Of all the areas of confusion surrounding the coronavirus pandemic, the use of face coverings must surely rank as one of the most prominent: from early shortages in the UK, to fierce debate about their effectiveness, and even Donald Trump recently changing tune from vehemently against, to encouraging their use.
Now, as of 24 July, they are mandatory for customers in shops in England (this was already the case in Scotland). This follows an earlier decision to make them compulsory for passengers on public transport. But the new order does not extend to people working in shops.
So let’s take a look at the government advice on when face coverings should and shouldn’t form part of your health and safety obligations to staff, and the reasons why.
What is a face covering?
A face covering protecting against the spread of COVID-19 outside of clinical settings is not regarded as personal protective equipment (PPE). It can be as simple as a bandana or scarf, although many in use have the appearance of a surgical mask. You are even allowed to make your own at home. To be acceptable, face coverings must cover the mouth and nose and fit securely around the side of the face.
Such face coverings are not regarded as PPE in a health and safety context because they are not CE marked or produced to a recognised standard, and are not tested to provide an accepted level of protection for risks at work like those from spray and dust.
So how do face coverings help?
Face coverings are thought to help prevent the wearer spreading germs to those around them, rather than helping the wearer directly themselves. COVID-19 is primarily spread by infected droplets emitted when coughing, sneezing and even talking. They can be inhaled by others, or land on surfaces. When this happens, people unknowingly touch them and go on to touch their mouth, nose or eyes (which it is human nature to do frequently) to complete the transmission.
The government and World Health Organisation say there is evidence that face covering can lower, although not eliminate, the risk of these droplets spreading. The UK government’s thinking, led by science, is that face coverings offer some benefit when strangers are in proximity with one another, but not when the same people are in frequent contact – such as colleagues in a workplace.
How to protect staff without using face coverings
To protect colleagues from each other, a risk assessment should reveal other measures are more effective: actions like social distancing, shift team rosters, screens and barriers, disciplined hand washing and regular cleaning of surfaces.
When should your employees use face coverings as part of your COVID-secure response?
Of course there are several settings where PPE grade face masks are advised, such as hospitals.
Other industries will already have a separate need for face covering PPE to protect against other risks, and the use of these should continue.
Some employees may make a personal decision to wear a face covering. The Health and Safety Executive recommends that you support them in doing so, if that is their wish. Conversely, there will be times when people are permitted not to use face coverings. In advice to the public the government cites a range of scenarios that align roughly with common sense and equality law. So if someone were speaking to a deaf person who relies on lip reading, it would be acceptable for them to lower their mask.
The UK is blessed with a diverse economy and there may be some businesses who, despite the government steer, do identify that face masks are a necessary mitigation during their risk assessment. Remember though that PPE is a last resort after you have assessed the risks. If PPE face masks are necessary you must supply them as an employer. You must choose them carefully, train your staff in how to use them effectively and have a system for detecting and reporting faults.
Further help
The government advice has evolved as the science dictates. So do keep an eye on their latest guidance. If you want help in preparing or implementing your COVID-19 risk assessment or are just seeking a second opinion, get in touch.
