Government Guidance for Working in Other People’s Homes
The Government has published guidance for getting back to work. The document ‘Working safely during COVID-19 in other people’s homes: Guidance for employers, employees and the self-employed’, was published on 11th May.
From that, we are providing a guide for retail window and door installation companies. We have extracted the key elements of the guidance, applying it to window and door sales and installation, so that you know what you need to do as part of your safe return to work.
The document is focused on two primary areas as follows.
Thinking About Risk
Getting business to carry out a COVID-19 risk assessment: It states: As an employer, you also have a legal responsibility to protect workers and others from risk to their health and safety. This means you need to think about the risks they face and do everything reasonably practicable to minimise them, recognising you cannot completely eliminate the risk of COVID-19.
Reducing the risk to the lowest practicable level through prevention: Employers have a duty to reduce workplace risk to the lowest reasonably practicable level by taking preventative measures. Employers must work with any other employers or contractors sharing the workplace so that everybody’s health and safety is protected.
We’re reversing the running order here as we feel that in understanding some of the practical requirements that the guidelines place on installers first, it’s easier to understand, the sorts of things that they need to be thinking about when carrying out risk assessments.
Can I Work in Someone’s Home?
Yes – government guidelines make it clear that working in someone’s home is acceptable as long as:
• The risks associated with doing so have been assessed i.e. you have carried out a risk assessment
• Where practical those risks have been mitigated • And that on this basis, it is reasonable to assume that the work can be done safely.
Hold-up – before you start knocking on doors, you need make an assessment as to whether the work can be done either remotely, e.g. from home or within social distancing guidelines e.g. while remaining 2m apart?
If you can’t or can only complete part of the tasks you need to within these guidelines, the Government is clear, you can still work, if those operations are critical to your business.
The caveat is that you must assess the COVID-19 related risks of doing this work – and where it is practical to – to mitigate them.
There are two exceptions to these rules:
Work should not be carried out if:
• The household is isolating because someone within it has COVID-19 symptoms
• Or where an individual has been advised to shield
Work can be carried out, but special arrangements must be made, if:
• Someone is clinically vulnerable but has not been asked to shield e.g. over 70. This would include communication with the household to avoid or reduce face-to-face contact; the introduction of strict hygiene controls, e.g.
• Catching coughs and sneezes in disposable tissues
• Increased hand washing and sanitizing
• Cleaning of regularly touched surfaces and objects
• Maintaining social distance.
How Does This Change How I Do Business?
So, as a window and door installation business you can generate business and run installations in someone’s home as highlighted as long as:
• No one in the household is isolating because someone within it has COVID-19 symptoms or where an individual has been advised to shield
• As long as you conduct a risk assessment and put in and can be seen to as far as is practical, mitigate risks associated with working to the occupants and your employees
• The element of work you are undertaking, cannot be completed remotely or from home This means you need to consider how each part of your business operates and the risks and controls you should in place to mitigate them.
Government guidelines make it clear that your sales team can, and should generate new business remotely and from home, remaining within guidelines where possible for social distancing. Where absolutely necessary guidelines say that appointments can take place but:
• Every effort should be made to maintain a 2m separation
• Avoid transmission by not sharing pens and other objects
• Holding meetings outdoors or in well-ventilated rooms.
Award-Winning Windows & Doors to the Trade
Surveyors will need to go out to the site to measure up – there’s no getting around it. This can be done within guidance providing a risk assessment that has been completed and controls have been put in place as far as possible to mitigate those risks.
For example, as a starting point, this would include implementing the Government’s list of preventative measures e.g. maintaining 2m social distancing; increased handwashing; cleaning of equipment; and so on (see full list as outlined, Appendix A).
It would also include planning in advance with the customer the sequence of works so that they can as far as possible, maintain social distancing during the visit.
And other practical steps, for example:
• COVID-19 employee awareness training and regular employee communication
• Not accepting a tea from the customer
• Using their toilet facilities.
• Leaving internal doors open to minimize contact
Do I Need Specialist PPE for Working in Someone’s Home?
You may be surprised to read that the answer is in fact ‘No’
Government guidance states that:
When managing the risk of COVID-19, additional PPE beyond what you usually wear is not beneficial. This is because COVID-19 is a different type of risk to the risks you normally face in a workplace, and needs to be managed through social distancing, hygiene and fixed teams or partnering, not through the use of PPE.
