Managing COVID-19 risks: Manufacturing industry

Restrictions apply across Victoria

Depending on your industry your workplace may:

• be subject to restricted operations or industry specific obligations
• be subject to COVID-19 vaccination requirements

It is mandatory for every Victorian business with on-site operations to have a COVIDSafe Plan. COVIDSafe plans should be reviewed and updated regularly.

COVID-19 restrictions in Victoria may be updated at any time. You must stay up to date with changes for your industry.

How are my occupational health and safety (OHS) obligations impacted by the restrictions?

There is no change to your obligations under the Occupational Health and Safety Act 2004 (OHS Act) and Occupational Health and Safety Regulations 2017 (OHS Regulations) as a result of the Pandemic Orders issued by the Victorian Minister for Health.

Preparation of a COVIDSafe Plan forms part of the development of a safe system of work. However, having a COVIDSafe Plan and complying with the Victorian Pandemic Orders does not necessarily mean you have complied with all of your duties under the OHS Act and OHS Regulations.

You must follow any Pandemic Orders that apply to how your business must operate, and ensure that you are meeting your obligations under the OHS Act. Employees must also comply with their duties under the OHS Act.

Transmission of COVID-19

Researchers are still learning about COVID-19, its long-term effects and emerging variants.

COVID-19 is a respiratory disease caused by a coronavirus (SARS-CoV-2) that can result in mild to very severe illness and death.

The main way COVID-19 spreads is when a person with COVID-19 exhales droplets and/or aerosol particles containing the virus. This can happen when they breathe out, cough, sneeze, speak, shout or sing.

Exhaled droplets range in size. Large droplets settle out of the air faster than they evaporate. Small droplets remain suspended in the air for longer periods. Very fine droplets may contain the virus, and can stay suspended in the air for anywhere from minutes to hours. Small droplets and particles are often referred to as ‘aerosols’.

Transmission of COVID-19 can occur in a number of ways, and possibly in combination.

1. Airborne transmission

This occurs when a person inhales aerosols that may contain viral particles that are infectious.

While the risk of transmission is highest when close to an infectious person, air currents can disperse small droplets and particles over long distances. These may be inhaled by people who have not had face-to-face contact or been in the same space with the infectious person. Airborne transmission is more likely to occur in indoor or enclosed settings that are poorly ventilated, crowded, or both. In these kinds of settings, the virus may remain suspended in the air for longer and increase the risk of spread as people tend to spend longer periods in indoor settings.

2. Droplet transmission

Transmission occurs where exhaled droplets from a person with COVID-19 come into contact with another person's mucosal surfaces (nose, mouth or eyes). The risk of transmission is highest when close to the source, where the concentration of these droplets is greatest.

3. Contaminated surfaces transmission

People may also become infected by touching surfaces that have been contaminated by the virus, and then touching their eyes, nose or mouth without cleaning their hands.

COVID-19 and the manufacturing industry

Manufacturing is one of the cornerstones of Victoria's economy, employing hundreds of thousands of people producing food, textiles, wood, printing, chemicals, metal, machinery and other goods. Employees in the manufacturing industry are at risk of being exposed to COVID-19 at their workplace through factors such as:

• close contact with fellow employees in high-traffic environments
• engaging with delivery drivers or contractors attending the workplace
• shared handling of plant and equipment
• shared handling of products, including raw materials during the manufacturing process
• shared handling of manufactured goods
• increased numbers of non-direct employees such as labour hire employees, sales persons, clients, suppliers and others

Under the Occupational Health and Safety Act 2004 (OHS Act) employers have a duty to provide and maintain, so far as reasonably practicable, a working environment that is safe and without risks to the health of employees, including independent contractors. This duty includes preventing risks to safety and health, including psychological health, associated with potential exposure to COVID-19.

Employees have a duty to take reasonable care of their own and others' health and safety in the workplace and to cooperate with their employers about any action they take to comply with the OHS Act and Occupational Health and Safety Regulations 2017 (OHS Regulations).

Identifying risks

Employers must identify hazards and, if necessary, assess the level of risk to the health of employees from exposure to COVID-19 at their workplace. This must happen in consultation, so far as reasonably practicable, with employees and any health and safety representatives (HSRs).

