Some three and a half months after the release of version 5, and with local lockdowns coming into force across the UK, the Construction Leadership Council (CLC) has today (20 October 2020) published version 6 of its Site Operating Procedures (SOPs), which it says streamlines its previous and updated guidance.
The latest SOPs appear to consolidate the CLC's own previous advice on how to operate construction sites safely during the Covid-19 pandemic and, the construction industry will be relieved to hear, do not contain any surprises.
Version 6 (which can be accessed here) is based on government guidance on Working safely during Coronavirus (Covid-19 – Construction and other outdoor work in England, which can be accessed here) and helpfully includes a "Current guidance" section on the first page. This sets out the government's current stance on infection control measures such as social distancing, alert levels, working from home and wearing face coverings.
The SOPs are then separated into key sections, summarised as follows:
When to go to work
In the section "When to Go to Work", the rules are familiar.
Where working from home is not possible, people should:
- Follow current social distancing guidelines;
- Self-isolate in certain instances; and
- If a worker falls ill, get a test and follow stay at home guidance.
Employers should contact PHE if there is more than one confirmed case of Covid-19 in a 14-day period.
Travel to work
The "Travel to Work" section contains guidance on avoiding vehicle sharing and how to go about sharing vehicles where it is absolutely necessary, including:
- Sharing with the same individuals and with the minimum number of people (up to a maximum of six) at any one time;
- Keeping the windows open;
- Travelling side by side or behind others (rather than facing them);
- Maximising distance between people;
- Wearing a face covering; and
- Cleaning the vehicle between journeys.
The section is followed by a section advising that "Driving at Work" should be carried out alone or, where unavoidable, carried out following government guidance on Working Safely during Coronavirus (Covid-19) – Vehicles (which can be accessed here).
The SOPs then go on to consolidate guidance for:
- "Site Access and Egress Points", including: staggering shifts, changing the number of access points, introducing one way systems, signage and providing direction as to cleaning;
- "Hand washing", including: allowing handwashing breaks, providing additional (i.e. pop up) handwashing and sanitising facilities, water supply and provision of rubbish bins;
- "Toilet Facilities", including encouraging pre- and post-use handwashing, restricting the number of toilet users at any one time, enhanced cleaning regimes, frequency of cleaning and the provision of rubbish bins;
- "Canteens and Rest Areas", including the displaying of a NHS QR code (which can be produced here), wearing face coverings (except when seated/eating/drinking), displaying the facility's capacity, staggering breaks, enhanced cleaning, sanitiser provision at the entrance, seating configuration and the use of contactless payment where possible;
- "Changing Facilities, Showers and Drying Rooms", including determining the facility's capacity, staggering start/finish times to reduce congestion and enhanced cleaning regimes;
- "First Aid and Emergency Service Response", including provision of adequate first aid resources, emergency plan updating and the prevention or rescheduling of high-risk work (or providing additional first aid/trauma resources; and
- "Cleaning", including guidance on enhanced cleaning procedures which includes a list of touch points which should be subject to such enhanced cleaning along with the communal areas.
The SOPs reiterate that "sites and work need to be planned and organised to avoid crowding and minimise the risk of spread of infection by following government guidance and the advice within these Site Operating Procedures" and that if it not possible to do so, to consider whether the activity should continue.
Where it must continue, the hierarchy of controls should be considered to produce a risk assessment, the results of which should be shared with the workforce. The hierarchy of controls is contained on page 6 of the SOPs
The CLC's landing page for the SOPs suggests that: "The wording has been reviewed throughout to reflect the fact that social distancing is no longer exceptional…".
Strictly speaking, this is not accurate as the SOPs continue to propose the use of the hierarchy of controls to consider whether to carry out an activity which cannot be carried out in a socially distanced manner.
That said, the industry will appreciate the latest SOPs, which arguably provide the clearest guidance the industry has received yet (albeit, seven months into the pandemic).
This article was authored by Craig Longhurst, a solicitor in the construction team at Fieldfisher. If you have any queries about the impact of Covid-19 on your particular projects or contracts please contact a member of the Fieldfisher construction team.
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