As part of a series of guidelines on how to work safely during the Covid-19 pandemic, the UK government has produced specific "Covid-secure" guidance for people whose jobs involve visiting other people's homes.
Unlike the other Covid-secure guidelines, which apply to designated workplaces, the homes guidelines apply much more widely to anyone performing work in other people's homes including employees, self-employed individuals and agency workers.
This includes "home workers", (not to be confused with people who are working from home), such as repair service providers, fitters, meter readers, plumbers, cleaners, cooks, surveyors and delivery drivers.
The guidelines do not apply to nannies, who spend all their time in one household, or their employers, although there is no equivalent guidance for visiting nannies or childminders, even though these groups have been encouraged to return to work under the government's Covid-19 Recovery Strategy.
The homes guidelines are not legally binding at this stage, however employers and self-employed workers are encouraged to follow the recommendations to minimise the risk of enforcement action from the Health and Safety Executive (HSE).
The guidelines are underpinned by a number of key principles, which home service providers should consider:
1. Covid-19 risk assessments
In addition to risk assessments already performed by businesses and individuals whose jobs involve them visiting other people's homes, a specific Covid-19 risk assessment will need to be undertaken and ideally completed before home visits resume.
For businesses that have been operating throughout lockdown, assessments should be conducted without further delay.
The employer must make sure the risk assessment addresses the particular risks represented by Covid-19 and that suitable control measures are implemented to reduce workplace risk to the lowest reasonably practicable level.
Employers should consult with their workers and a health and safety representative selected by a recognised trade union, or a representative chosen by workers, although there is no further guidance on what to do if risk assessments cannot be agreed.
Once the risk assessment has been prepared and agreed, the guidelines stipulate that employers must share the results with their workforce and are encouraged to publish the results on the company's website. This becomes an expectation for businesses that employ more than 50 workers.
2. Working from home
Government guidance remains that people should work from home, where they can, and employers should make every reasonable effort to enable staff to do this.
Realistically, however, the majority of home-based service providers will not be able to work from home and therefore every effort should be made to comply with social distancing guidelines when workers visit other people's homes.
3. Know your workforce and customers
Employers should identify clinically vulnerable individuals (CVIs) and clinically extremely vulnerable individuals (CEVIs), both in their workforce and their customer base.
CEVIs have been advised not to work outside their own home and employers should abide by this. CVIs are at high risk of severe illness and, if CVIs cannot work from home, should be offered the option of the safest available on site-roles, enabling them to stay two metres away from others.
If they have to spend time within two metres of others, careful assessment is needed as to whether this involves an acceptable level of risk, although it is unclear what this means in practice and in reality will be a subjective assessment.
No work should be carried out in a household that is isolating because one or more family members has symptoms, or where an individual has been advised to shield, for example, because they are a CEVI, unless it is to remedy a direct risk to the safety of the household.
When working in a household where someone is a CVI but has not been asked to shield, such as someone aged 70 or over, prior arrangements should be made with the CVI to avoid face-to-face contact and the worker should be particularly strict about hygiene.
4. Social distancing
The default position is that any activity undertaken in other people's homes must be undertaken at a social distance (i.e., two metres away from other people).
Businesses should discuss working environments and practices with households and clients in advance of visits, to confirm how the work will be carried out.
Where social distancing cannot be followed in full for a particular activity, businesses should consider whether that activity needs to continue while the risk of infection remains high, and if so, take all mitigating actions possible to reduce the risk of transmission between staff members and between workers and clients.
Mitigating actions may include:
- Planning for the minimum number of people needed on site to operate safely and effectively, for example consider using a single worker where safe to do so and for that worker to use their own transport (where insurance permits);
- If workers are required to travel together, journeys should be with the same individuals, the number of people travelling per vehicle should be limited and vehicles should be regularly cleaned;
- Keeping the activity time as short as possible;
- Using screens or barriers to separate people from each other, where practical;
- Using back-to-back or side-to-side working (rather than face-to-face) if barriers/distancing measures are not possible;
- Reducing the number of people each person has contact with by using fixed teams or partnering to prevent transmission among a large group of people;
- Increasing the frequency of hand washing and surface cleaning, particularly on arrival and departure;
- Maintaining good ventilation throughout the house and asking the household to open all internal doors to avoid contact with door handles.
Work areas in the home should be kept clean to prevent transmission by touching contaminated surfaces. This should be incorporated into the Covid-19 risk assessment.
There should also be carefully planned waste disposal procedures in place and workers should be encouraged to wash or sanitise their hands regularly and thoroughly.
For home deliveries, the government recommends following standard social distancing principles and for deliverers to work alone where possible.
Contact with recipients should be minimised, for example by calling to inform a household that a delivery is imminent, rather than ringing the doorbell, and advising recipients not to approach deliverers, and by taking payment in advance or via contactless payment.
Once a business has undertaken these measures, they can download and display a notice to say that they have complied with government guidance.
This can be displayed at company premises or in the windows of company vehicles for home visitors.
It is not yet known whether the HSE will use these notices as a precursor for investigations/inquiries into health and safety standards, but the focus is likely to be initially on businesses who do not display this notice.
Other people's homes may present unique challenges for businesses trying to adopt appropriate control measures to safeguard the health and safety of their workers and others affected by their business.
The most proactive step that home-based service businesses can take is to plan ahead with customers to identify how the work can be performed safely, at a social distance and away from CVIs and CEVIs.
If you have any health and safety-related questions or concerns about your business in light of the coronavirus outbreak, Fieldfisher's health and safety team will be happy to discuss your specific circumstances with you.
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