Employers should consider each group of employees, from those handling deliveries of raw materials through to those involved in producing the final manufactured goods. This includes areas such as manufacturing, packaging, storage, warehouses, forklift movement, cleaning and maintenance, cafeteria staff, administration, contractors and their employees who have to come on site to carry out work for the employer, such as the servicing and maintenance of plant and equipment.

Contributing factors

Some of the main factors that could contribute to manufacturing employees contracting COVID-19 include:

Controlling risks

Where a risk to health is identified at a workplace, employers must, so far as reasonably practicable, eliminate the risk. Where it is not possible to eliminate the risk, employers must control the risk, so far as reasonably practicable.

Face masks in workplaces

Pandemic Orders made by the Victorian Minister for Health about face masks are in place across Victoria. For more information see the guidance Managing COVID-19 risks: Face masks in workplaces.

COVID-19 vaccinations in workplaces

COVID-19 vaccination is one control measure that can reduce the risk of COVID-19 in workplaces. This should be part of a suite of controls used to reduce the risk of COVID-19 in workplaces.

Consult with employees

Employers have a duty to consult with employees, independent contractors and any health and safety representatives (HSRs), so far as is reasonably practicable, on matters related to health or safety that directly affect, or are likely to directly affect them. This includes consultation on identifying hazards or risks and decisions about how to control risks associated with COVID-19.

The consultation should be conducted in accordance with any agreed consultation procedures.

Screening

Employers should implement an employee screening process to minimise the introduction of COVID-19 into the workplace. Employers should ask employees before they enter the workplace if they are currently subject to any Pandemic Order requirements (such as needing to isolate or quarantine), and instruct employees who have been in contact with confirmed or probable cases of COVID-19 to follow Department of Health (DH) procedures.

Ensure employees know what to do

An employer's duty to eliminate or reduce risks associated with exposure to COVID-19 so far as is reasonably practicable includes ensuring that:

• confirmed COVID-19 cases do not attend the workplace
• employees know what to do or who to notify if they feel unwell or suspect they've been infected, according to the information provided by DH
• employees who have been in contact with confirmed or probable cases of COVID-19 are instructed to follow DH procedures
• any unwell employee does not attend the workplace, including those who have been tested for COVID-19 and are awaiting their test result

The symptoms of COVID-19 are: fever, chills or sweats, cough, sore throat, shortness of breath, runny nose and loss or change in sense of smell or taste.

Some people may also experience headache, muscle soreness, stuffy nose, nausea, vomiting and diarrhoea.

If an employee develops any COVID-19 symptoms, however mild, they should:

• self-isolate immediately, get tested and if needed, seek advice from their doctor or the Victorian Coronavirus Hotline on 1800 675 398.
• tell their employer as soon as possible, follow the procedures their workplace has in place to deal with symptomatic people, and update their employer if their situation changes, for example: if they receive a positive COVID-19 diagnosis

In the event of a suspected or confirmed COVID-19 case or cases at the workplace, Pandemic Orders issued by the Victorian Minister for Health may also require employers to take specific response actions.

The Staff COVID-19 health questionnaire on the coronavirus.vic.gov.au website is a useful screening tool for employers.

Policies and procedures for screening employees should be developed in consultation with employees, any HSRs and occupational medical professionals.

If an employee is at work and develops symptoms of COVID-19, the employer must direct the employee with symptoms to travel home immediately. Where this is not possible, the employee should be isolated in a separate room until they can travel home.

The employee should be advised to be tested for COVID-19 as soon as possible, call the Victorian Coronavirus Hotline on 1800 675 398 and follow the self-isolation guidance available on the DH website. More information is available on the DH website.

Record keeping and contact tracing

Under Victorian Minister for Health’s Pandemic Orders, workplaces are required to keep records of attendance to assist with contact tracing.

Physical distancing

One of the ways COVID-19 spreads is by people coughing or sneezing, causing airborne droplets to transmit from one person to another. This is why face masks and physical distancing are among the best ways to protect others.

Maintaining at least 1.5m distance between employees, customers and other visitors to the premises is essential to prevent the spread of COVID-19.

Under the Victorian Minister for Health's Pandemic Orders, Workplaces may also be required to comply with particular density quotient rules.

Manufacturing workplaces should ensure physical distancing is achieved wherever possible. This includes the factory floor, entry and exit points, toilets and change rooms, dining and smoking areas, office areas and at meetings.

