Employers & employees responsibilities for COVID-19 and the Hierarchy of Controls

I started my career in Health & Safety in 1994 with the construction and commissioning of the Hillside Aluminium Smelter in Richards Bay. Since then, I have made Health & Safety my passion and not a career. Along my journey, I have met a lot of people who share my passion and some that did not, but through motivation and behavioural based safety programmes, I managed to change some of their minds. However, it is unfortunate that a lot of HSE personnel do not share the same passion as a lot of us do.   Their mind-set is still to install fear, and this has to change and now is the time to change it.  At the end of March, our project was postponed due to the lockdown and restriction of contractors on site due to the COVID-19 outbreak. 

In the 26 years that I have been in construction and operational projects, I have experienced a bumpy “rollercoaster” ride with regards to the economic situation, not just in South Africa, but world-wide.

It seems now that the “chain” that pulls the rollercoaster cart up the tracks has snapped sending the global economy in a downward spiral which is not good news for any company, no matter if you are a small local outlet or a global corporation.

In this tough situation that we are facing, there is the reality that there will be potential job losses on a large scale which cannot be prevented and in turn, could result in depression for those who have lost their jobs and for those who are still in employment, unforeseen incidents due to stress of possibly losing theirs.

To limit the impact of the COVID-19 outbreak on businesses and their employees as well as the public, it is crucial for all businesses to plan for COVID-19 addressing the specific exposure risks, sources of exposure and routes of transmission and compare it to the influenza (flu) virus.

The legislation governing workplaces in relation to COVID – 19 is the Hazardous Biological Agents Regulations (as set out in the Occupational Health and Safety Act, Act 85 of 1993) and section 8 (1) of the Occupational Health and Safety Act, Act 85 of 1993, as amended, which requires the employer to provide and maintain as far as is reasonably practicable a working environment that is safe and without risks to the health of employees and section 8(2)(b) which requires steps such as may be reasonably practicable to eliminate or mitigate any hazard or potential hazard before resorting to personal protective equipment (PPE). However, in the case of COVID–19, a combination of controls is required. Here are some examples of controls:

Elimination Controls

  • Minimize contact among workers, clients, & customers (replace meetings with virtual communications).
  • Encourage sick workers to stay at home.

Engineering Controls

  • Install high-efficiency air filters.
  • Increase ventilation rates.
  • Install physical barriers such as screens at counters.

Administrative Controls

  • Minimize the number of workers on site (rotation or shift work).
  • Discontinuing nonessential local and international travel.
  • Develop emergency communications plans
  • Provide workers with up-to-date training on COVID-19 risk factors.
  • Train personnel in correct selection and use of protective clothing & equipment.

Safe Work Practices

  • Provide a work environment that promotes personal hygiene.
  • Require regular hand washing or using of alcohol-based hand rubs.
  • Display hand washing signs in restrooms.

Personal Protective Equipment (PPE)

  • Select based on the hazard to the worker (risk assessment).
  • Correctly fitted (e.g., respirators) and consistently worn when required.
  • Regular inspections and maintained, and replaced, as necessary.
  • Properly removed, cleaned, and stored or disposed of.

Employers are obligated to provide their workers with PPE needed to keep them safe while performing their duties. The types of PPE required during a COVID-19 outbreak will be based on the risk of being infected with SARS-CoV-2 while working and job tasks that may lead to exposure.

Written by Alan Stacey (Project Health & Safety Management Practitioner)