In this section
Objective: That all employers carry out a COVID-19 risk assessment.
As an employer, you have a legal responsibility to protect workers and others from risk to their health and safety, including from the risks of COVID-19.
COVID-19 is a hazard in the workplace and, as such, should be managed in the same way as other workplace hazards. This includes completing a suitable and sufficient assessment of the risks of COVID-19 in the workplace and identifying control measures to manage that risk.
Failure to carry out a suitable and sufficient risk assessment and put in place sufficient control measures to manage the risk may be considered a breach of health and safety law.
Your risk assessment will help you decide whether you have done everything you need to. There are interactive tools available to support you from the Health and Safety Executive (HSE).
You should also consider the security implications of any decisions and control measures you intend to put in place, as any revisions could present new or altered security risks that may require mitigation.
If you have fewer than 5 workers, or are self-employed, you don’t have to write anything down as part of your risk assessment, but you may decide it would be helpful to.
Employers have a duty to consult on health and safety matters. You can do this by listening and talking to them about the work they do and how you will manage the risks from COVID-19.
This may be through consulting with any recognised trade union health and safety representatives or, if you don’t have any, with a representative chosen by workers.
As an employer, you cannot decide who the representative will be. Employers and workers should always come together to resolve issues. If concerns still cannot be resolved, see below for further steps you can take.
Where the enforcing authority, such as the HSE or your local authority, identifies employers who are not taking action to comply with the relevant public health legislation and guidance to control public health risks, they are empowered to take a range of actions to improve control of workplace risks. Where serious breaches are identified HSE and Local Authorities have a range of things they can do to ensure compliance. These include sending letters, serving improvement notices and prohibition notices and in cases where significant breaches are identified then prosecutions can be brought.
Employers are expected to respond to any advice or notices issued by enforcing authorities rapidly and are required to do so within any timescales imposed by the enforcing authorities. The vast majority of employers are responsible and will join with the UK’s fight against COVID-19 by working with the government and their sector bodies to protect their workers and the public. However, inspectors are carrying out compliance checks nationwide to ensure that employers are taking the necessary steps.
How to raise a concern:
- contact your employee representative
- contact your trade union if you have one
- contact HSE at:
Objective: To reduce risk to the lowest reasonably practicable level by taking preventative measures, in order of priority.
Employers have a duty to reduce workplace risk to the lowest reasonably practicable level by taking preventative measures. Employers must work with any other employers or contractors sharing the workplace so that everybody’s health and safety is protected. In the context of COVID-19 this means protecting the health and safety of your workers and clients by working through these steps in order:
Ensuring both workers and clients who feel unwell stay at home and do not attend the premises. By law, businesses may not require a self-isolating worker to come into work.
In every workplace, increasing the frequency of handwashing and surface cleaning.
Businesses and workplaces should make every reasonable effort to ensure their workers can work safely. This includes consideration of reasonable adjustments for workers or customers with disabilities, including hidden disabilities that are not immediately obvious. Anyone who can work from home should do so. Anyone else who cannot work from home should go to their place of work, if COVID-secure guidelines are followed closely. When in the workplace, everyone should make every reasonable effort to comply with the social distancing guidelines set out by the government (2m, or 1m+ with risk mitigation where 2m is not viable).
Fresh air helps to dilute the virus in occupied spaces so provide adequate ventilation through doors, windows and vents, by mechanical ventilation using fans and ducts, or a combination of both.
Where the social distancing guidelines cannot be followed in full, in relation to a particular activity, businesses should consider whether that activity can be redesigned to maintain a 2m distance or 1m+ with risk mitigations.
Further mitigating actions include:
– further increasing the frequency of hand washing and surface cleaning
– keeping the activity time involved as short as possible
– using screens or barriers to separate clients from one another; as everyone working in close proximity for an extended period of time should wear a visor and a Type II face mask, screens will not be necessary between the practitioner and the client.
– working from the back (behind the client) or from the side, regularly circling the client.
– unless crucial for the treatment, avoiding skin-to-skin contact and using gloves where possible
– using a consistent pairing system, defined as fixing which workers work together, if workers have to be in close proximity (defined as being within arm’s-length of someone else for a sustained period of time)
Where the social distancing guidelines cannot be followed in full, even through redesigning a particular activity, businesses should consider whether that activity needs to continue for the business to operate, and if so, take all the mitigating actions possible to reduce the risk of transmission between their staff.
Clearly, when providing close contact services, it often may not be possible to maintain social distancing guidelines (2m, or 1m+ apart with risk mitigation). As a result, personal protective equipment in the form of a visor and a Type II face mask should be used to mitigate the risk. Further details on which can be found in section 6.
Remind customers and staff to wear face coverings where they are required, for example, through use of signage or verbal reminders.
In your assessment you should have particular regard to whether the people doing the work are especially vulnerable to COVID-19.
If your building has been unoccupied for a period during any lockdowns, consider legionella risk and HSE advice.
The recommendations in the rest of this document are ones you must consider as you go through this process. You could also consider any advice that has been produced specifically for your sector, for example by trades associations.
If you are currently operating, you will already have carried out an assessment of the risks posed by COVID-19 in your workplace. You should use this document to identify any further improvements you should make. You must review the measures you have put in place to make sure they are working. You should also review them if they may no longer be effective or if there are changes in the workplace that could lead to new risks.
You must share the results of your risk assessment with your workforce. If possible, you should consider publishing the results on your website (and we would expect all employers with over 50 workers to do so). We would expect all businesses to demonstrate to their workers and clients that they have properly assessed their risk and taken appropriate measures to mitigate this. You should do this by displaying a notification in a prominent place in your business and on your website, if you have one.
Below you will find a notice you should sign and display, which can also be provided as cards, stickers or similar, to show you have followed this guidance.