The return to the office…how to ensure your building is ready
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With the UK government and devolved administrations’ announcements on re-opening looking increasingly positive, now is the time for businesses to start considering what actions are required to get buildings, back in shape.
No formal announcements have been made regarding when those working from home should return to office buildings but the administrations are aligned in their hope that things will return to ‘normal’ this summer.
Consideration should be given to ensuring that risks relating to health and safety are being managed, prior to the return to the many buildings that have been largely or entirely unoccupied during the lockdown period. Assessments and reviews will need to be carried out to ensure changes to buildings required as a result of Covid, are scheduled, so that any necessary work can be completed. We set out below a number of areas that employers, the self-employed and people in control of premises, such as landlords and tenants should consider prior to reopening any building.
Legionella
We previously wrote about the need to manage legionella during lockdown (which can be found here). One year on and the advice remains current: it is essential that when buildings begin to re-open after lockdown that the risks are assessed before water systems are put back into use.
The Legionella Control Association has published guidance with a clear message: simply reopening a building that has stood idle, without addressing the safety of its water system, is unacceptable and is likely to be in breach of the law. If dutyholders are not able to put in place a proper recommissioning process to use the water system safely, they should not reopen the building.
The guidance goes on to consider the requirements for “recommissioning” a water system and what that might entail, as well as the additional legionella risk factors that may need to be considered in the risk assessment process.
Prior to reopening a building it is important to review existing risk assessments to ensure they remain suitable and sufficient. Any changes to the planned occupation of the building going forward, such as reduced use or occupancy should also be taken into consideration as part of the risk assessment process.
Fire safety
For the buildings that were allowed to re-open in 2020, significant control measures were implemented to ensure social distancing. Whilst the respective governments are yet to identify what the return to work road map will look like, it is likely that buildings will open with some residual social distancing and additional hygiene measures in the first instance. Further, it might be expected that there will be increased expectations on the part of the workforce for such measures in the wake of a pandemic, given everyone’s heightened awareness of hygiene and the on-going risks. Overall, the layout of buildings may look different to their previous set-ups and this should have been considered in terms of fire safety.
Fire safety risk assessments should be reviewed to ensure that they remain suitable and sufficient. Fire evacuation plans should be reviewed to ensure that evacuation routes are still accessible and that muster points remain appropriate. Consideration should also be given to the identified fire marshals for the building. Where reduced numbers may return to the office and personnel changes may have occurred, is there a sufficient number of fire marshals in place upon reopening?
It is likely that prior to reopening, fire safety equipment such as fire alarms, sprinkler systems and fire extinguishers will also need re-testing and all maintenance undertaken, which may not have been undertaken during lockdown.
Asbestos
Many buildings have asbestos contaminating material (ACMs) with asbestos management plans in place outlining monitoring and managing requirements. The responsible person should ensure that any necessary inspections or reviews are undertaken to ensure plans are up to date. If additional works are required to ensure the safe management of the material, these may require to be undertaken prior to reopening.
LOLER
Any buildings containing lifting equipment should ensure that lifts are tested and maintained in accordance with the Lifting Operations and Lifting Equipment Regulations. Given the length many buildings have been shut down it is likely that LOLER inspections may be required.
Electrical equipment
As with lifting equipment it may be that electrical testing has not been undertaken whilst a building has been shut down. Consideration should be given to any additional measures required to be taken prior to reopening a building to ensure that the risk from electricity is managed.
First aid
As with fire marshals, consideration should be given as to whether upon reopening, there are a suitable number of first aid trained individuals in the building at any time. Further, thought might be given to the review of first aid boxes, to ensure essential items are in date and complete.
Once again, the advice is to plan ahead to ensure that risks are managed and buildings are available and on schedule for re-opening when authorised to do so. Careful planning and scheduling will likely be essential in order to deal with availability of contractors and materials. As ever, a failure to manage these issues could constitute a breach of health and safety law and dutyholders will be keen to avoid any risks of enforcement action.