SK-IHS talk about Covid risk & workplace health protection
Occupational Hygiene is all about protecting the worker from unnecessary exposure while ensuring compliance and in so doing protecting the employer from enforcement action. The principles we in Occupational Hygiene use are centred around recognising the presence of a hazard in the workplace, evaluating that potential for exposure and working on ensuring the controls necessary to achieve the required level of protection are developed, implemented or improved.
The last 12 months have thrown unprecedented changes at all of us in our profession and in particular the team that is SK Industrial Hygiene Services (SK-IHS).
The Scottish First Minister is often quoted as saying that workplaces should only operate :”where it is safe to do so”. So what does that really mean for worker health protection?
SK-IHS is engaged with the Scottish Government by being part of one of their advisory groups on safer workplaces and as such is very clear on what the FM means by “safe to do so” from a workplace perspective. However, our recent experiences are showing this message is not always clear to employers or employees.
Despite having to provide “safe workplaces”, we have still had work visits postponed on occasions because some employers put a blanket ban on site visits while continuing to operate with staff on site. This is not what “where it is safe to do so” means. The pandemic and the associated restrictions imposed on all our lives requires this additional hazard to be factored in to how employers approach longstanding statutory duties around risk management in the workplace. Covid is not a reason to ignore them or postpone elements of the management of them.
Speaking about the current situation, Dougie Collins Principal of SK-IHS stressed the importance of not overlooking all of the pre-existing safety systems companies have in place; “We felt it was worth highlighting the value of integrating Covid risk assessments in to existing systems as these must not compromise existing requirements for monitoring, measurement and assessment as well as compliance driven instruction and training that should instead take place in parallel with any Covid workplace management strategy”. He went on to say, “These historical elements still need to be the priority as compliance is not a list of choice, it is all encompassing. In recent months, proactive and morally responsible employers have followed our roadmap of integrating all of their historical statutory duties in to what is now required for Covid compliance in the workplace. This includes occupational hygienist like myself and the team being one of those key workers on the front line of keeping our economy going by providing a full range of service aimed at worker health protection”.
Examples of site surveys and statutory compliance visits that should continue to proceed because they are an essential part of exposure protection in all workplaces where they apply are below. Therefore any postponement is not justified just because of a blinkered focus just on Covid:
- Exposure monitoring for dust, gases, vapours, fume, etc. to comply with Regulation 10 of COSHH
- Statutory inspection and testing of Local Exhaust Ventilation to comply with COSHH Regulation 9
- Respirator face fit testing to ensure duties under COSHH Regulation 7 and 8 are met as well as duties under Regulations relating to Lead, Asbestos and Radiation are also met.
- Noise survey to ensure exposure is reduced as low as reasonably practicable and the duties under Regulation 5 and other duties in the CONAW Regulations are met
- Asbestos surveys, condition inspections, etc are needed to ensure Regulation. 4 of the Asbestos Regulations are met regarding duty to manage Asbestos Containing Material.
- Information, instruction and training required to allow employees to have sufficient knowledge to carry out their assigned duties must also be current and refreshed in a timely way to avoid human factors impacting negatively on exposure risk.
- Fire Risk Assessments are being compromised in some worksites without site management realising that COVID changes to workplace arrangement may impact on existing compliance including invalidating parts of site Fire Risk Assessments. Site reviews should be conducted to ensure this is not the case in your workplace.
Dougie Collin’s is a Chartered Fellow in Occupational Hygiene and a Chartered Chemist with over 35 years’ experience in this and related fields. He summarised the last 12 months as “probably the most challenging I have ever faced in my career. However, the benefits improving employers understanding of the need to properly assess and manage the working environment is a positive legacy we will all benefit from in the future”.