Managing the risk of exposure to coronavirus (COVID-19) – a checklist for employers

This checklist is designed as a tool to help employers meet their obligations under the Occupational Health and Safety Act 2004 (OHS Act) and associated regulations regarding risks from coronavirus (COVID-19).

Directions and industry requirements are regularly updated

This guidance is correct as at time of publication, however, Victorian Chief Health Officer (CHO) Directions and industry requirements are regularly updated. Readers of this guidance need to check the latest CHO Directions for applicability.

Restrictions apply across Victoria

Depending on your industry your workplace may:

  • be required to close temporarily for on-site work
  • remain open for on-site work with a completed COVIDSafe Plan in place
  • be subject to restricted operations or industry specific obligations.

It is mandatory for every Victorian business with on-site operations to have a COVIDSafe Plan.

Victoria’s COVIDSafe settings 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 directions issued by the Victorian Chief Health Officer (CHO).

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 CHO directions does not necessarily mean you have complied with your duties under the OHS Act and OHS Regulations.

You must follow any health directions 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.

Checklist background

Employers should use this checklist with WorkSafe's Exposure to coronavirus in workplaces guidance. Employers should also read relevant information and updates from the Department of Health and Human Services (DH), Business Victoria and other appropriate government departments and industry bodies.

Completion of a COVIDSafe plan forms part of a safe system of work to control the risk of employees and other persons contracting COVID-19 at a workplace, however duty holders also have to meet OHS Act obligations. The information in this checklist and the WorkSafe guidance can help employers identify and implement appropriate controls in their workplace.  

Duty holders must also ensure they continue to undertake the required risk assessments and implement appropriate controls for non-coronavirus (COVID-19)-related hazards.

Visit the DH website for the latest information and requirements relating to coronavirus (COVID-19) in Victoria.

Consult with employees

Employers have a duty to consult with employees, independent contractors and any 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.

Employer checklist

Check off each action point in the following checklist. If you are unable to check off a point you should develop and implement measures to address the issue.

Employer duties – identify risk

Employers and employees must comply with the directions currently in force, including the Workplace Directions, Workplace (Additional Industry Obligations) Directions and the Permitted Worker Scheme Directions.

        Information about workplace directions is available on the DHHS website.

          • identifying hazards and making decisions on risk management plans and response plans
          • providing regular updates to employees, HSRs and other representatives on new information and advice
          • making procedures about monitoring the health of employees, such as confirmation of any positive cases and how positive cases will be contact traced and managed
          • resolving health and safety issues
          • providing information, giving opportunity to provide feedback and taking comments into consideration when making decisions
          • proposing changes to the workplace, plant, substances, other things or conduct of work performed
          • An employer (host) must consult with the labour hire agency on occupational health and safety (OHS) matters, including the provision of necessary personal protective equipment (PPE) and relevant points of contact of health and safety between the organisations. Information about the responsibilities of labour hire hosts and labour hire agencies is available on the WorkSafe website.
            • minimising employees working in close contact with other persons for prolonged periods, including no carpooling
            • minimising the use of shared tools
            • cleaning and disinfection of high-touch points and shared spaces
            • supply of PPE
            • supply of personal hygiene supplies – soap, hand sanitiser
            • employee training and awareness of latest coronavirus (COVID-19) information
            • additional cleaning
            • changed work arrangements, for example, reduced workforce, staggered shifts and break times

            Controls

              Physical distancing

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

              Under Directions from the Chief Health Officer, Workplaces may also be required to comply with particular density quotient rules for shared spaces.

              In consultation with employees and independent contractors, employers should develop a plan to ensure physical distancing is maintained. This could include, where reasonably practical, staggering start times and breaks for staff members.

              Where a work premises has a publicly accessible space, employers must display a sign at each public entry to each such space that includes a statement specifying the maximum number of members of the public that may be present in the space at a single time. That maximum is the number permitted by the density quotient, rounded down to the nearest whole number.

