Employers, or persons conducting a business or undertaking (PCBU), have a duty under work health and safety (WHS) legislation to eliminate or, if that is not reasonably practicable, minimise the risks of COVID-19 at the workplace so far as is reasonably practicable.
In addition to your obligations under the WHS legislation, you must also comply with any public health orders issued by the WA Department of Health.
This guidance is intended to assist PCBUs in Western Australia to manage these risks to reduce exposure to the COVID-19 hazard.
PCBUs must consult with workers on work health and safety issues, including reducing the risks from COVID-19 in the workplace. See Work health and safety consultation, cooperation and coordination: Code of practice
Risks should be managed with regard to the hierarchy of control measures (Figure 1), which identifies the types of controls that are generally more effective. A combination of control measures is typically required to minimise the risks of COVID-19.
Hierarchy of control
Table 1 provides examples of control measures for COVID-19 using the hierarchy of controls. It should be noted that control measures are selected based on the risks at the workplace, so not all workplaces require the same control measures.
Workplace controls are selected based on the specific risks and take into consideration the practicability of implementing specific control measures. It should be noted that not all control measures are reasonably practicable in all circumstances; for example, there may be supply issues around accessing a particular control which mean that it is not practicable to obtain it for a period of time. There is a requirement to regularly review your control measures as the practicability and effectiveness of controls may change over time.
Note: Guidance on the practicability of controls is available in the How to manage work health and safety risks: Code of practice.
Examples of control measures
Table 2 Examples of control measures
Category | Example control measures |
Elimination |
Physically remove the hazard It may not be practicable to eliminate the risk of COVID-19 in the workplace at times of significant community transmission. |
Isolation |
Isolate the hazard from people
It is unlikely to be practicable to require visitors to undertake a RAT.
|
Engineering controls |
Physical controls
|
Administrative controls | Change the way work is done |
Effective policies and procedures |
Designate someone to lead the management of COVID-19 risks at the workplace. Regularly review procedures as new or updated guidance or new control measures become available. In higher risk workplaces (eg hospitals, ports), designate workplace zones based on risk, and ensure appropriate controls are used in each zone. Develop a vaccination policy for workers and visitors if required based on risk. Implement procedures in relation to a good standard of cleaning. Implement policies and procedures on training requirements, based on risk. Ensure appropriate information is provided to external clients, visitors and other stakeholders who interact with the workplace. This may be via signage, email, advertising or other communication methods. Implement a policy on not attending work when unwell. Such policies are more successful when supported by suitable pay and leave arrangements. Implement a requirement for workers to notify the PCBU immediately if they:
Implement a plan for managing a positive case at the workplace. Implement a plan for a workplace outbreak. Implement a policy in relation to proactively testing workers in higher risk situations; e.g. prior to and after higher risk travel, before attending a vulnerable location/workplace, where the worker conducts high risk work tasks (such as caring for or working with COVID-19 positive people), or where there are other individual risk factors. If you, as a PCBU, determine that the use of RAT is required to implement a safe system of work, you need to supply the RAT kits. |
Manage infection risks |
Keep COVID-19 positive and other patients or residents separate. Manage visitors, clients and other external people based on risk. Provide hand hygiene facilities and supplies and consider supplying masks where appropriate based on risk. Provide information to workers and others about safe mask use, mask handling and disposal, hygiene measures and physical distancing. Maintain physical distancing and provide information to people at the workplace on this requirement. This may include floor marking, signs or other communication. It should also include a review of the maximum capacity for meeting rooms and lunch rooms. |
Manage cases in the workplace |
The PCBU’s response to COVID-19 cases in the workplace should include:
|
Manage work related psychosocial hazards |
|
Personal protective equipment (PPE) | Protect workers by providing PPE and supporting its safe use |
Risk assessment |