Ways that employers and employees can achieve physical distancing include the following:

Ventilation

People in indoor environments, particularly in crowded or inadequately ventilated spaces, are at a higher risk of becoming infected with COVID-19. When someone infected with COVID-19 has been present, the virus may linger in poorly ventilated spaces or areas with stagnant air for a longer period of time.

Note: If workplaces use fans, such as pedestal or hard-mounted fans, minimise air from fans blowing from one employee directly at another.

Providing an adequate supply of fresh air (ventilation) to enclosed areas of a workplace dilutes the number of airborne virus particles and lowers transmission risk. Improving ventilation alone does not reduce the risk of transmission via droplets and contaminated surfaces. It needs to be considered as part of a suite of infection control measures.

Adequate ventilation can be achieved using natural or mechanical ventilation, or a combination of the two.

• Natural ventilation is fresh air coming in through open windows, doors or air vents.
• Mechanical ventilation means a method of forced or induced ventilation using mechanical air-handling systems that bring in fresh air from outside. It forms part of a building’s heating, ventilation and air conditioning (HVAC) system.

Note: Natural ventilation is dependent on variable local conditions (eg window opening size, weather conditions including wind speed and direction) and may not always be effective in quickly removing airborne virus particles.

Better ventilation can be achieved by:

• increasing the rate that air is supplied
• increasing the supply of fresh outdoor air
• reducing or eliminating recirculated air in HVAC systems
• improving filtration for air recirculated by HVAC systems if the ventilation rate is not compromised
• regular maintenance of the HVAC system, including changing filters

Guidance on HVAC systems is available in AS1668.2:2012 The use of ventilation and air-conditioning in buildings, Part 2: Mechanical ventilation in buildings. Further information on HVAC systems and COVID-19 is available in World Health Organization (WHO) guidance Roadmap to improve and ensure good indoor ventilation in the context of COVID-19 (who.int).

In areas where it is not possible to maintain adequate ventilation and there is a high risk of transmission, portable high-efficiency particulate air (HEPA) filtered air cleaners may be appropriate to be used to reduce the concentration of airborne virus particles and other aerosol contaminants. These units are not a substitute for ventilation. Employers should assess the risk and/or undertake a ventilation assessment to identify what ventilation strategies are appropriate for the space and whether an air cleaner is needed and consider operational placement and maintenance of these units.

Employers should work with the building’s owner or manager to improve ventilation where possible. Engaging a suitably qualified person such as an occupational hygienist or a ventilation engineer to advise and assist should also be considered.

For more information about ventilation, see the following documents on the DH Infection prevention control (IPC) resources page:

• COVID-19: Ventilation principles and strategies to reduce aerosol transmission in community and workplace settings
• Department of Health IPC Ventilation Policy
• Coronavirus (COVID-19) transmission from air-circulating, wind-blowing devices and activities
• Ventilation strategies to reduce COVID-19 infection, when used as per DH guidelines

Hygiene and cleaning

Environmental cleaning

The amount of time COVID-19 survives on inanimate objects and surfaces varies. Environmental cleaning is one way to remove the virus.

Cleaning needs to be conducted in accordance with the DH information on cleaning and disinfection for workplaces.

Employers are required to comply with cleaning Pandemic Orders issued by the Victorian Minister for Health in the manufacturing sector. These Pandemic Orders may be updated at any time. You must stay up to date with any changes.

Employers should increase usual cleaning practises, including at the end of each shift.

In addition:

• ensure frequently touched surfaces including hand rails and door handles are cleaned and disinfected regularly with appropriate detergent or disinfectant solutions
• frequently cleanse and disinfect personal items used in the workplace such as glasses and phones
• workplace amenities including kitchens, lunchrooms, common areas, change rooms, toilets, showers, drink fountains and vending machines should be cleaned and disinfected and the frequency of this cleaning should increase

Additional cleaning and hygiene controls that may be required include:

• ensuring surfaces are cleaned if an employee spreads droplets, such as through sneezing, coughing or vomiting
• ensuring people who are cleaning wear gloves and follow manufacturer's recommendations for use of personal protective equipment (PPE). For example, employees may need protective eye wear when using some chemicals. Where possible, wash hands with soap and water after cleaning or, if washing is not possible, use alcohol-based hand sanitiser. The DH website has information about putting on and taking off PPE and there is also PPE information on this page under the heading Personal protective equipment
• making alcohol-based hand sanitiser available throughout the workplace, including for employees to use after disposing of waste
• providing foot-operated closed bins in appropriate locations for employees to hygienically dispose of waste such as used tissues as soon as possible after use
• where employees' work clothes are washed on site, appropriate procedures should be in place and reviewed to ensure the effectiveness of the procedures
• consider increasing the use of fresh outside air and reducing the use of recirculated air conditioning in common areas

