‘Risk Adjusted Strategy’ could be enforced at differing levels from province to province.
The necessary arrangements for the permits which correspond with ‘Form 2’ and the sworn affidavits as per ‘Form 6’ of ‘Annexure A’ for permitted services in terms of the ‘Disaster Management Act: Alert Level 3 & 4 Regulations’, should be clearly established and maintained in the Return-to-Work plan.
According to the ‘Annexure B’ Sectoral Guidelines from the Consolidated COVID-19 Direction on Health and Safety in the Workplace the ‘Provision of safe transport for employees’ include:
- Personal hygiene
- Social distancing
- Arrangements to minimise exposure associated with commuting
- Cloth masks (if commuter)
- Employer provided transport
- PPE (driver/conductor of employer-provided transport)
Hazards and Risks
The procedure provides a comprehensive list of relevant factors to consider for an accurate hazard identification, including vulnerable persons and mental health factors.
It provides a break-down of the hazards and risks by compelling the risk assessor to identify the source and location of the Covid-19 hazards and to clearly indicate who can be affected, known as the risk population, and the possible route and effect of transmission.
The parameters provided in the guidelines from the National Institute of Occupational Health, namely the likelihood of the exposure and the consequence of the exposure, should suffice in the evaluation of Covid-19 risks. Organizations, however, should integrate these parameters with their own to understand the investment required to be classified as an organisation within the SIC with the desired level 1 risk of transmission and consequently a ‘permitted service’.
The raw risk and residual risk evaluation process allows organisations to be transparent and more precise in their risk control, because of the clarity on the effectiveness of each control.
Covid-19 Risk Control
Some of the compulsory controls and arrangements related to Covid-19 are:
- Implementing social distancing with at least one and a half meters apart
- To place barriers and provide the necessary personal protective equipment, where social distancing is not possible
- The provision and maintenance of at least two cloth masks per employee
- Providing disinfection and sanitising equipment, facilities and safe operating procedures
- Provision of adequate ventilation systems
- Provision of safe transport
- Screening, reporting and isolation arrangements
- Training and communication
- Special work arrangements
Yes, it is a simple task to indicate these action plans in a report but the implementation and management thereof demand far greater efforts and investment.
The business-saving solution!
A tailored Return-to-Work plan will eliminate the guessing and insecurity of the future of your business by providing the essential infrastructure that is required to enable your business to participate in the South African economy.
Remember the goal:
‘Low transmission risk AND severe impact OR high value Source: Department of Co-operative Governance and Traditional Affairs, ‘Risk-Adjusted Strategy’
The risk assessment procedure provides the structure required to set up the action plans that can shift the risk profile to a ‘Low transmission risk’ level. It also provides for the identification of possible opportunities that will allow your business to support the SIC and promote the economy.
The Return-to-Work plan creates the business case for the implementation and management of a ‘Risk Adjusted Strategy’ that is relevant to your organisation and scale. These arrangements to promote the well-being of our social and economical environment should be carefully aligned with ‘business contingency’ objectives and be carried out with co-operative governance.
Contingency plans are imperative for business continuity and due diligence. These are terms that are considered by external stakeholders, including the Government and the Inspectorate. The RtW plan will reflect the organisation’s strategy and movement towards the prevention of infection and transmission and its contribution to the economy.
Sustainability
Businesses in South Africa along with the Government have the opportunity now to save the economy, whilst sharing social responsibility in a sustainable manner.
This global pandemic has caught many unawares and influenced every single person on the planet. The options along with the tools and specifications have now been provided to get out of the situation and to stay out of it. National lockdown allows for a gradual transition between ‘alert levels’, but it is our responsibility to make it happen. By understanding the options given to us and by mastering the rules of engagement, we can take back control over our lives and our freedom.
I firmly believe that true sustainability means that single units only continue to grow by its contribution to the continuous growth of the whole. This means that the single unit supports the whole AND the whole supports every single unit. The beauty of this principle is that if the cycle continues, it will not matter who started the process.
I leave you with one of my favourite quotes and I repeat it often…
“He will win whose army is animated by the same spirit throughout all its ranks” – Sun Tsu
P.S. – The Return-to-Work plans are developed to suit the risk costing budget of the business, which makes the return on investment absolutely manageable and measurable.Book your FREE online consultation, here!
