Duncan Spencer, Head of Advice & Practice at IOSH, discusses the important role OSH professionals play in responding to the COVID-19 pandemic...
So, your workforce diminishes as people fall ill with COVID-19 or are obliged to isolate and you need to work with a skeleton staff. This means that you don’t have enough resources to fully operate your safety management system or implement the full suite of risk controls.
What do you relax? What room do you have for compromise? Do arguments of reasonable practicability exist or apply to this situation?
These are important questions. It might be a time of national emergency, but that does not mean that laws are suspended. OSH professionals must think the situation through and provide sound advice to the Board of their organisation and pragmatic guidance to line management.
Organisations who are truly risk-led and evidence-driven are at an advantage in meeting the challenges of answering these questions. A well thought through risk register, founded on quality risk assessment and assembled to show the relative significance of the list, is the key.
For example, consider a retail distribution centre who is struggling to meet panic buying demand and who has a reduced employee number due to the virus. Management should first consider what is at the top of their OSH risk register e.g. preventing unauthorised drive away from docking bays, or the safe use of pallet inverters. They would also review what is at the bottom of the list e.g. risks associated with some housekeeping duties.
The focus on the top of the risk register would highlight controls that must not be compromised under any circumstances e.g. traffic light systems and key control procedures must be enforced at docking bays. Consideration of the bottom of the risk register may reveal where control may be relaxed for a period or be covered by new controls e.g. housekeeping procedures being more pragmatically controlled in this period by managers walking about and responding to conditions rather than normal procedural routines.
Management systems may also need modification. Less people and a busier environment may compromise the normal running of safety management systems, or key personnel may be absent. The OSH professional must take a lenient view on paperwork and process. Clarity is needed on what reporting can be dropped and which must be continued if the Board are to meet their governance and legal decision-making responsibilities. It may be prudent to announce which OSH projects will be paused during the crisis.
These are tough choices, but they are based upon the application of reasonable practicability. With a reduced workforce at a time of high demand, it is highly likely that normal working practices are compromised. Risk management principles demand that we predict and react to these changing circumstances and how the likelihood of accidents may well increase at a time of reduced resources.
Temporary risk management decisions such as the examples given are therefore often necessary and can be justified. But don’t forget the secondary challenge. When demand and staffing returns to normal, the compromises made may not be reasonably practicable any longer.
The OSH professional must have a plan for reinstating normal control standards and management systems and ensure that the OSH culture of the organisation going forward is not undermined in the long term.
OSH professionals have an important role to play in this epidemic. More than ever they must be an enabler and supporter of the tough operational decisions that need to be made by their operational colleagues. They must remain a critical friend, willing to compromise where possible and provide clarity where it is not - advising guiding and influencing.
IOSH has created and is regularly updating its easy-to-use coronavirus guidance, providing useful information on preventative measures, emergency planning and ways of managing the safety, health and wellbeing of workers.
This guidance is available here: www.iosh.com/coronavirus