COVID-19 Risk Assessment

This will result in multiple individuals (partners, associates and staff) becoming infected and possibly seriously or fatally ill

Vulnerable workers could be worst affected^[1]

Fee earners and staff (where possible) to work from home

Already implemented- in consultation with partners/ heads of department fee earners take individual responsibility to work from home, and to liaise with support staff over them home working.

Take steps to review work schedules including start and finish times/shift patterns, to reduce the number of people on site at any one time

Already implemented - All offices exercise strict social distancing. To be kept under review as more staff return to work on site.

Set an upper occupancy limit of X% for our offices at any time

Not necessary at the moment for each site.

Strict no sharing any workstation rule already implemented. To be kept under review.

Desks removed (or desks sealed with tape) to encourage physical distancing

Physical survey of each site to be conducted by COSS and Neil Sumner before end of June. Furniture to be removed, taped off where necessary.

Closure of canteen/communal areas OR putting in place social distancing markers and measures in communal areas including kitchens and canteens

Signage and strict hygiene in kitchens, toilets and by communal photocopiers already implemented. Cleaning and hygiene products available. Signage throughout each site.

No one feeling ill will be allowed to come to work

Already implemented and enforced, where necessary

Communication and awareness-raising posters referring to the above measures

Already implemented- signage throughout each site, regular updates and briefings from COSS

Enhanced cleaning regime, including for toilets, pantries and frequent touchpoints such as door handles, light switches, reception area using appropriate cleaning products and methods

Signage and strict hygiene in kitchens, toilets and by communal photocopiers already implemented. Cleaning and hygiene products available. Enhanced cleaning regime in place via contract cleaners.

Hand washing awareness: see the NHS guidance

Already implemented- prominent signage at each site and reminders regularly sent by COSS

Sanitation products (hand sanitiser, cleaning wipes) widely available. Consider providing a ‘cleaning pack’ for staff with hand gel, wipes etc

Already implemented- Hygiene and cleaning products available throughout each site

Reminding everyone of the public health advice through posters, leaflets and other materials made widely and prominently available: see the government guidance

Already implemented- prominent signage at each site and reminders regularly sent by COSS

This will result in multiple individuals (partners, staff, visitors/clients and contractors) becoming infected and possibly seriously or fatally ill

No face-to-face events permitted on site

Implemented initially, now relaxed in favour of strict control of access to site by visitors, use of designated meeting rooms on ground floor by entrance doors, strict social distancing, staff briefed on face to face meetings as per signage, circulars and reminders. Perspex screens have been ordered for reception and meeting rooms.

Face-to-face meetings discouraged with conference calls to be used instead.

Already implemented- staff briefed to use telephone or video calls where possible, face to face meetings are a last resort and are to be kept as short as possible. . Perspex screens have been ordered for reception and meeting rooms.

Upper limit on meeting numbers determined by available room size

To be implemented through physical survey of each site social distancing signage and taping.

Meetings staggered so no congestion possible

Already implemented- central rota for conference room at each site maintained

Seats removed from meeting rooms to ensure physical distancing

Already implemented

Enhanced cleaning regime, including before/between/after each individual meeting

Already implemented- staff briefed through signage, circulars and reminders

Sanitation products (hand sanitiser, cleaning wipes) available inside each meeting room

Already implemented

No catering/refreshments offered inside meeting rooms

Already implemented- staff briefed through signage, circulars and reminders

Pre-meeting notification (if possible) sent to all attendees asking them to stay away if feeling unwell

Already implemented- staff briefed through signage, circulars and reminders to ask any intended visitor if they, or any member of the household, has felt unwell in the previous 14 days

Temperature checks at building entrance will keep away any external attendee with an elevated temperature

Not currently implemented but to be kept under review

Physical distancing in place in reception/waiting area

Physical distancing of furniture already in place, to be enhanced through taping and increased signage by end of June. Strict meeting by appointment only and no waiting polices in place.

X-hour upper limit on meetings strongly advised and communicated  

Already implemented- staff instructed to keep appointments as short as possible

No cloakroom service – visitors should look after their own personal items

Standard practice in any event

This may result in the individual staff member experiencing medical distress on-site and could increase the risk of onward transmission of the virus among other people with whom the individual has been in proximity

If anyone becomes unwell with a new continuous cough, a high temperature or loss of sense of smell in the workplace, they will be sent home and advised to follow the stay at home guidance

Already implemented through signage, circulars, reminders and enforcement when necessary. Staff are instructed to leave immediately; they do not need permission and to report to COSS and a partner thereafter.

Everyone in the relevant office to be informed

As necessary by COSS

Partners and managers to increase the frequency of contact with those they supervise during this time

Partners will challenge staff, and staff to report suspected ill health of a colleague to partner and COSS.

People instructed to work from home

Already implemented- those who can work from home are.

Reemphasise that no-one feeling ill is allowed to come to work

Already implemented through signage, circulars, reminders and enforcement when necessary.

OPTIONAL: Temperature checks at building entrance should prevent anyone with an elevated temperature entering the office

Not currently implemented but to be kept under review

Maintaining up-to-date contact information (including emergency contacts) for all partners and staff

Already implemented, COSS maintains a dashboard with all partners’ and staff contact details, including next of kin. Copied to Management consultant each day for continuity.

