LOCKDOWN LEVEL 4
FINAL REGULATIONS STILL PENDING
Government has not yet published the Occupational Health and Safety (OHS) regulations and requirements applicable to employers who may commence operations under Level 4 lockdown on 1 May 2020.
There may be insufficient time available for these employers to prepare for the resumption of operations on 1 May, consequently, we have compiled a list of minimum requirements that we believe employers will have to comply with as a basis for the proposed measures likely to be effected by Government.
Kindly note that that apart from the requirement dealt with herein, compliance with the normal OHS requirements for a particular workplace must remain.
The following requirements will, according to current information, be compulsory in every Level 4 workplace:
Personal hygiene policy:
• all employees should regularly wash their hands with soap and water for a minimum of 20 seconds;
• no handshakes or other physical contact is allowed between employees or employees and visitors/clients;
• employees should sanitise their hands regularly with alcohol-based hand sanitizer, with an alcohol content of at least 70%, after contact with any person or after contact with frequently touched surfaces;
• employees must cough into the fold of their elbow or in a tissue which must be discarded in a waste bin afterwards, and then wash their hands immediately afterwards as set out above; and
• employees must avoid touching their eyes, nose, and mouth.
Personal protective equipment (PPE)
The employer will be compelled to introduce a COVID-19 PPE policy in respect of all employees and visitors to the workplace and to provide PPE, as to be determined by the regulations. We propose, in preparation, to introduce the following PPE measures in the workplace:
• the issuing of masks to all employees and all employees must wear these masks;
• the employer may not allow any visitor to enter the workplace without the proper PPE as per the regulations and/or the employers’ policy;
• the employer should inform all visitors that they are to provide their own PPE in order to enter the workplace, alternatively, issue all visitors with the required PPE;
• the employer should train employees on the correct use, necessary hygiene practices and proper disposal of PPE in order to avoid cross-contamination from PPE to the user’s hands or clothes;
• supervisors should monitor and enforce wearing, sanitising and disposal of the appropriate PPE; and
• the employer should perform non-invasive temperature testing of all employees and visitors upon entering the premises.
Social distancing measures
It is widely expected that the regulations will enforce social distancing measures in the workplace, as social distancing is one of the main strategies in preventing the spread of the virus.
Employers will likely be expected to implement the following measures:
• employees must practice social distancing of at least 1.5 meters away from any other person in all circumstances;
• the employer should introduce staggered tea and lunch breaks to avoid a gathering of people and should also enforce social distancing protocols during these breaks;
• the employer should adopt and enforce a policy to avoid face to face meetings and, where possible, conduct meetings via electronic platforms (such as Skype, Zoom or Microsoft Teams);
• the employer should, where possible, adopt a work from home policy, particularly in respect of vulnerable employees;
• the use of paper towels on door handles, handrails and other commonly touched surfaces should be enforced;
• the employer should implement measures for the regular cleaning of the office and commonly touched areas; and
• the employer should introduce rules confining employees to their workstation, as far as practically possible.
The employer must enforce a strict ‘no travel for business purposes policy’, subject to the exceptions as per the regulations, i.e. cargo that may be moved across provincial borders.
Policies and procedures to be implemented in the event of a COVID-19 outbreak in the workplace:
• the employer must develop a policy and protocol which is to be implemented when a case of COVID-19 infection has been detected in the workplace. It is not yet clear what this protocol will contain as the Government has not yet provided guidance on this issue;
• the employer should train employees on their responsibilities and the relevant procedures in terms of the protocol;
• employers should utilise a checklist to ensure compliance with all the OHS requirements. A checklist will be provided as part of a toolkit that NEASA will circulate to members once the final regulations are available.
It is strongly advised that a dedicated manager should be identified to monitor and enforce compliance with all of the above.
We will notify employers of the final regulations as soon as they are gazetted in the Government Gazette.
NEASA 24/7 NATIONAL HOTLINE: 086 016 3272
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