6th April 2020

New Building Occupancy Guidance During COVID-19

Introduction

During the current Coronavirus pandemic, many organisations have implemented systems to allow the majority, if not all, of their employees to work from home.  This is a sensible measure assisting with social distancing and allowing flexibility to those self-isolating in line with current guidelines. A lack of footfall through the doors does, however, pose several questions of how to manage the facility in the absence of its normal day to day usage. 

Statutory Inspections

All statutory inspections and tests such as ‘LOLER’ thorough examination and inspections on lifting equipment used to lift loads or people e.g. passenger lifts should continue to be undertaken. Also, thorough examinations and inspections of pressure vessels in accordance with a written scheme, along with 5-year fixed wiring inspections on electrical installations should continue to be undertaken.  

This requirement of statutory inspections brought under the HSWA has been confirmed by the Health & Safety Executive (HSE) recently with them stating that they are ‘not considering issuing exemptions or relaxation of these requirements, but we recognise this is a fluid situation and this position is constantly under review’.

Organisations also need to ensure the resource of competent persons to operate safety-critical machineries such as lifting equipment (including cranes and forklift trucks) and pressure vessels (including industrial boilers) is maintained. 

Fire Alarms, Emergency Lighting and Air Conditioning Systems

Additional measures for systems such as fire alarm sounder tests, emergency lighting tests and air conditioning systems maintenance are not essential in a temporarily vacant building. They are there for the safety and comfort of the building’s occupants and if the building or unit is unoccupied, there is no need for ongoing maintenance to be carried out when the property is unoccupied. 

You should, however, ensure that before re-occupation, all previous maintenance and inspection regimes are resumed so that facilities systems can be confirmed to be functioning correctly to maintain good safety and hygiene practices in general.  

Just as a side note, current research from World Health Organisation indicates that COVID -19 does not readily transfer through air conditioning system and sights infections not passing readily passing from ward to ward in hospitals as evidence.

What about Water Systems..?

Water systems pose a slightly different conundrum as Legionella bacteria thrive in stagnant water. Naturally, buildings that are temporarily unoccupied will no longer be benefiting from regular toilet flushes and tap and shower usage which gives rise to standing water and bacteria developing in the system.  

Where water systems are mains fed there are a couple of options available to duty holders as follows:

1. To ensure that water systems retain an element of flow and stop stagnant water encouraging the development of Legionella bacteria, all little-used outlets in systems including toilets, taps and showers should be used at least once weekly.
   • Usage would include:
     • A single flush on a toilet
     • A one minute run for all taps (including water heaters) and showerheads 

2. Alternatively, all water systems can be left stagnant with no use throughout the unoccupied period if required, but this would necessitate engaging a water treatment suitable contractor chlorinate the entire system before re-occupation. 

Where water systems are more complex and involve water storage tanks/vessels etc, we would encourage the continuation of all existing control measures detailed in the Written Scheme of Maintenance. It is critical that high-risk premises such as those with cooling towers or evaporating condensers continue to maintain their controls stated in the Written Scheme of Maintenance. Companies also need to ensure that there continue to be a competent person to manage the risk from legionella on-premises to cover times of absence. 

Cleaners

Clearly, if buildings and units are unoccupied then the requirement for daily bin emptying and general cleaning will not be as great. It is at the discretion of the organisation as to whether cleaning contractors are asked to continue, operate a reduced rota or cease altogether. 

It is however vital that before reoccupation, a deep clean of all facilities including workstations, corridors, meeting rooms, canteens and toilets is undertaken to assist in the prevention of the spread of the Coronavirus. 

Buildings with ‘Skeleton’ staffing

Organisations who are not operating a strict working from home policy and are continuing to allow employees to access their buildings in any way will retain all obligations to upkeep their facilities, including the continuation of fire alarm/detection/emergency lighting checks and air conditioning systems maintenance. 

Cleaning regimes should also remain appropriate for the building’s usage. 

Contractors on site

Specialist contractors will inevitably need to access sites which may have implemented a strict no visitor policy during the crisis. In this situation, we would advise the contractors to demonstrate their COVIS-19 control measures within the accompanying RAMS for their intended work. It is also suggested the companies policies and procedures on infection control and social distancing be clearly communicated at site induction before any works commencing. 

Enforcement Action

It is worth noting that in the aftermath of the Coronavirus Pandemic, Enforcing Authorities may well consider investigating those workplaces considered to have significantly contributed to an outbreak by not following government guidance i.e. allowing social distancing/maintaining clean workplaces under the provisions brought by Sections 2 and 3 of the Health & Safety At Work Act 1974 and other statutory instruments.  

Organisations must continue to be mindful of their obligations to document the significant findings of their risk assessments when employing 5 or more persons, this includes the provision for COVID control. 

Our health and safety advice line remains available at all times to clients with any queries. Call us on 0845 459 1724.