Ensure your organisation – and your suppliers – are Covid-19 safe before the inspectors descend, says Oliver Williams, regional health & safety manager at Ellis Whittam and manufacturing sector specialist
Back in April 2020, the UK’s Health and Safety Executive (HSE) reminded employees how to report genuine concerns if they believed their workplaces to have a lack of appropriate measures to protect staff from contracting Covid-19. Along with local authorities, the HSE began visiting workplaces to check for Covid-compliance. According to the HSE, almost 4,000 businesses were subjected to spot checks between 9 March and 29 June 2020. These were performed via a mixture of site visits and over-the-phone checks supported by a request for evidence including documents, photos and in some instances video footage.
With businesses keen to reopen once lockdown restrictions are eased, do not be tempted to rest on your laurels – remain prepared for a compliance inspection. For those in procurement and supply chain management the challenge is two-fold: is my company prepared if we were to be inspected, and are my suppliers prepared, so as not to present any risk to business continuity? Are they too working ethically and within the law, in line with the ongoing challenges of Covid-19?
5 tips on how to prepare for a Covid-19 inspection by the Health and Safety Executive
1. Make sure you’re taking all reasonable precautions
Even if your business isn’t currently on the HSE’s radar, there is every chance you could be visited soon. You must prepare for that possibility by ensuring all ‘reasonably practicable’ measures are in place. It will not be possible to eliminate the risk of Covid-19 completely, and that’s not what the law requires; it’s about taking sensible measures that are proportionate in terms of the time, energy and cost involved in implementing them, aligned to published guidance (see www.hse.gov.uk/coronavirus/working-safely). You should apply the hierarchy of risk controls to make sure that the most effective measures are considered first.
2. Understand what could prompt a complaint – and work with staff, not against them
Employees can submit an anonymous complaint to the HSE if they’re concerned risk isn’t being properly managed. All complaints will be considered by the regulator, with some triggering a spot check. Issues that might lead to a complaint include not adhering to social distancing measures or providing adequate PPE, not producing a Covid-19 risk assessment and making this available to staff or providing training to employees on your risk control measures, and allowing symptomatic staff to remain in work. It’s important to deal with staff who raise concerns responsibly, as safety is a very sensitive issue in the Covid-19 era. These are critical opportunities to refine your controls so that your employees trust their employer and your business is less exposed. Work with your staff to find solutions and strengthen your team dynamic – this is far better than facing a potential whistleblowing situation.
3. Organise your documents
When it comes to risk management, being able to demonstrate compliance is essential. It’s certainly not a case of producing lengthy paperwork for the sake of it, but your plans and associated action should be documented. Not only will this form the basis of your communication with internal and external parties, it is highly likely you’ll be asked to show particular documents if you are inspected, so make sure you have:
- A Covid-19 health and safety policy, or a separate section within your existing policy that deals with Covid-19,
- A Covid-19 risk assessment. If you employ five or more employees, it is a legal requirement to keep a written record of significant findings
- Training records, and
- An emergency action plan.
4. Know your stuff
The HSE inspector or local authority inspector will ask a series of questions to determine whether you’re managing risk properly. You must be able to answer these types of questions with confidence:
- Did you conduct a risk assessment before opening?
- Was the risk assessment documented?
- How are you ensuring the specific controls mentioned in your risk assessment are being adhered to and remain effective?
- Has the risk assessment been kept up to date?
- What is your policy surrounding workers who may be displaying symptoms of coronavirus?
- Who are your competent person/s?
5. Don’t neglect your other health and safety responsibilities
While minds are currently focused on addressing the risk posed by Covid-19, remember to maintain your other responsibilities, including fire safety, lifting equipment, and transport of goods.
If any of these points raise concern, now is the time to close the gaps. By understanding whether your own company is prepared, you will be well equipped to ask such questions of your suppliers. If their responses do not give you full confidence, you must move quickly to ensure they act and do not pose a risk to your supply.