Workplaces should not encourage the precautionary use of extra PPE to protect against COVID-19 outside clinical settings or when responding to a suspected or confirmed case of COVID-19.
Unless you are in a situation where the risk of COVID-19 transmission is very high, your risk assessment should reflect the fact that the role of PPE in providing additional protection is extremely limited. However, if your risk assessment does show that PPE is required, then you must provide this PPE free of charge to workers who need it. Any PPE provided must fit properly.
What About Face Masks?
The guidance does, however, state that, face masks, while offering little protection from catching COVID-19, may help you or your team prevent giving it to someone else: Wearing a face covering is optional and is not required by law, including in the workplace. If you choose to wear one, it is important to use face coverings properly and wash your hands before putting them on and taking them off.
In short, you, your team and the customer may feel better about wearing a mask, but the guidance says the benefits are strictly limited and masks are not a requirement by law.
The same controls and mitigations for safe working and interaction with the customer set out for surveyors, also applies to fitting teams. Again, they and you, can’t do their job/run your business, without going into someone’s home, which is why the Government says you should return to work.
As most jobs run on a minimum two-man team, this creates additional requirements to protect your workforce. This includes:
• Social distancing where possible
• Increase the frequency of handwashing and surface cleansing
• Avoid sharing of tools – and increase cleaning of them
• Use back-to-back or side-to-side working where possible
• Run ‘fixed teams or partnering’, so each team works with only a few others
And the customer:
• Again, planning in advance with the customer the sequence of works so that they can maintain social distancing.
• Leaving internal doors open to minimize contact
• Increased cleansing of surfaces
The Government also makes a series of recommendations on travelling to and from the job. This includes if possible:
• Using your own transport
• Keeping the same teams together travelling to site
• Keeping windows wound down
• Regular cleaning of vehicles
• Washing of hands-on arrival at someone’s home
What do I need to include in a COVID-19 risk assessment for working in someone’s home?
The preceding part of this analysis has been focused on answering questions of ‘can you work in someone else’s home?’ and ‘what practical steps do you need to be thinking about to do it as safely as possible?’
The Government has, however, made it clear that it wants businesses to think about this before starting the job, and that means conducting a COVID-19 risk assessment.
It acknowledges that the risks posed by COVID-19 can’t be eliminated altogether but you need to be able to demonstrate that you have considered them and done ‘everything reasonably practicable to minimise them’.
Every window and door retail business will run differently and will have slightly different controls and procedures in place for the assessment and management of risk, which is why the practical measures outlined in the preceding pages of this document are for guidance.
This is why carrying out risk assessments for individual operating environments is key. It’s fundamentally about identifying sensible measures to control the risks in your workplace.
There are interactive tools available to support you from the Health and Safety Executive (HSE) at https://www.hse.gov.uk/risk/assessment.htm.
It also doesn’t have to be arduous. If you have fewer than five workers, or are self-employed, you don’t even have to write anything down as part of your risk assessment.
As an illustrative example you may, however, want to consider the following:
• Consult with your team in the same way as a standard risk assessment
• What is the risk of infection?
• Can and how will those risks be mitigated? For example:
• Is the fitting team ‘well’?
• Is the customer ‘well’?
• Is the customer shielding? (this is where you put the job on hold!) Is the customer ‘vulnerable’ but not shielding?
What additional measures do you need to put in place?
• Can social distancing be maintained?
• If not, how can risks associated with not doing so be mitigated?
• Have employees gone through awareness training?
• Are they familiar with what is required from them?
• Have you communicated effectively with the customer?
• Are hygiene and cleaning procedures established?
Risk assessment results should be shared with others working in a home or when visiting others’ homes and ideally posted online.
The road back from COVID-19 is going to be a long one – but we now at least have a map and a sense of direction.
We know exactly how tough it is in retail – we have our own installation business – and will continue to share the insights that this gives us with our customers and our dedicated guide to safe operating procedures in retail can be accessed via our customer portal.
We’re also making the following tools developed for our own retail and manufacturing businesses available to customers:
• Safe systems of operation
• Office working
• Employee training
• COVID-19 return to work awareness and assessment
• COVID-19 Retail sales guide
• COVID-19 Remote sales software
Whatever lies ahead, we would like to reiterate that we are here to support our customers for the long-term.