Cleaning hazards

Using flammable or disinfectant cleaning products to spray or wipe down equipment may present additional hazards, especially when used around potential ignition sources.  Flammable cleaning liquids must not be sprayed directly near ignition sources or near open flames. Employers must eliminate or reduce these risks, so far as reasonably practicable.

Shared tools, plant and equipment

Avoid the shared use of tools, plant and equipment wherever possible.

Where it is not possible to eliminate shared use:

• provide cleaning products, for example, alcohol spray or solution, where communal tools, plant and equipment are located
• keep cleaning products with tools, plant and equipment if they move around the factory
• ensure all operators thoroughly wash with soap and water or sanitise their hands before and after every use
• ensure all parts of tools, plant and equipment, for example, buttons, switches, levers, handles and handrails, are wiped down before and after use

The shared use of phones, desks, offices, computers and other devices should also be avoided. Where this is not possible, these items should be regularly disinfected.

Employee hygiene

Ensure all employees practise good hygiene, including by:

• washing hands frequently with soap and water for at least 20 seconds, including before and after eating and going to the toilet
• completely drying hands using paper towel or hand-drying machines following washing of hands
• covering coughs and sneezes with an elbow or a tissue
• avoiding touching the eyes, nose and mouth
• immediately disposing of tissues into a waste bin then washing hands
• using alcohol-based hand sanitisers
• cleaning and disinfecting surfaces and shared equipment after use
• limiting contact with others
• Employers should ensure that washroom facilities for employees have adequate facilities for good hygiene, including clean running water and an adequate supply of soap, water, single-use paper hand towels or hand-drying machines and toilet paper. Facilities must be kept clean, properly stocked and in good working order.

Employers should also provide alcohol-based hand sanitisers containing at least 60% alcohol if soap and water are not immediately available. Place hand sanitiser in multiple locations to encourage hand hygiene. If possible, choose touch-free hand sanitiser stations.

Employers should also consider other ways to promote personal hygiene, such as:

• building additional short breaks into staff schedules to increase the frequency that staff can wash their hands
• extending currently rostered breaks to allow employees to follow proper hygiene procedures
• providing tissues and no-touch trash receptacles, for example, foot pedal-operated rubbish bins, for employees to use
• educating employees that cigarettes and smokeless tobacco use can lead to increased contact between potentially contaminated hands and mouths, and that avoiding these products may reduce the risk of infection
• educating employees not to share items such as drink bottles or cigarettes
• reducing the number of touch points for employees, for example, by leaving access doors open where appropriate

Employers should educate employees to avoid touching their faces, including their eyes, nose and mouth, particularly until after they have thoroughly washed their hands upon completing work and after removing PPE.

Personal protective equipment

Employers are required to comply with Pandemic Orders in relation to PPE. These Pandemic Orders may be updated at any time. You must stay up to date with any changes.

Where face masks are required to be worn or carried under Pandemic Orders made by the Victorian Minister for Health, employers must take reasonable steps to ensure employees carry or wear a face mask as required while at work.

Where the work or task requires the use of specific types of face masks in the workplace, the employer must provide these masks.

Employees may already wear respiratory protective equipment (RPE) to control risks associated with their work. Where employees wear RPE, the employer must conduct a risk assessment to ensure the level of RPE provided controls the risks associated with their work, including the risk of exposure to COVID-19.

Appropriate face masks include respirators that meet the Australian/New Zealand Standard on Respiratory protective devices (AS/NZS 1716:2012) or its equivalent and surgical masks, noting that surgical masks would be adequate and that respirators should be primarily reserved for specialist healthcare procedures.

