The Health and Safety Executive (HSE) published an Education eBulletin on 4 September announcing its intention that, alongside businesses, it will be carrying out spot checks on schools, writes Hayley Dunn.
Spot checks will be in the form of a phone call to review measures taken for reopening to “minimise the spread of the virus causing COVID-19”. Where the call raises concerns about a school’s approach, the bulletin advises the case “will be referred for a further intervention which may include a visit to the school”.
We have been seeking to clarify the requirements, and asking questions to gather a better understanding and to look at the impact of yet another accountability process for schools.
We asked what it is including in the checks? Whether any documentation is required to be submitted? What happens if schools ‘fail’ a check? How are the checks going? How do call recipients know the caller is legitimate?
Here is what we know.
From our understanding there are two assurance processes planned which are already well underway in Scotland (began on 11 August) and in the initial stage in England and Wales (began on 7 September).
The initial stage is the ‘spot check’, whereby the HSE has a call centre undertaking telephone interviews with the most appropriate person in school. The individuals making the calls are not experts in health and safety, and therefore for the most part must be working to a script. The responses are triaged and where there are concerns about assurance an assessment is made.
The issue of how HSE representatives and inspectors identify themselves is vitally important in order to enable schools to verify they are who they say they are. There are many scams and cold calls happening and some of them are very plausible. We have raised this with HSE and been assured that processes are being put in place.
The next stage will be pre-arranged onsite visits made by HSE inspectors. These will be individuals who are health and safety experts, but not necessarily education sector specific experts.
Their aim is to inspect a wide demographic of schools, which will include some of those where a spot check has raised concerns, but others too. It is important that schools engage in the process as the HSE continues to have responsibility under the regulatory framework to ensure that employers abide by the Health and Safety at Work Act.
They will be looking for assurances around social distancing, cleaning measures and regimes, and awareness and adherence to public health guidance.
Their eBulletin specifically mentions the following Government guidance:
Guidance on preparing for the start of the new school term in August 2020 (Scotland)
DfE Guidance for full opening – Schools (England),
Operational guidance for schools and settings from the autumn term (Wales)
It also mentions the control measures required under health and safety legislation, and guidance for school science and technology activities, provided by SSERC (Scotland) and CLEAPSS (Wales and England).
It is fair to say that HSE is expecting there will be interpretation of the guidance and that there will be site specific solutions. Many school buildings are different to those where other industries are employed; many do not have new buildings with air maintenance systems and lots of additional unused space.
Whether you are talking with the call centre or an inspector be prepared to clearly state the measures and risk reduction strategies you are using. Talk about them in your specific context as influenced by building layouts, activities undertaken, support needed, pupil numbers, demonstrating a risk minimisation approach.
As long as the HSE process is undertaken in an effective and supportive way, providing advice and assistance when schools have questions, we are sure it will be welcomed by the sector.
More widely, however, the safety measures in schools must be backed up with an effective test and trace system and access to public health advice. In many areas, these services are completely overwhelmed.