The UK government has produced "Covid-secure" guidelines for laboratories and research facilities, which apply widely to indoor research environments including:
- Engineering centres;
- Clean rooms;
- Prototyping centres;
- Wet labs;
- Wind tunnels;
- Computer labs;
- Material development labs; and
- Specialist testing rooms.
The guidelines recognise that such facilities require onsite collaboration between people, often in close proximity and involving frequent use of shared apparatus, not all of which can be washed down. They also concede that flexibility in terms of shifts and floor layouts may be limited.
Although the guidelines are not legally binding at this stage, employers are encouraged to follow their recommendations to minimise the risk of enforcement action by the Health and Safety Executive (HSE).
Businesses operating within laboratory and research environments should therefore consider the following key principles:
1. Covid-19 risk assessments
In addition to risk assessments already deployed in laboratories and research facilities concerning their specific work activities, a Covid-19 risk assessment will need to be undertaken and should be completed before facilities open.
For those that are already open in some capacity, these assessments should be conducted without further delay.
Employers must make sure the assessment addresses the risks of Covid-19 and suitable control measures are implemented to reduce workplace risk to the lowest reasonably practicable level.
Employers should consult 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.
The guidelines make clear that the HSE will seek to take enforcement action against labs and research facilities that do not have robust risk assessments in place.
Once the risk assessment has been prepared and agreed, the guidelines stipulate that employers must share the results with their workforce and encourage employers to publish the results on the company's website. This becomes an expectation for business that employ more than 50 workers.
2. Working from home and knowing your work-force
Government guidance remains that people should work from home where they can, and employers should make every reasonable effort to enable laboratory and research staff to work from home where practical (for further advice on safeguarding the health and safety of remote workers, please see our previous guidance).
However, the majority of workers whose jobs are lab or research facility-based will not be able to work from home all the time and every effort should be made to comply with social distancing guidelines (see below) when staff are on site.
Employers should identify clinically vulnerable individuals (CVIs) and clinically extremely vulnerable individuals (CEVIs). CEVIs have been advised not to work outside the home and employers should abide by this.
CVIs are at higher risk of severe illness and if CVIs cannot work from home, they 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.
3. Social distancing
Where workers are required on site, activities must be undertaken at a social distance (i.e., two metres away from other people).
However, the guidelines for labs and research facilities recognise this may be particularly difficult in these environments, which are designed for close-proximity collaboration.
Fixed equipment may make it impossible to change layouts to create more space. Therefore, businesses that operate these facilities will need to consider whether that activity needs to continue for the business to operate, and if so, take all the mitigating actions possible to reduce the risk of transmission between staff.
Mitigating factors may include:
- Planning for the minimum number of people needed on site to operate safely and effectively;
- Keeping the activity time as short as possible;
- Staggering arrival, departure and break times to reduce crowding into, out of, or around common areas;
- Introducing one-way flow through buildings and long corridors and providing floor markings and signage to workers to remind them to remain socially distant;
- Using screens or barriers to separate people;
- 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 large groups;
- Limiting passengers in corporate vehicles or vehicles used for onsite travel and leaving seats empty to facilitate social distancing;
- Reducing maximum occupancy for lifts, providing hand sanitiser for the operation of lifts and encouraging the use of stairs;
- Using remote working tools to avoid in person meetings and, if contact meetings are required, maintaining social distance;
- Requesting staff change into work clothing on site using appropriate changing areas and observing social distancing and hygiene guidelines;
- Washing lab clothing and equipment such as goggles on site rather than allowing individuals to wash clothing/equipment at home;
- Providing packaged meals or similar to avoid opening staff canteens and reconfiguring seating/tables to maintain spacing;
- Providing training, guidance and signage on Covid-19-related safety measures.
Before labs and research facilities reopen, employers should ensure these sites are clean and ready to restart. This should be incorporated into the Covid-19 risk assessment.
Laboratories and research facilities should assess whether the workplace is sufficiently ventilated and, if they have concerns, they will need to think about improving ventilation and airflow into the workplace and potentially seek advice from their heating, ventilation and air conditioning (HVAC) engineers or advisers.
They should also consider whether they have appropriate air-handling and filtering systems installed for maintaining areas with high-risk of exposure to airborne particles.
All areas of the facilities should be regularly cleaned using the usual cleaning products. Particular attention should be paid to regularly touched surfaces such as door handles, testing surfaces and shared equipment.
There should be increased handwashing and hand sanitisation facilities made available to all occupants and signage about increased hygiene and good handwashing techniques.
Once a lab or research facility has undertaken these measures, they can download and display a notice to say that they have complied with government guidance.
It is not yet known whether the HSE will use these notices as a precursor for investigations/inquiries into health and safety standards in a workplace, but the focus is likely to be initially on businesses who do not display this notice.
Due to the nature of these workplaces, labs and research facilities may struggle to implement some of the control measures recommended by government.
It remains to be seen whether the HSE and the government will allow businesses operating in these environments more flexibility, but for the time being, labs and research facilities should adopt a conservative approach to risk and implement as many of the recommendations as is reasonably practicable.
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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