Covid19 has been the biggest Health and Safety risk that schools have faced in 100 years.
Since March schools have demonstrated incredible resilience in the face of the COVID19 pandemic. They have adapted from traditional classroom education to a mix of classroom and remote delivery.
On the 2nd July, the Government released guidance on full opening of schools from September 2020. This guidance focused on schools producing a risk assessment for managing the risk from Covid-19.
COVID-19 Risk assessment for Schools
Apart from the Government guidance requiring schools to carry out a risk assessment. All schools as the “employer” have a duty under the Health and Safety at Work Act 1974 to take all reasonably practicable steps so as to ensure the health, safety and welfare of their staff and anyone else impacted by their operations (this includes pupils and visitors and contractors).
There is also the Management of Health and Safety at Work Regulations 1999 regulation 3 that requires the employer to undertake “suitable and sufficient assessments of the risks to the health & safety of employees and other persons, not directly employed, that could be affected by their undertaking”.
Both these pieces of legislation require the employer to complete a risk assessment to identify what measures need to be in place for managing the risk from Covid-19 and reducing the risk to a low as possible.
Risk Management
The HSE on their website have guidance on how to complete a risk assessment and many schools may have engaged the services of a Health and Safety consultant to carry out the risk assessment or conducted this themselves. The risk assessments would have been extensive and between 20 to 30-pages.
The safety “hierarchy of control” should have been used when considering what can be done to manage the risk. Any mitigation controls devised and implemented must reduce exposure of employees and pupils to the virus.
The risk assessment should cover the following “prevention” and “response to an infection” measures.
Prevention:
- Minimizing contact with individuals who are unwell by ensuring that those who have coronavirus (COVID-19) symptoms, or who have someone in their household who does, do not attend school.
- Hand hygiene.
- Good respiratory hygiene by promoting the ‘catch it, bin it, kill it’ approach.
- Enhanced cleaning, including cleaning frequently touched surfaces often.
- Minimise contact between individuals and maintain social distancing wherever possible.
- Where necessary, wear appropriate personal protective equipment (PPE).
Response to any infection
- Engage with NHS Test and Trace process
- Manage confirmed cases of coronavirus amongst the school community
- Contain any outbreak by following local protection team advice
Once the risk assessment has been completed it is important to remember that a risk assessment does not control risk. It is the actions of individuals who apply the controls identified by the risk assessment that mitigate the risk.
For example, where the school identifies social distancing as a control measure between pupils and their teachers (secondary schools) if this is not followed by staff or pupils the risk will remain.
So much emphasis would have been on the full opening from September but spending effort on developing and applying controls bespoke to the school’s circumstances is a waste of time unless the implementation and performance is monitored over time. The written risk assessment is only the starting point and the successful delivery will be in the continual monitoring of the control measures that the school has identified.
Schools should identify plans for routinely reviewing the effectiveness of the risk assessment controls. It is vital to ensure that these controls are maintained and even improved on as knowledge about the virus, its transmission and its control develops.
Monitoring control measures
This could be as simple as allocating staff at different times of the day for example lesson changeover, breaks and lunches to observe staff and pupil behaviour and check control measures are followed. For example:
- When staff arrive at school early do, they wash or sanitise their hands. Are they keeping apart from colleagues?
- Are pupils hand washing effectively for 20 seconds throughout the day?
- Are staff and students observing social distancing in classrooms, corridors?
- Are staff and pupils using tissues when sneezing and putting them in a bin.
- Are toilets and high contact touch points being cleaned frequently throughout the day using the appropriate cleaning materials?
- Are shared resources quarantined for 72 hours or cleaned between bubbles.
Consider introducing a system of reporting near misses for example weaknesses in the controls.
Sharing the Risk Assessment
The risk assessment should have been shared with Trade Unions and with all staff (including those not in a trade union) meeting the employer’s requirement for legal consultation.
Before returning to work staff must be made aware of the hazards and measures in place to control them. For example, if administering first aid changes or new staggered break times etc.
Many schools have developed a staff guide/handbook/operational manual to record all the new arrangements.
Staff training (delivered remotely) on the new arrangements will be key to the success of the school’s operations. It is important to keep a record of any training delivered when this has been refreshed following changes.
For schools that have over 50 staff the risk assessment should also be published on the school website.
It is so important to get parental support and co-operation with the new school procedures. This could be in the form of a handbook/guide and parental agreement. The agreement could include a commitment to follow government advice and not send their child into school with symptoms, agree to their child taking a test if required and providing the result from any test as part of the NHS Track and Trace system.
Reviewing the COVID-19 Risk Assessment
This risk assessment will need regular review, initially daily, as things change for example following: –
- government and public health advice,
- scientific evidence,
- specific education guidance updates for example from CLEAPSS, Association of PE
- case of COVID-19
- Introduction of new activities such as lettings, educational trips, extracurricular activities
- other change in circumstance.
- local lockdown
In the Autumn term we will also be moving into the “normal flu” season. Good “respiratory hygiene” and “handwashing” remains a critical control for managing the risk from COVID-19, flu and other infections and therefore should be monitored closely.
Building resilience
We really do not not know what the future holds in terms of a second spike or wave in COVID-19 cases.
What we do know is that the virus will not go away until there is a vaccine, and this could be many months away. Therefore, schools should be reviewing their business continuity plans and as a guide have a plan A, plan B and plan C in place.
Plan A – School open fully for all year groups delivering face to face teaching following government measures.
Plan B – School open with face to face delivery but also remote delivery for individuals or “bubbles” that have to be at home (self isolating, suspected or a confirmed case).
Plan C – School open for key workers pupils and remote learning as local or national lockdown in place.
The ability to be able to switch between plans will be so important to the successful seamless delivery of education over the coming months.
Cousins Safety is a health and safety consultancy to schools and provides a range of services including AUDIT, TRAINING and CONNECT (advice service) to schools to help manage the risk.
Please get in touch on 01480 718007 or info@cousinssafety.co.uk