Conduct a risk assessment of different workers’ requirements, based around the tasks that they undertake, the potential for exposure, duration of higher risk tasks, other risk factors such as locations worked, and the controls currently in place. Use the risk assessment to identify PPE requirements. You may need to review this frequently as circumstances change; e.g. the local rates of community transmission increase or decrease. |
Respiratory protection program |
Where respiratory protective equipment (RPE) is required to protect workers from airborne hazards, PCBUs should have a respiratory protection program in place. Training on the use and limitations of respirators must also be provided in workplaces using this control. More information on respiratory protection programs can be found in the Australian/New Zealand Standard AS/NZS 1715:2009 Selection, use and maintenance of respiratory protective equipment. |
Disposable P2/N95 respirators |
For higher risk work, a P2/N95 respirator (or higher) should be selected where reasonably practicable. Guidance on buying P2/95 masks is available from the Australian Institute of Occupational Hygienists (AIOH). The respirator should be appropriate for the task, the correct size and fit-tested before use. These respirators also need to be put on and taken off correctly, and user seal checked (fit checked) before each use. Further guidance on the respirator removal is here. P2/N95 respirators that have unfiltered exhalation valves or vents do not protect others in the vicinity of the wearer as aerosols may be exhaled. If it is not reasonably practicable to undertake fit testing prior to use, workers must do the following every time an N95/P2 respirator is worn:
Manufacturer’s instructions typically advise to replace P2/N95 respirators after each use, and other guidance indicates they should be discarded when they are dirty, damaged, or difficult to breathe through. |
Re-usable (elastomeric) respirators |
Half-face or full-face tight-fitting respirators consist of face pieces made of synthetic or natural rubber material. These respirators can be repeatedly used after appropriate cleaning, disinfection, storage and changing the replacement cartridges according to the manufacturer’s instructions. Some types of non-disposable half- or full-face respirators offer higher protection than disposable P2/N95 respirators provided they are used correctly, including-fit testing. Reusable respirators also have adjustable straps that may accommodate a better fit. Re-usable respirators that have unfiltered exhalation valves or vents do not protect others in the vicinity of the wearer as aerosols may be exhaled. |
Powered air-purifying respirators |
A PAPR is a battery-powered device that provides filtered air under positive pressure into either a loose-fitting hood or helmet or a tight-fitting face piece. Because the filtered air is delivered under positive pressure, the device can compensate for an imperfect seal. For this reason, a PAPR is regarded as potentially providing a higher level of protection than other RPE. PAPRs with loose-fitting hoods do not need to be fit-tested and they can be used by workers who cannot achieve an acceptable seal due to facial hair or other reasons. PAPRs are often reported to be more comfortable than other forms of RPE. |
Other PPE | Other required PPE may include safety glasses, goggles, face shields, long-sleeved gowns, surgical masks and gloves. |
Notifying WorkSafe of COVID-19 cases
Under the WHS Act, PCBUs must notify WorkSafe when it is confirmed that a person has contracted COVID-19 through carrying out work and:
- the person dies
- the person is required to have treatment as an in-patient in a hospital
- the person contracted COVID-19 while carrying out work that involves providing treatment or care to a person; or involves contact with human blood or body substances. In this case, the carrying out of work must be a significant contributing factor to the infection being contracted.
For mining operations, positive COVID-19 cases could cause serious harm to a person and reporting is required in accordance with r. 5 and r. 675V of the WHS Mines Regulations. To assist in determining if a COVID-19 case (or any other infectious disease) is reportable, then the following criteria should be considered:
- does the person require medical treatment on site?
- is the person unable or unlikely to do their normal duties for 10 or more days?
If any of these interventions are required then it is likely that serious harm could have occurred and the case should be reported.
There is no longer a requirement to report positive asymptomatic or close contact cases in isolation to the regulator.
There still exists an obligation to report confirmed cases to the lead agency, the Deparment of Health.
Further information
Department of Health
WA Government
Safe Work Australia
Department of Health (Australian Commonwealth)