April 23, 2020
Employers: H&S Considerations as Lockdown Restrictions Evolve

Going back a few months, perhaps the biggest threat people associated with a virus, related to our IT infrastructure and data security. However, 2020 has provided governments, medics, business, safety professionals and the general public with an unprecedented challenge.
The actions the government took in March and April of 2020 have seen many working from home or furloughed on 80% salary (or £2,500). With others continuing to work in factories, workshops, care settings, construction sites and other essential workplaces or environments, where work could continue safely (following Public Heath Guidelines).
As we explore the current restrictions and guidelines and try to second guess the government’s next steps, there are numerous questions; more than can be asked or answered in the few hundred words we are publishing here.
In previous posts we’ve looked at securing the safety and health of those now finding themselves at home and those continuing to work in existing workplaces. Here we’ll discuss a few possible scenarios for a small relaxation of the lockdown, mainly to aid readers thinking about the coming weeks and with no real insight to the government plans.
We’re also past the initial 3-week furlough period, for any employees furloughed at the start of the scheme. Employers may be thinking about bringing employees back into the workplace to start or increase production or cover staff shortages.
Social Distancing to Continue
One thing we can be sure of is the next Government review in early May will not see any major lifting of restrictions. Social Distancing will continue to be a primary control in the prevention of the virus spreading across the general population and within any workplace that’s currently or decides to return to working from their premises. Less clear is whether masks will be required to support social distancing as restrictions are lifted.
Pubs, clubs, theatres and other places which encourage socialising in larger numbers at close proximity, are unlikely to be allowed to re-open. Even when they do so, they should expect to have to implement strict controls to limit customer numbers and person-to-person contact. Similarly, hairdressers, beauty therapists, tattooists – they’ll have longer to wait until the government allows them to open and there are likely to be new guidelines to follow when they do.
Food Providers
Where a food business has moved from seated service to takeaway delivery, the Food Standards Agency are strongly suggesting these businesses review their Hazard Analysis and Critical Control Points to ensure the food is delivered to the end consumer in a safe condition.
Back to the Workplace?
The lifting of restrictions is also unlikely to remove the requirement for homeworking where it’s possible. So, many temporary homeworkers will be looking to continue doing so throughout May and maybe into June.
Where employers are bringing employees off furlough and back into the workplace, this may impact any social distancing controls already in place, as the number of employees working will likely increase. Employers may need to think about how this impacts the current restrictions in place. One key consideration is how staff can stay two metres apart in areas with restricted floor space such as toilets, kitchens and lifts. Also, in kitchens – are mugs and kettles a potential point of contamination, along with other contact surfaces such as door handles?
Further, if your business is extending operating hours to spread the workforce out and thin the numbers on site to facilitate social distancing, how does this impact on First Aid and Fire Marshall provisions?
Personal Protective Equipment
If you use PPE as a last resort to protect employees from dust exposures, are you able to secure supplies given the NHS requirement for the same PPE you will be needing? Can you reduce exposure by other means, negating the need to use PPE? In some industries, the HSE are providing guidance on extended use of disposable PPE to help ease the pressure. For example, in the world of Asbestos Removal, the HSE have set procedures to allow for the repeated use of disposable overalls as long as strict rules are followed.
Current Guidance
There is extensive guidance on the government website here.
The key elements are:
- Staff awareness of symptoms and the requirements to self- isolate for 7 / 14 days if there are symptoms within their household
- Encouraging staff to follow the above rules
- Ensuring managers can identify symptoms and deal with staff who attend work exhibiting the symptoms
- Provision of and encouraging correct use of hand washing facilities
- Social Distancing – 2 metres or 6 foot
- Minimising face-to-face contact
- Staggered shift patterns
- Provision of information to staff on general and business specific procedures
HSE Approach
Currently the HSE are using the Public Health England Guidance as their benchmark for compliance. The HSE have stated they will take enforcement actions where employers are not following the PHE Guidance to protect employees. However, they do not believe businesses should be forced to close where they can continue to operate safely and inline with the above guidance.
Moorepay Support
You may be planning either to return to a vacant property, to restart work, or introduce more staff back into an operation you scaled back for a few weeks. If so, there are a lot of COVID-19 and none COVID-19 related Safety and Health questions to be considered. Our Team of Health and Safety Professionals are on hand to discuss likely scenarios and help with assessing risk and planning for a safe and healthy work environment.
NOTE: Bringing staff back from Furlough may require support from the HR Services team in Moorepay to avoid any future potential problems relating to the procedure followed.