In response to the immediate changes to working practices regarding COVID-19, businesses have new and additional pressures; increased demand for existing products, the production of new products due to nationwide shortages, and lack of employees due to self-isolation or illness, to name but a few.
Even though the situation is leaving many businesses time-poor, this pressure may necessitate a need for enhanced induction and training protocols, as new employees may not have manufacturing experience. The manufacturing environment may also be adopting new production processes such as; changing production line to maintain the two-metre rule and roles specific to changed working systems, for example, staggered shifts to avoid cross- contagion of workers.
Health and safety, the methodology of training employees, updating risk assessments and associated safe systems of work and maintaining behavioural safety standards are considered key when looking to managing risk during this period.
It is advised that employers implement social distancing in accordance with Government advice1, which should be adhered to by employees. Where the production process makes this difficult to do, employers should consider what additional measures should be put in place. Government advice states that ‘the practical implementation will depend on local circumstances’.2 Therefore, risk assessment and procedures should be reviewed, and where practicable the two metre rule applied, with floor markings to assist with this. If not practicable, additional control measures should be considered and documented.
The Health and Safety at Work Act 19743 requires you to provide whatever information, instruction, training and supervision as is necessary to ensure, so far as is reasonably practicable, the health and safety at work of your employees. This is expanded by the Management of Health and Safety at Work Regulations 19994, which identify situations where health and safety training is particularly important, e.g. when people start work, on exposure to new or increased risks and where existing skills may have become rusty or need updating.
Businesses identify the skills and knowledge needed for people to do their job in a safe and healthy way and also compare these against people’s current skills and knowledge to identify the gaps. This is usually reviewed as new employees enter the business or existing employees are reallocated. An updated training needs analysis spreadsheet is one way to assist this process.
Consideration should be given within this initial training review process that new employees may not have worked in a manufacturing environment previously. This may necessitate an enhanced site-specific induction programme.
A review of risk assessments can help businesses identify where information or training have been identified as factors in controlling risks. A review of risk assessments can help businesses identify where information or training have been identified as factors in controlling risks.
This is particularly important if a new process or equipment is being installed and operated. Check associated safe systems of work have also be updated for new processes and equipment.
Even though you may be experiencing time pressures to meet demand and deliver, it is recommended new or changed manufacturing risk areas are reviewed in addition to the ongoing risk management process. Some examples as noted below;
Induction training is designed to be delivered and completed as soon as employees commence work. This usually includes all safe working practices and rules. Employees new to manufacturing may require shadowing and direct supervision for a defined time period. Existing employees also may need an induction refresher programme. It is important process changes are reflected in updated safe working procedures, with these formally trained out to applicable new and existing employees. Training updates for employees in self isolation should also be considered.
Additional monitoring through audits and inspections across the site should be considered. This should assess suitability and implementation of risk controls. In particular behavioural safety factors due to changes in working practices should be monitored.
In current times it is understandable to focus on COVID-19 risks but businesses may need to ensure they’re not losing sight of the key risks Food and Drink Manufacturers face on a daily basis. Stepping back and looking at your foundation procedures, updating in light of your production amends and Government guidance will help to maintain a safe and productive environment.
Each applicable policy of insurance must be reviewed to determine the extent, if any, of coverage for COVID-19. Coverage may vary depending on the jurisdiction and circumstances. For global client programs it is critical to consider all local operations and how policies may or may not include COVID-19 coverage.
The information contained herein is not intended to constitute legal or other professional advice and should not be relied upon in lieu of consultation with your own legal and/or other professional advisors. Some of the information in this publication may be compiled by third party sources we consider to be reliable, however we do not guarantee and are not responsible for the accuracy of such information. We assume no duty in contract, tort, or otherwise in connection with this publication and expressly disclaim, to the fullest extent permitted by law, any liability in connection with this publication. Willis Towers Watson offers insurance-related services through its appropriately licensed entities in each jurisdiction in which it operates.
COVID-19 is a rapidly evolving situation and changes are occurring frequently. The information given in this publication is believed to be accurate at the date of publication shown at the top of this document. This information may have subsequently changed or have been superseded, and should not be relied upon to be accurate or suitable after this date.
1 https://www.gov.uk/government/publications/covid-19-guidance-on-social-distancing-and-for-vulnerable-people/guidance-on-social-distancing-for-everyone-in-the-uk-and-protecting-older-people-and-vulnerable-adults
2 https://www.gov.uk/government/publications/covid-19-guidance-for-food-businesses/guidance-for-food-businesses-on-coronavirus-covid-19
3 http://www.legislation.gov.uk/ukpga/1974/37/contents
4 http://www.legislation.gov.uk/uksi/1999/3242/contents/made
