It’s important that you continue thinking about how to minimise the risk of COVID-19 transmission at work. These prompts are general and apply for all businesses and services.
The answers to the prompts may change depending on the traffic light level for your area, your circumstances, and the nature of your business. They may not cover all areas of your work.
Your industry may have prepared guidance to help you operate safely. Check with your industry association or peak body for specific guidance.
The COVID-19 protection framework
The traffic light system (COVID-19 Protection Framework) sets the public health requirements for managing the risk of COVID-19 transmission. It identifies the controls you need to use to minimise the risk for your workers, volunteers, and other people affected by the work, such as customers. When thinking about what working under the traffic light system means for how you operate, you need to consider how you will implement the public health requirements it includes.
Meeting the Health and Safety at Work Act 2015 (HSWA) requirements as well as the COVID Protection Framework requirements
We want to emphasise the important of engaging with your workers and their representatives about how to manage the risk of COVID-19 transmission. HSWA requires you to engage with workers and their representatives on matters that relate to their health and safety. Learn more about worker engagement.
You should encourage your workers to tell you if they are ‘at risk’ or immunocompromised against COVID-19. It’s up to workers to decide if they want to do so. You can find out more in this advice from the Ministry of Health(external link). You must meet the Privacy Act’s requirements for any personal information collected(external link) when you check with workers or others.
There are a range of reasons why workers may come to work despite being told they should stay home if unwell. It’s important to have open communication with workers to understand why they want to be at work.
Some businesses and services may still choose to use alternative ways of working, including working from home. You should continue to ensure that workers who are working remotely can do so safely.
Links to more information
Masks and PPE requirements under HSWA
Wear a mask | Unite against COVID-19(external link) has the latest information about mask requirements under COVID-19 legislation.
Depending on the traffic light setting, workers, customers, and visitors may need to wear a face covering in certain situations. Some workers may be required to wear specific types of face coverings, depending on the work they do. Making sure workers have face coverings and wear them when required also helps you meet your HSWA primary duty of care.
You can require face coverings to be worn on your premises as a condition of entry even though you are not obliged to ensure members of the public comply with face covering rules. As with any health and safety matter, we expect you to engage with workers to conduct a thorough risk assessment to work out what’s best for your work.
You will also need to ensure you have a suitable arrangement in place for accommodating people who cannot wear face coverings for legitimate reasons. You may want to consider the rights of affected people when thinking about face coverings and access to businesses. Guidance is available on the Human Rights Commission’s dedicated COVID-19 website page(external link).
You should consider how you will mitigate the risk of violence or aggression toward workers in any risk assessment you carry out related to such a decision.
The latest general guidance on masks for business and services can be found at the Business.govt.nz page on face coverings(external link).
Face coverings worn for infection prevention and control in health and disability settings are Personal Protective Equipment (PPE). For PPE requirements, including advice on how to use masks, see the Ministry of Health’s page on masks(external link).
Links to more information:
Managing exposure or suspected exposure to COVID-19
You should have a plan for what to do if there is an exposure or suspected exposure to COVID in your workplace.
You should familiarise yourself with how testing, isolation, and contact tracing requirements change under the traffic light system(external link) and the Government’s plan to deal with Omicron in the community.(external link)
Your workers may be exposed in places outside of work. Think about how your business may be affected if key staff are unwell or must isolate. If you have critical roles that must be performed by qualified or otherwise specialist staff, then think about how you will manage these in the event of an exposure. Having a plan for business continuity will help you manage the effects of disruption to your business or service and the effects on staff.
Links to more information
Notifying WorkSafe about work-related COVID infections
Because most cases are unlikely to be related to work, such as infection through family or community contact, most businesses and services do not need to tell us about COVID-19 infections. However, you must notify us (as a HSWA notifiable event) of any COVID-19 infection you are aware of where the carrying out of work is a significant contributing factor to the infection, including an infection attributable to carrying out work:
- with COVID-19 as a micro-organism; or
- that involves providing treatment or care to people who are known to have or likely to have COVID-19; or
- that involves contact with human blood or bodily substances where COVID-19 is known to be or likely to be present; or
- involves handling or contact with animals or animal products (including fish and marine mammals) where there is a known risk of COVID-19.
Employer vaccine requirements
Checking to see if your work processes and risk controls are effective
A change in traffic light levels may require different ways of working, and things may not always go to plan. You and your workers will need to be prepared to learn and adapt to find the best ways to maintain physical distancing, and good hygiene and cleaning practices.
To make sure you can learn and adapt quickly, engage with your workers to find ways for them to let you know about what’s working, what’s not, and how things could be improved. You need to have good processes in place, which encourage workers to engage in work health and safety matters. Do not assume that workers will come to you with feedback. Make sure to ask them if what you are doing is working.
Many businesses and services will already have effective incident reporting approaches that can be adapted to assess how well their COVID-19 controls are doing. If you don’t have an incident reporting approach, or your usual practices aren’t right for these circumstances, you’ll need a way to find out if your COVID-19 controls are working.
You might like to consider:
- the best way to engage with workers and their representatives – ask them how they would like to engage on decisions and provide feedback, and remember it may not be possible for them to complete forms or attend meetings outside of work
- scheduling regular times to review your COVID-19 controls and their effectiveness
- how you’ll communicate changes to processes and make sure all workers know about the changes and are trained to implement them
- how you might use health and safety representatives to evaluate the COVID-19 controls’ implementation.
Changes to how you work may impact the risks of the work you do
Changes to work procedures or practices may affect the way you’ve routinely managed the risks that arise from your work. For example, you may have controlled the risk of lifting heavy items by having two people involved, and now only one person is available to do the task.
It’s also possible the new procedures you put in place bring new risks or challenges you’ve not had to think about before. For example, if you are planning to introduce shift rotations, you’ll need to work out how to manage the risks that come from that.
You must engage with workers and worker representatives to either eliminate or else minimise new risks created by the changes you implement.
Links to more information
COVID safety plan templates
You may like to use our template to develop plans for your sites. By writing down your approach it can be shared with others, including customers or clients. This will also make it easier to regularly review and update your approach, including when traffic light levels change.