As everyone is aware, the Government guidelines are wherever possible for people to work at home while we remain on “lock down” during the COVID-19 outbreak. However, the construction industry plays a vital role in our nation’s wellbeing and will be a pivotal cog in the wheel in assisting with the country’s economic recovery over the coming months. As such, construction workers are still permitted to go to work as usual including where this involves travelling to and from the construction site. To assist in ensuring that the health and well-being of our construction workers is preserved as far as possible, the Construction Leadership Council working in conjunction with the industry has published Site Operating Procedures (“SOPs”). In this article, I explore the SOPs and set out some of the main important procedures.
Notwithstanding the issue of the SOPs it is important to remember that the health and safety requirements of any construction activity must not be compromised. If an activity therefore cannot be undertaken safely it should not take place.
- has a high temperature of a new persistent cough;
- is a vulnerable person (by virtue of their age, underlying health condition, clinical condition or pregnancy); or
- is living with someone in self isolation and/or with a vulnerable person
should not come to the site.
If a worker develops a high temperature or new persistent cough whilst at work, they should avoid touching anything, go home immediately and follow the self isolation guidelines.
Travel to site
Wherever possible, workers should travel to sites using their own transport.
Sites need to consider parking arrangements for additional cars and cycles.
Site Access Points
Hand cleaning facilities should be provided at all site entrances and exits. All workers should be required to wash their hands upon entry and exit of sites.
All non-essential visitors should be stopped.
Consideration should be given to staggered start and finish time to avoid congestion and ensure social distancing is maintained. Where there is a queue for entry or exit, social distancing should be adopted.
Additional access points may need to be created to assist with social distancing measures.
All entry systems which require skin contact (e.g. fingerprint scanners) should be disabled and/or removed.
The number of workers using toilet facilities at any one time should be restricted to ensure social distancing can be exercised.
All workers should be required to wash their hands upon entry and exit.
Cleaning regimes for toilet facilities should be enhanced, particularly as regards door handles, lock and the toilet flush. This should also be applied to the site generally, particularly communal areas and especially during peak periods of use.
Portable toilets should be avoided wherever possible.
Suitable and sufficient rubbish bins for hand towels should be provided with regular removal and disposal. Sufficient rubbish bins and the same procedure should also be undertaken in other communal areas of sites.
Canteen and eating arrangements
Workers should be required to stay on site once entered and not use local shops.
Dedicated eating areas should be introduced to limit food waste and contamination.
Canteens will not be able to operate as normal. If catering is provided on site, it should be pre-prepared and wrapped food only.
Crockery, eating utensils, cups etc should not be used.
Drinking water should be provided but enhanced cleaning procedures for the tap mechanism should be introduced.
Whilst it is a requirement for sites to provide workers with facilities to heat food and make hot drinks where it is not possible to introduce a process to ensure equipment (e.g. kettles, microwaves etc) is cleaned between use, these must be removed from sites.
Break times should be staggered to reduce congestion and contact at all times.
Workers should be required to wash their hands upon entering and leaving food areas. Washing facilities should be provided for this purpose.
Social distancing should be adhered to at all times and all workers should sit at least two metres apart from each other.
Payment for food should be by way of contactless card wherever possible.
All rubbish should be put straight in the bin and regular removal and disposal procedures should be in place.
All tables should be cleaned after each use and the entire area at the end of each break and shift including all chairs, door handles, vending machines and payment devices.
Changing facilities, showers and drying room
Staggered start and finish times should be introduced to avoid congestion and contact.
Enhanced cleaning procedures of all facilities should be introduced throughout the day and at the end of each day.
Social distancing should be adhered to at all times so if possible consider extending the number or size of facilities at sites.
Provide suitable and sufficient rubbish bins and ensure regular removal and disposal.
Non-essential physical work that requires close contact between workers should not be carried out.
Work requiring skin to skin contact should not be carried out.
All other work should be planned to minimise contact between workers.
Should personal protective equipment (“PPE”) be provided for workers?
Where supplied, re-usable PPE should be thoroughly cleaned after each use and not shared between workers. Single PPE should be disposed of so that it cannot be re-used.
Stairs should be used in preference to lifts or hoists. Where lifts or hoists must be used lower their capacity to reduce congestion and contact at all times and regularly clean touch points, doors, buttons etc.
Increase ventilation in enclosed spaces.
Regularly clean the inside of vehicle cabs between use by different operators.
Whilst the majority of the SOPs involve around enhancement of the Government guidelines regarding social distancing and personal hygiene, particularly as regards hand washing, sites will need to ensure that firstly they have the facilities in place and secondly, put in place procedures to ensure that workers adhere to the procedures. Additional cleaning of sites is also an essential element of ensuring compliance with the SOPs.
Sites need to ensure that they have measures in place to protect their workforce and minimise the risk of spreading the disease. Adopting these procedures and ensuring that all workers do likewise will mean that sites should be able to continue to operate during COVID-19. However, a word of warning by way of final conclusion, if sites are not consistently implementing the SOPs it may be required to close down, so sites not adopting and implementing the SOPs do so at their peril!
Consistent with our policy when giving comment and advice on a non-specific basis, we cannot assume legal responsibility for the accuracy of any particular statement. In the case of specific problems we recommend that professional advice be sought.