Have you been closed down for a while? If so, what do you need to think about to safely re-open.
Some of our businesses have been closed for some time now, it is important to remember that the building, plant and equipment is still in need of maintenance and inspection. Additionally staff need your consideration.
As we move towards re-opening you will need to consider your way forward.
· Building Safety;
· Plant and Equipment Safety;
· Management of Safety; and
· Managing Wellbeing.
What will you need to do:
The first thing you need to do is carry out a risk assessment to identify what you will need to do to make return as safe as you can, areas to consider are:
• how employees and contractors can safely enter a building that may have been closed for some time
• how to safely restart equipment and machinery that has out been of use for a period of time
• how social distancing will be maintained
• the provision of welfare facilities (hand washing facilities etc..)
• cleaning operations (in the context of Covid-19)
• whether further training is required both for Covid-19 and for operations that may have become unfamiliar to staff whilst away
You will need to make sure that the building is ready for you and your staff to come back into, One important area you will need to consider is to make sure your fire systems are working:
• a full test of the fire detection and alarm system (using different call points across the site and ensuring any call receiving centre is working)
• a complete discharge test of the emergency lighting system across the site
• a visual inspection of all fire extinguishers to ensure that they are correctly located, not discharged or obviously damaged and that annual servicing is within date
• checking that fire escape routes are clear of any obstructions
• checking that final fire escape doors are unlocked and operational
• checking the operation of internal fire doors to ensure that they close properly and are undamaged
• checking that any automatic fire dampers, smoke venting and smoke extraction systems are operational.
You will also need to ensure that your fire risk assessment is still relevant. If things have changed or you are past the review date you may need to carry out another assessment. Healthandfiresafety.com can assist you with your fire risk assessment and all other fire safety needs visit our website for details.
Water Management – Control of Legionella Bacteria
One of the major causes of Legionella outbreaks is standing water even if it is only standing for a few weeks so it will be essential that you have your Legionella risk assessment in place and have a suitable management plan (It is a requirement to have a Legionella risk assessment in place and depending on your circumstances you may need a management plan as advised by your water management contractor).
· Firstly, the system should be thoroughly cleaned, flushed and disinfected, you may need to seek further advice from a specialist water treatment company.
· You should also conduct temperature checks on designated outlets, e.g. sentinel taps (as outlined in the written scheme of your legionella management plan) to ensure that the system is performing as expected to prevent the build up of Legionella bacteria.
· In addition control measures need to be established to protect those undertaking initial flushing, due to the risk of them being exposed to airborne contaminates.
· This is especially true in relation to flushing showers (and arrangements to contain the water from shower heads and route it directly to a drain, away from the person undertaking the flushing)
· Finally, it should be remembered that where a wet cooling tower or evaporative condenser has been taken out of use, there is a requirement under the Notification of Cooling Towers and Evaporative Condensers Regulations 1992 to notify the local authority that it is being returned to service.
Asbestos Containing Materials (ACMs)
If your building was constructed before 2000 you are required by law to have an asbestos survey carried out to identify any ACM and provide a management plan.
If there are ACM on your property it is recommended that you complete a thorough visual inspection of all prior to reoccupation to confirm that they remain undamaged. Where any damage to ACMs is observed, the area should be isolated immediately and advice sought from a specialist licensed asbestos management company
Deep Cleaning for Reoccupation
If your building has not been occupied, it is highly unlikely that the COVID infection will be of any risk to your staff or visitors when you first re-occupy although staff may well feel more peace of mind if some form of enhanced cleaning is carried out. (Healthandfiresafety.com offer a fogging and misting service before re-opening that may well give your staff the peace of mind that you want. Please contact us for advice)
However, you will need to consider your response to any positive case after re-opening. This response will require you to carry out enhanced cleaning in areas occupied by any positive case which could result in lost time and potential loss of confidence in your business.
Plant and Equipment Safety
Restarting Plant and Equipment
You must establish a clear plan for restarting your equipment that has been taken out of service or just remained unused during lockdown. This is to ensure the safety of those who are carrying out the maintenance as well as protecting the equipment from damage
The restart process may require:
· electrical and mechanical isolations to be reconnected,
· fluid levels replaced,
· plant and equipment to be powered up in a specific sequence or order.
You will need to base your plans around any manufacturers or other guidance and ensure competent persons carry it out. In addition, once re-starting has happened you will need to continue monitoring the equipment to ensure it performs as expected.
Remember also to test any emergency stops and interlocks.
You will need to record all of this.
The HSE have given some leeway with regard to inspections but before you re-open your premises ‘the law for Lifting Operations and Lifting Equipment Regulations (LOLER) and Pressure Systems Safety Regulations (PSSR)’ remain in place. As such, you must ensure that:
· statutory inspections on lifting equipment,
· pressure systems,
· fixed electrical systems,
· gas appliances etc. are ‘in date’ prior to the reoccupation of buildings.
Employers must also consider whether equipment, which has not been used for an extended period of time needs a statutory inspection or servicing even if one is not due; e.g. where personal lifting equipment has been left in a condition which may have compromised its structural integrity or a lift has not been used for a protracted period of time
Training and Supervision
When you have your plant and equipment into full use, you must ensure that your employees have retained adequate knowledge to use it safely. It might be a good idea to carry out some refresher training, tool box talks or other training. This is particularly important to employees who only had limited experience using equipment prior to the lockdown.
You must also review the status of any planned periodic refresher training which may have been missed during the lockdown, e.g. forklift truck training.
Management of Health and Safety
Managing the Risks of Covid-19 Infection
The Government have given plenty of advice surrounding managing infections in your business however, I have written a separate blog with advice which you can find here.
Management of Fire and First Aid
You will need to develop and maintain a suitable and sufficient fire risk assessment, outlining how fire safety will be managed on your site.
You must therefore review your fire risk assessment and your fire management procedures contained within before returning to the building.
Remember that the review not only needs to consider any changes to fire safety systems and equipment but also issues such as providing sufficient fire wardens.
Consider the suitability of Personal Emergency Evacuation Plans (PEEPS)
You need to make an assessment of the level of first aid coverage you need We have produced a blog at Healthandfiresafety.com to assist you with that. You must also review the levels of first aid equipment that you have on site and ensure that these are still adequate to minimise risk to First Aiders in a Covid-19 context. In particular, the purchase of
· resuscitation face shields,
· disposable gloves and
One area that is definitely under-considered is the wellbeing of staff during this time. Staff are struggling with the effects of being in lockdown whist nervous at the prospect of returning to workplace.
Although it is not necessarily a legal requirement, it is certainly a moral requirement that you discuss and support your staff with any wellbeing issues.
Most important is to consult them about the changes that you are putting in to protect them, this is a legal requirement but it will give them confidence about their return to the workplace.
We are helping where we can
The biggest difficulty for employers is that people have widely differing views about how seriously to take this pandemic, from social distancing, to wearing a face covering. From Government conspiracies to genuine fears for themselves and their families. A recent positive case at a local school created very passionate responses from people on social media, with some parents immediately pulling their children out, demanding the whole school be deep cleaned. Do you think that is a proportionate cleaning response?
This makes putting the right controls in place a nightmare for employers but they have to put a suitable and sufficient management system in place.
We recently helped a local engineering company pose all of these questions and put a Covid risk assessment in place for his buildings and his staff and we talked through all these important questions and many more. From social distancing floor markings, to posters and other information. From cleaning touch points on machines, to carrying out deep cleaning and fogging solutions in the event of a positive case.
If you have any questions, don't hesitate to get in touch.