WITH guidance and regulation dictated by central government , part of the responsibility for ensuring businesses are COVID-secure lies with the Health & Safety Executive ( HSE ). Following the Government ’ s announcement on its return to work strategy in May , the HSE stated it had begun proactive inspections , and in July , reiterated that “ all sectors and businesses of all sizes are in scope for inspections ” to ensure workplaces were COVID-secure .

It laid out five steps that businesses should be meeting to meet the latest guidance , including :

1 . Carrying out a COVID-19 risk assessment in line with HSE guidance

2 . Developing increased cleaning , hand washing and hygiene procedures

3 . Taking all reasonable steps to help people work from home

4 . Maintaining social distancing where possible

5 . Managing transmission risk , where social distancing is not possible

Industry specific concerns

Whilst these steps appear relatively simple , the ever-evolving Government guidance – whether it was a move of social distancing from 2m to 1m +, or enforcing the wearing of face coverings in enclosed spaces – means that some in agriculture could understandably struggle to ensure the workplace is meeting the most up-to-date guidance . Further , for some it is proving costly to put new procedures in place , only for the guidance to then change once more .

There are also some concerns that the jurisdiction a business has over ensuring COVID guidance is followed has not been properly clarified . Consider staff interactions – how can you ensure social distancing is being followed in off-site smoking areas , for example ?

Agriculture was an industry on the frontline in the early days , working to meet increased demand and keep the UK fed , as supermarkets saw panicked shoppers stockpile . Whilst the overarching rules regarding PPE , increased hygiene and social distancing apply , the industry had its specific set of concerns regarding workplace safety as demand increased , particularly as our understanding of

how susceptible livestock and animals are to the virus evolved . Further , these concerns will vary depending on the production type , whether dairy , animal feed , or food products , and will also be disproportionately more challenging for smaller , family-run businesses than larger agriculture operations .

The Food Standards Agency ( FSA ) reminds agricultural and farming businesses that not only do the normal product safety and hygiene rules apply , but employers must ensure that staff handling products must be in good health . Staff must be educated on the Fitness to Work policy and employers should consider surveying those onsite to assess and mitigate COVID exposure .

How can I prepare for a COVID inspection ?

So far , the HSE appears to be carrying out the majority of its inspections as random ‘ spot checks ’, including phone calls and on-site visits . Interestingly there have been cases where the HSE has attended on-site to investigate a reported incident and the inspector has extended their investigation to include a COVID assessment whilst present . Requests have also been made by Inspectors to provide COVID-19 procedures and a copy of the COVID-19 risk assessment prior to the visit taking place .

It ’ s therefore vital to ensure your business is following COVID-secure guidance and is mitigating necessary risks ahead of time , as you are unlikely to receive notice that an inspection is upcoming . Reasonably practicable measures must be taken – and clearly demonstrated – to minimise the risk of COVID-19 transmission .

Having documentation to evidence the reasonably practicable measures that have been put into place to minimise the risk of COVID-19 transmission is key . Equally , evidence of these measures being communicated to workers and any associated additional training provided is critical to support and protect an organisation ’ s position A business should therefore document the risk assessment process ( recording any changes made in response to further advice from the government and regulator ) and associated actions such as safe systems of work , training and communications so that if questioned at a later date , the organisation can demonstrate the assessment carried out , justify the measures taken and

satisfy the HSE that the guidance and developments had been kept under review .

A chronology of compliance set against government and industry wide advice and guidance is critical . Advice and information is continually evolving in respect of COVID-19 so it is important to be able to give clear evidence on what policies and procedures were in place at the time of an incident and be able to draw a comparison with the available information at that time , demonstrate how and when this has been updated since and why , particularly after any new cases of COVID-19 being reported .

As part of the inspection , be prepared to answer questions concerning risk assessments , systems of work and training , handling possible outbreaks within the workforce and measures in place to enforce and oversee the new measures . Documents to support this and demonstrate what is in place should also be pulled together in preparation for this . And remember that the HSE will not just look at what the organisation has implemented at management level ; expect inspectors to speak to affected workers to gather evidence of their understanding of the measures and the level of compliance on the ground .

If your business operates within a location affected by local or partial lockdown , be