Record keeping on who is in and where in the office on a given day to aid potential contact-tracing efforts and processes

Already implemented, COSS maintains a dashboard with absences and the reason recorded. Copied to Management consultant each day for continuity.  Partners receive a daily absence report.

This may result in increased risk of transmission, including to/from clients and visitors

Marketing material (brochures and literature), newspapers and magazines removed from client reception area

Already implemented

Libraries (if applicable) to develop a special protocol for cleaning all books, journals and other publications held in the open

NA

If advised that a member of staff or visitor has developed COVID-19 and was recently on the premises the management team will ask the local public health authority for advice, identify people who have been in contact with them and take on any actions or precautions

Government guidance on test and trace will be implement, followed and enforced.

This may result in increased risk of transmission by handling of objects

Cleaning protocol is in place for all incoming mail and courier packages

Currently staff are advised to wash hands regularly and to take care when handling post.

Glove are available for opening and handling post. To be kept under review.

Staff advised to clean any mail/post items delivered to their desks (wet wipes to be provided)

Currently staff are advised to wash hands regularly and to take care when handling post. Glove are available for opening and handling post. To be kept under review.

This may result from increased stress caused by home-working and the lockdown, potential bereavements, increased caring responsibilities, elevated incidence of anxiety and depression associated with isolation, concerns about personal and family circumstances and job security

Staff members of BAME background may feel more uncomfortable coming back into the office

Signpost to LawCare resources and the Law Society’s mental health resources

Already implemented, COSS set up a WhatsApp noticeboard at early stage to include distributing signposting support services, that continues for staff at work and those furloughed.

Increase volume of guidance materials and resources   available

Already implemented, COSS set up a WhatsApp noticeboard at early stage to include distributing signposting support services, that continues for staff at work and those furloughed.

Raise awareness on any Employee Assistance Programme (EAP) offering access to additional resources and support

Already implemented, COSS set up a WhatsApp noticeboard at early stage to include distributing signposting support services, that continues for staff at work and those furloughed.

Adjust policies around home working and leave-taking to support working parents

All reasonable adjustments and allowances are made for staff with child care commitments. No formal policy, worked on an ad hoc basis with fee earner/ partner as necessary.

Regular internal communications from senior leadership emphasising self-care and regular and inclusive communication. The emphasis should also be on honesty and transparency about the difficulties the firm is facing and how to best manage these together

Already implemented, COSS leads on circulating information to staff, Senior partner follows up to reinforce policies and highlight issues to be addressed when felt appropriate.

Regular communication of mental health information and an open-door policy for those who need additional support

Already implemented, COSS set up a WhatsApp noticeboard at early stage to include distributing signposting support services, that continues for staff at work and those furloughed

Provide assurance over measures taken to protect employees’ health and safety

Already implemented, signage and circulars sent out by COSS

Crowded and unsanitary conditions on public transport services

From 15 June 2020 all users of public transport MUST use masks. That has been communicated to staff by COSS.

All staff on public transport to abide by >2m distancing.

Already implemented.

If staff members need to travel (for example to courts or to do site visits) they should not share vehicles or taxis, unless suitable distancing can be achieved

Applies to few staff. All are fee earners and take personal responsibility for hygiene and PPE.

Narrow spaces in the firm’s carpark or bicycle storage area may elevate the risk of person-to-person transmission

Set a X% of occupancy limit

NA – outdoor car parking at all sites

There is a risk that individuals waiting for extended periods of time at building entrances due to physical distancing and temperature checks experience adverse weather-related health impacts or could be subject to opportunistic crime/harassment

Staggered arrival times for those attending the office should limit congestion

Does not arise at the moment due to reduced staff numbers, to be kept under review.

Staff encouraged to arrive early before temperatures rise

NA

Building management to increase staffing at main entrance and increase contact with police

No increased risk because of COVID

Risk that there is an increase in targeted harassment or stigma directed at individuals who have been ill or are from a specific ethnic background

Reporting channels to permit investigation and where proven appropriate misconduct procedures followed

Zero tolerance to any form of bullying.

Partners and managers to offer support to staff who are affected by COVID-19 or have a family member affected

Time off, adjustments made to working hours, allowances made for increased stress, and assured confidentiality all already in place.

Review the organisation’s bullying and harassment policy and remind managers of it

Zero tolerance to any form of bullying in any event.

Publish or signpost colleagues to facts about COVID-19 to dispel myths

Already implemented, COSS set up a WhatsApp noticeboard at early stage to include distributing signposting support services, that continues for staff at work and those furloughed

Ensure senior figures in the organisation issue and support messages about values and diversity and inclusion

To be kept under review- but all staff are aware of anti-bullying and whistle blowing procedures which are set out in the office manual.

Reminder training on unconscious bias

Risk that a member of the firm ignores firm’s guidance

Communicate the importance of the adherence to the rules

Already implemented- staff briefed through signage, circulars and reminders

Stricter enforcement of rules against people continuing to attend the office while feeling unwell

Already implemented- staff briefed through signage, circulars and reminders.

If necessary, staff receive one to one advice. Repeated ignorance of government or internal guidance will result in staff being excluded from the premises.