Updated Site Operating Procedures provide additional guidance on 2 metre distancing in construction
The updated SOP is based upon the latest government guidance on construction work and addresses three main areas:
- When and how to travel to work;
- On site facilities; and
- Close working.
Unlike the short-lived version 2 of the SOP (which was published on 2 April and then immediately withdrawn), version 3 of the SOP does not recommend that work should only be carried out if workers can distance themselves by more than 2 metres. Instead it provides a hierarchy of controls (discussed further below) where it is not possible for an activity to be carried out maintaining a 2 metre distance between workers.
The updated SOP quotes government guidance on social distancing:
“Where it is not possible to follow the social distancing guidelines in full in relation to a particular activity, you should consider whether that activity needs to continue for the site to continue to operate, and, if so, take all the mitigating actions possible to reduce the risk of transmission.”
It also supplements this with the following statement:
“The health and safety requirements of any construction activity must not be compromised at any time. If an activity cannot be undertaken safely, it should not take place.”
There will remain questions about whether taking all mitigating actions possible to reduce the risk of transmission means an activity can be undertaken safely. This will need to be considered on an activity by activity basis and those planning and carrying out on-site activities will need to consider the practical measures which can be taken to mitigate risks and then evaluate whether the activity can be carried out safely.
The updated SOP provides a hierarchy of controls where it is not possible to maintain 2 metre distancing for a particular activity. These controls identify specific practical steps to:
- eliminate or reduce risks;
- isolate workers so that they operate in small teams; and
- control face to face working where this is essential to carry out a task when working within 2 metres.
The hierarchy explains that where it is not possible to maintain a two metre distance, each activity should be risk assessed using the hierarchy of controls and against any sector-specific guidance, and emphasises that masks (RPE) are the last resort in the hierarchy.
The updated SOP emphasises that people should travel to site alone using their own transport wherever possible. If that is not an option, journeys should be shared with the same individuals and with the minimum number of people at any one time. There should be good ventilation and regular cleaning of vehicles. If workers need to use public transport, site hours should also be staggered to avoid congestion on public transport and to avoid travel during peak times (5.45–7.30am and 4–5pm).
The SOP emphasises the need for social distancing when entering and leaving site and when using all site welfare facilities. This includes use of signage to ensure a 2 metres gap between people when queuing. Further detail is included regarding hand washing and general cleaning issues, including in welfare facilities and when using machinery and equipment.
The updated SOP provides welcome additional guidance to the industry and should provide a framework for contractors to assess means of progressing work on site. Contactors will however need to carry out risk assessments on an activity by activity basis to establish whether work can be carried out safely. Clients should be requesting updates on how their contractors are adapting their working arrangements to meet the updated guidance. They should not however issue instructions about how to follow the guidance, as primary responsibility for health and safety arrangements on site sits with the Principal Contractor under CDM.
Whilst the guidance on social distancing and the hierarchy of controls are helpful additions, there will remain questions about whether and how certain activities can be completed.
With many construction sites now reopening, contractors are clearly adapting their working arrangements to address government and CLC guidance. The reopening of builder’s merchants will also support on-site activity. Significant challenges remain, but the industry is likely to see greater output on sites in the coming weeks.