Ten Tips for Completing Your COVID-19 Risk Assessment

If you’ve been following the news, you’ll be aware that Coronavirus infection rates have started to creep up and that local lockdowns are becoming normal around the country.

Under health and safety legislation this will mean judging whether organisations, including churches, are ensuring health and safety so far as is reasonably practicable. This means checking for compliance with the non-mandatory guidance, judging whether deviations from the guidance represent a failure to manage risk to this standard, and ensuring that risk assessments are suitably robust.

As churches, it is important that we aspire to be not merely compliant with the guidance but exemplary in their conduct:

• We should seek to minimise the risk of harm to our congregations and wider communities as a matter of love (Luke 6:31, Galatians 6:10);
• We owe due respect to earthly governments (Romans 13:1-7, 1 Peter 2:13-17);
• Good or poor cooperation in the wider national effort to contain the virus will inevitably impact positively or negatively on our witness to the nation (1 Peter 2:12);
• The better a job we do of managing transmission risk in our churches, the more likely we will be permitted to keep them open;
• Church gatherings are, objectively, a relatively high-risk activity when it comes to spreading the coronavirus.

With all this in mind, below are my personal top ten tips for completing risk assessments. They apply not only to COVID-19 risk assessments, but to any risk assessment - while the focus is currently on COVID-19, our existing legal duties concerning other health and safety risks are unchanged!

1. Decide if you are assessing risk or writing a risk assessment

Are you assessing risk or writing a risk assessment? They might seem like the same thing, but the difference is which is your primary goal – that risk should be managed to an appropriate standard (good) or that you should have a document at the end of the process (less good).

Risk assessments are mandatory, but they are only a means to an end. If you are writing the risk assessment solely to ensure compliance with the requirement to produce it, you probably won’t achieve this end as effectively.

2. Avoid ‘copy-and-paste’ risk assessments

It is very tempting to copy another risk assessment, make some minor tweaks and call it a day, but this is a dangerous approach. By all means reuse existing material – either your own or those of another church – and avoid re-inventing the wheel. However, you should never take for granted that a different risk assessment will be fully applicable, and you should check through it point by point to ensure validity.

3. Be systematic

When identifying hazards, their potential effects and the controls you could put in place, it pays to adopt a structured, systematic approach or you are more likely to miss things.

Templates can be very helpful here (for example the FIEC COVID-19 risk assessment template), as can reference to existing risk assessments and checklists – however, as noted above, don’t forget to check if they are missing anything.

4. Ask ‘what if?’

If you aren’t sure what hazards you might have missed, or you’ve identified some controls and think there might be others you should consider, try asking a few ‘what if’ questions.

What if this happens? What if this control fails? Walk through the activity in your mind (or maybe wander around the venue if you are able to) and explore what might go wrong – and what you’ve implicitly assumed won’t go wrong. You may be able to make those assumptions, but it usually pays to make a note of what they were.

5. Think about likelihood and severity

When assessing the level of risk, it is important to think about both the likelihood or frequency with which an adverse event may occur, and the severity of that event if it occurs.

Both are important – a situation with a high chance of transmission to a single person might be as much of a problem as one with a low chance of multiple transmissions.

6. Don’t always bother with ranking risk

If you have seen structured risk assessments before and then looked at the FIEC template, you may have wondered at the lack of risk ranking. You can, of course, adopt any ranking approach you like to decide when a risk is tolerable or not using that template. However, we have chosen against making them a standard feature of the FIEC template because ranking scales aren’t always that helpful, especially for risks which are not understood in detail (and this is certainly true of transmission risk of COVID-19).

This tends to lead to arbitrary rankings, which may instil a false degree of confidence in the results – better to recognise the limits of what you know and judge whether you think you could do anything more that is reasonably practicable. Ranking can also lead to an unhelpful temptation to ‘engineer’ results to produce an outcome on the ‘right’ side of a threshold.

7. Choose inherent safety over engineered safety over reliance on human behaviour

In the chemical process industry, there is a saying that “what you don’t have can’t leak”. Removal of a hazard at source is invariably safer than trying to manage it. For many church activities this presents a stark choice about whether or not to run activities at all, and this is a valid question to consider – but there are areas where the trade-off isn’t quite so bleak.

For example, you might choose to not provide refreshments at an activity instead of jumping through hoops to try to make the catering arrangements safe.

In a similar fashion, physical safety measures are usually more reliable than human behaviour. We clearly have to rely on behaviour for social distancing, but there are physical measures we can use that reduce the burden on behaviour – for example, blocking rows of chairs is safer than just telling people not to sit there.

Similarly, masks may be more reliable than social distancing because the latter requires constant alertness to the people around you whereas a mask’s benefit is consistent (as long as it doesn’t come loose).

8. Consider if you have done enough

Somewhat frustratingly, the only definitive test of how safe is ‘safe enough’ (i.e. how far is ‘so far as is reasonably practicable’) is in a court of law. Most of the time we can be pretty confident when we have done enough if we follow the guidance.

The litmus test is this: if someone points out something you’ve chosen not to do, you can confidently say “to do so would not be reasonably practicable (your Honour).” Hopefully you’ll never have to add those last two words!

9. If you say you will do something - do it!

Make sure you do everything your risk assessment said you would do. Putting things another way, don’t document a control that you don’t believe will be followed through. Your risk assessment should be assessing the real risk, not a hypothetical one.

If you find yourself under scrutiny from the authorities, a risk assessment is a documented admission that you should have been doing something and can be weaponised against you if you haven’t actually done it.

10. Review and update

Risks evolve over time and therefore so should risk assessments. They should be reviewed and updated periodically to account for changes in circumstances or new lessons learned in practice.

An annual review plus a review every time there is a significant change is a good rule of thumb. Given how rapidly the pandemic is evolving and how often the Government guidance is updated, you can expect to review COVID-19 risk assessments every couple of months.