Where PPE such as face masks is relied on as a control measure:

• employers must ensure adequate PPE is available on site and within easy access
• appropriate training on the wearing, removal and maintenance of the PPE needs to be provided, along with supervision to ensure it is appropriately used
• disposable face masks should be disposed of after every break
• non-disposable face masks need to be appropriately cleaned and stored when not in use
• protective eyewear that is reusable must be appropriately cleaned after each use

Deliveries, contractors and visitors attending the workplace

• Consider installing entrance signs which state all visitors require appointments.
• Consider using security measures such as locked gates to restrict unauthorised entry to the site.
• Minimise the number of employees attending to deliveries and contractors as much as possible.
• Delivery drivers and other contractors who need to attend the workplace to provide maintenance or repair services or perform other essential activities should receive clear instructions of requirements while they are on site.
• Ensure handwashing facilities or, if not possible, alcohol-based hand sanitisers are readily available for employees physically handling deliveries and for those people coming onto the site.
• Instruct visiting delivery drivers and contractors to remain in vehicles and use contactless methods such as mobile phones to communicate with employees wherever possible.
• Instruct visiting delivery drivers and contractors to use alcohol-based hand sanitiser before handling deliveries.
• Use, and ask delivery drivers and contractors to use, electronic paperwork where possible to minimise physical interaction. Where possible, set up alternatives to requiring signatures. For instance, see whether a confirmation email or a photo of the loaded or unloaded goods can be accepted as proof of delivery or collection, as applicable.
• Employers should ask contractors and labour hire businesses to provide copies of their COVID-19 management plans. This may provide employers with information about contract and labour hire employees' knowledge and awareness of COVID-19, hygiene measures and ways to prevent the virus from spreading.

Communication and employee welfare

Employers must consult with employees and any HSRs on matters related to health or safety that directly affect, or are likely to directly affect them, so far as reasonably practicable. Employers should also:

• maintain regular and ongoing communication with employees on how COVID-19 is being controlled at the workplace and what controls are being put in place
• provide information to employees in a format that they can readily understand, for example, in their own language, and in multiple formats, for example, email, posters and verbal, including employees on leave, contractors and casual employees
• ensure there are contingency plans in place for staff replacement when necessary
• provide documented information to family, potential visitors, labour hire staff, contractors and others

What to do if an employee has COVID-19

Employers should establish a response plan and procedure for suspected and confirmed cases, which should include the following:

1. Consultation and communication arrangements with employees and contractors, including making sure contact details are up to date, including, for example, visitors, labour hire employees and contractors.
2. Maintain workplace record keeping and tracing information.
3. Identify site locations for cleaning and disinfection.
4. Implement an appropriate cleaning and disinfection regime, which should be overseen by a competent person, for example, an occupational hygienist.
5. The competent person should advise that the cleaning and disinfection regime has occurred for re-entry to the affected areas.
6. Provide employees and contractors with relevant information prior to re-entering the site and resuming work.
7. Review and revise systems to ensure risks are effectively controlled, in consultation with employees and HSRs.
8. Review and improve security measures as required.

In the event of a confirmed COVID-19 case at the workplace, Pandemic Orders made by the Victorian Minister for Health may also require employers to take specific response actions.

Legal duties

Employers have duties under the OHS Act, which include that they must, so far as is reasonably practicable:

• provide and maintain a working environment that is safe and without risks to the health of employees and independent contractors
• provide adequate facilities for the welfare of employees and independent contractors
• provide such information, instruction, training or supervision to employees and independent contractors as is necessary to enable those persons to perform their work in a way that is safe and without risks to health
• monitor the health of their employees
• monitor conditions at any workplace under the employer's management and control
• provide information concerning health and safety to employees, including, where appropriate, in languages other than English
• ensure that persons other than employees of the employer are not exposed to risks to their health or safety arising from the conduct of the undertaking of the employer
• consult with employees and any HSRs on matters related to health or safety that directly affect or are likely to directly affect them
• provide documented information to family, potential visitors, labour hire, contractors

A person with management or control of a workplace must ensure, so far as reasonably practicable, that the workplace and the means of entering and leaving it are safe and without risks to health.

Employees

Employees also have duties under the OHS Act, which includes that they must:

• take reasonable care for their own health and safety
• take reasonable care for the health and safety of persons who may be affected by the employee's acts or omissions at a workplace
• cooperate with their employer with respect to any action taken by the employer to comply with a requirement imposed by or under the OHS Act

The OHS Act gives HSRs a role in raising and resolving any OHS issues with their employer, and powers to take issues further if necessary. For more information see WorkSafe's guidance on powers for HSRs.