                • Identify the roles that can be adapted to be performed from home.
                • Adapt working arrangements to enable working from home.
                • Regularly assess staff in attendance at the workplace to determine whether they are required to be there.

              Under CHO directions, an employer:

              • may allow employees to work from the workplace (in accordance with the Restricted Activities Directions)
                • must allow employees to work from home or another suitable location where it is not reasonably practicable for them to work from the workplace

                  For office work, the direction is that employers:

                  • must allow employees to work from the workplace where it is not reasonably practicable for them to work from home or another suitable location
                    • must not require employees to work from the workplace if it is reasonably practicable for them to work from home or another suitable location
                      • may allow employees to attend the workplace in accordance with the requirements of the COVIDSafe Plan for that work premises

                        Whether working from home is reasonably practicable depends on the specifics of the workplace, the facilities available for employees to work remotely and the ability for employees to do their work safely from home. Employers should consult with employees and HSRs about whether working from home is an appropriate arrangement, including at an individual employee level.

                            • Rearrange, remove or cordon off furniture in common areas to ensure physical distancing, stagger seating so staff are not facing one another on break.
                            • Consider signs or posters to reflect the maximum number of people permitted in each area (i.e. 1 person per 4sqm or 1 person per 2sqm). For example, room size of 10m x 6m = 60sqm. 60sq ÷ 4sqm = maximum of 15 people. Provide signs in languages other than English where required.
                            • Identify areas that require floor marking, such as lifts, kitchen areas, printer collection areas.
                              • Where required, communicate the requirement for employees not to work across multiple sites, except where unavoidable, for example, healthcare workers.
                              • Adjust rosters and develop procedures to ensure employees do not work across multiple sites.
                              • If a worker is working across more than one work site for two or more different employers the worker must provide a written declaration to each employer to advise that the worker is working at more than one premises and must provide details of the other premises to each employer.
                              • Employers must maintain a record of all workers who have disclosed that they are working across more than one premises.
                              • Identify which workstations need to be modified.
                              • Reconfigure workstations so employees do not face one another.
                              • Ensure workstations are adequately spaced from each other, including the implementation of shields or barriers where appropriate.
                              • Stagger start and finish times, shifts and break times to reduce use of common areas at the same time.
                              • Encourage staff to minimise time on breaks in shared facilities with others.
                              • Consider cohorts of employees during shift work. Ensure there is no mixing of staff across different shifts.
                                • Establish contactless delivery or invoicing.
                                • Record keeping of any visitors to the premises for more than 15 minutes, including name, contact number, date and time of delivery, and the area of the premises that the person attended.
                                • Display signs for delivery drivers.
                                • Identify designated drop off areas.
                                • Provide separate waiting areas and amenities for delivery drivers.
                                • Develop a sign in system for delivery drivers to aide contact tracing.

                              Personal protective equipment

                              Where face masks are required to be worn under Victorian Chief Health Officer directions, employers must take reasonable steps to ensure that employees wear a face mask while at work.

                              For more information see the guidance Managing coronavirus (COVID-19) risks: Face masks in workplaces.

                                • Perform a risk assessment to determine the most appropriate face mask, based on task and guidance available.
                                • Provide policies and procedures in relation to the use of face masks in the workplace.
                                • Provide information, instruction and training in the safe use of face masks within the workplace.
                                • Consult with employees and HSRs on how face masks are implemented within the workplace.

                                Note: Respirators with exhalation valves do not prevent coronavirus (COVID-19) being breathed out by a wearer who is infected with the virus. This type of respirator may not be effective for source control. Therefore respirators without exhalation valves should be worn in workplaces for the purpose of preventing transmission of the virus from a wearer who is infected with the virus.

