Since it was announced that restaurants, bars, pubs and cafes in England can emerge from their three-month hibernation on 4 July, employers have been contemplating what proportionate yet effective COVID-19 controls can be introduced to keep customers and staff safe.
Those given the green-light must open in a “COVID-secure” way – but what does it take to keep people safe and meet your legal duties in the inherently social hospitality sector?
The process to control the risks presented is no different to any other hazard you may encounter in the workplace and can be broken down into 5 stages:
Step 1: Identify the hazard and think about areas and activities in the workplace where there may be a risk of transmission. Bars, lounges, dining areas, kitchens, toilets, cellars and outside areas should be considered.
Step 2: Decide who may be harmed and how? This includes staff, customers and contractors.
Step 3: Assess the risks and take action. For each hazardous situation and activity identified, consider how likely it is that transmission may occur and the severity of the harm. The severity of COVID-19 will be high in all cases given the potential health consequences and so your focus should be on reducing the likelihood of becoming infected by introducing effective control measures. It will not be possible to eliminate the risk of COVID-19 completely and that is not what the law requires. Remember it’s about being able to demonstrate that you have taken all reasonably practicable measures.
Step 4: Record the significant findings. If you employ more than five members of staff, it is a legal requirement to make a written record of your risk assessment but if you have fewer than five employees you are encouraged to do so as it can help to demonstrate compliance and can be shared with staff. The government has also encouraged businesses employing over 50 people to publish their risk assessment online.
Step 5: Review the risk assessment regularly and whenever there is a significant change to your business practices or personnel, new or updated government guidance, or if there is reason to believe your controls are no longer effective.
Deciding on practical controls
There is plenty of guidance available to support the sector, but it’s important that you introduce control measures using a systematic approach by following the ‘Hierarchy of Controls’. This ranks the types of controls from most effective (elimination) to least effective (PPE). You must exhaust the control measures required at the top levels because they are not reasonably practicable before proceeding to the next level. Let’s look at some examples:
Elimination: Does the activity need to be undertaken or a particular area occupied? If not, remove it from your workplace. For example table service to avoid congestion at the bar, card only payment, removing touchpad devices.
Substitution: Can the hazardous activity be replaced with an equivalent that is intrinsically safer? For example, pre-booking to control the amount of customers, replacing self-service of food, cutlery or condiments with these being brought to the table with the food.
Engineering Controls: Can people be separated from the hazard, through guarding or isolation? For example, installing screens in front of payment points and counters, traffic light system for toilets requiring one in one out.
Administrative Controls: Can safe working procedures be developed to minimise exposure? For example, signs, notices, instructions, floor markings. Having staff work in fixed terms or facing away from each other, providing adequate soap and hand sanitiser stations.
PPE: This should only be used as a final resort when all other options have been exhausted.
Remember, this is a collaborative effort, so involve employees in the risk assessment process. Not only will their insight help to decide on and implement adjustments, but their collective buy-in will ensure plans are properly executed and enable you to get back on track swiftly and safely.
There’s no doubt the world of hospitality is going to look entirely different as we emerge from lockdown but it’s important to stay alert and follow government advice to keep people safe, meet your legal duties and limit your liabilities.
Nick Wilson is Director of Health & Safety Services at Ellis Whittam and a former HSE Inspector. For free industry-specific risk assessment templates and further guidance documents, visit Ellis Whittam’s ‘Back to Business Hub’ at https://elliswhittam.com/covid-19/register/