                                The following face masks are suitable for preventing droplet transmission only:

                                • P1 disposable respirators
                                  • surgical masks
                                    • Note: There are Therapeutic Goods Administration-approved face masks for use in healthcare settings. Face masks are graded as level 1, 2 or 3 based on the level of protection provided, or fluid resistance. All levels are suitable for preventing droplet transmission but Level 1 does not include protection against risk of blood or bodily fluid splash.
                                  • single-use face masks – refer to DH website
                                    • Where employers are providing disposable masks for employees, they should, so far as reasonably practicable, provide regular replacement masks, particularly in dirty production environments.
                                  • cloth masks – refer to DH website
                                    • Where employers are providing cloth face masks, there needs to be a procedure for laundering the face masks.

                                  Other PPE

                                      • Note: Washing hands with soap and water is one of the best defences to prevent the spread of coronavirus (COVID-19). Gloves have other purposes, such as, for example, being required for handling hazardous substances and medical gloves used in health care. If gloves are not used appropriately, a person can transfer contaminants to other objects or their face if they do not replace and dispose of or clean their gloves between tasks. Gloves are not a substitute for the promotion of frequent hand hygiene and the provision of handwash stations. Complacency while wearing gloves can reduce hand hygiene.
                                      • for example, surgical gowns in health care

                                    Cleaning and disinfection

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

                                      • Increase environmental cleaning, including between changes of rostered shifts.

                                        Hygiene practices

                                                        Training, instruction and information

                                                            • Develop and educate staff on strategies and work practice changes to maintain physical distancing.
                                                            • Reinforce messaging to staff that physical distancing needs to be maintained during work and during social interactions.

                                                                  Screening and illness plan

                                                                          • free of coronavirus (COVID-19)-related symptoms
                                                                          • have not been in contact with a confirmed case
                                                                          • have not been directed to self-isolate or self-quarantine by an Authorised Officer

                                                                        Information on Workplace (Additional Industry Obligations) Directions, including which industries are subject to the directions, is available from the DH website.

                                                                          • Review processes to maintain up-to-date contact details for all staff.
                                                                          • Provide information on protocols for collecting and storing information.

                                                                            Site mapping

                                                                              • date and time work was done
                                                                              • employees who worked together
                                                                              • specific work areas at the workplace
                                                                              • any breaks taken, including time and location
                                                                              • movement between multiple workplace locations

                                                                              Consider:

                                                                                  *Congregate setting — a setting in which a group of persons reside, meet or gather, either for a limited or extended period of time in close physical proximity.  Examples include prisons, nursing homes, schools and workplaces, including food processing lines and meat and poultry processing facilities that could result in higher risk for coronavirus (COVID-19) transmission.

                                                                                  Confirmation of positive coronavirus (COVID-19) case

                                                                                  In the event of a confirmed coronavirus (COVID-19) case at the workplace, Directions from the Chief Health Officer may also require that employers take specific response actions.

                                                                                  Following the identification of a suspected or confirmed case, employers should ensure appropriate communication to staff, contractors, visitors and customers, including:

                                                                                          Actions to be undertaken by employers in response to identification of positive cases

                                                                                          A confirmed case is defined as a person who has returned a positive coronavirus (COVID-19) test as per DH guidelines. Employees must disclose to their employer as soon as possible, after they receive notification that they have tested positive for coronavirus (COVID-19) and they attended the workplace in the infectious period, typically 48 hours prior to symptom onset.

                                                                                                    • Consider a cleaning plan that captures cleaning schedules, who has performed the cleaning, products used and the areas cleaned.

                                                                                                  Note: DH has 'Outbreak Squads' which may be deployed to a workplace to oversee cleaning and disinfecting and provide advice on infection control measures. The decision to deploy these squads is made on a case by case basis.

                                                                                                        Records from the period of 48 hours prior to the onset of symptoms in the suspected case that include all rosters and employee details, along with customers, clients, visitors and workplace inspectors will assist in contact tracing following confirmation of a positive case.

                                                                                                        Note: All close contacts will be contacted by the DH and will be required to quarantine for 14 days post most recent exposure to the case while infectious. Refer to DH website for information regarding quarantine requirements.

                                                                                                        References

                                                                                                        Further information