On Wednesday, 14 May 2020 in his address to the nation President Cyril Ramaphosa advised of the consultations currently being undertaken in view of; firstly, easing the measures in place as per Alert Level 4 of the nationwide lockdown as it pertains to further allowances with regards to goods allowed to be sold via e-commerce as well as the resumption of operations for the automotive industry. Secondly, and of greater implication, is the possibility of easing the lockdown through a risk adjusted transition from Alert Level 4 to Alert Level 3, which transition could take effect as soon as the end of May 2020. The ramifications of a shift towards Alert Level 3 with regards to trade and movement are vast. The diagram below gives an indication of what we can reasonably expect from Alert Level 3:
ALERT LEVEL 3 – MODERATE VIRUS SPREAD WITH MODERATE READINESS
| CURFEW | Between 20:00 and 05:00 |
| PUBLIC GATHERINGS | Limited to no more than 10 (ten) people outside of a workplace |
| INTERPROVINCIAL TRAVEL | Not allowed, except for transportation of goods and exceptional circumstances (e.g. funerals) |
| AIR TRAVEL | Limited domestic air travel, with a restriction on the number of flights per day and authorisation based on the reason for travel |
| TRANSPORT RESTRICTIONS | Bus services, taxi services, e-hailing and private motor vehicle may operate with limitation on vehicle capacity and stringent hygiene requirements. |
| SECTORS PERMITTED | Licensing and permitting services, deeds offices and other government services designated by the Minister of Public Service and Administration. Take away restaurants and online food delivery. Liquor retail within restricted hours. Clothing retail. Hardware stores. Stationery, personal electronics and office equipment production and retail. Books and educational products. E-commerce and delivery services. Clothing and textiles manufacturing (at 50% capacity). Automotive manufacturing. Chemicals. Bottling. Cement and steel. Machinery and equipment. Global Business Services. SANRAL construction and maintenance. Transnet at 100% |
Alert Level 3 by necessary implication will place a greater burden on employers to ensure that they are fully compliant with safety regulations so as to ensure the work environment is safe. At present, there is no directive as to the regulations that will govern the work space during Alert Level 3, however, it is equitable to anticipate that the directives will be an extension of the regulations published by the Department of Cooperative Governance and Traditional Affairs on 29 April 2020 (Government Gazette No. 43258). The regulation required the following, namely that each Employer must:
1. Develop and adopt a Covid-19 Workplace Plan;
2. Implement hygiene and health protocols; and
3. Designate a Covid-19 Compliance Officer who is tasked with overseeing and ensuring compliance with the hygiene and health protocols.
In view of the abovementioned it is imperative that employers adopt a proactive approach herein. We have developed a checklist to assist employers to determine whether or not they have complied with the current regulations or will comply with the regulations to come. Further, we have added additional requirements which we reasonably foresee being mandated:
| WORKPLACE PLAN | Yes | No |
| Have you undertaken a risk assessment based on the floor size, age demographic, health records and other factors unique to your niche of work and work environment? | ||
| Are your employees required to report their symptoms and do you have a system in place to collate such data? | ||
| Is there a rotation/shift system to limit the amount of employees at the workplace at any given time and to promote social distancing? | ||
| Has an internal policy been circulated and explained to ensure your employees are fully aware of the policies around the policies adopted, social distancing and a shift/rotation system, screening, etc.? | ||
| Have protocols been adopted to regulate meetings with Clients as well as interaction with customers and members of the public? | ||
| Are there measures in place to assist employees over the age of 60 and those with underlying health conditions to continue working, albeit remotely? | ||
| Have you identified high activity areas/communal areas, such as smoking areas, printing rooms, receptions, kitchens? Have you adopted rules to be followed when in such areas with regards to numbers of persons at any given time, social distancing and sanitising? | ||
| Have you designated a Covid-19 Compliance Officer? Have you made the details of the Covid-19 Compliance Officer available? | ||
| HEATH AND HYGIENE PROTOCOLS | Yes | No |
| Are there screening facilities at points of entry and exit of the work place? | ||
| Do you have a testing facility? (This applies to employers with more than 500 employees) | ||
| Has the workplace been thoroughly cleaned? Have arrangements been made for the thorough cleaning of the workplace on a frequent basis? | ||
| Has provision been made to ensure availability of cleaning products to disinfect surfaces and work areas? | ||
| Is the wearing of a mask a requirements inside the workplace? | ||
| Have you adopted a social distancing policy? | ||
| Are you actively promoting hygiene and social distancing through the use of posters and notices? | ||
| OTHER | Yes | No |
| Have you updated your leave policies and policies around working from home? | ||
| Have you adopted a no contact system for deliveries to the workplace? | ||
| Do you have a system in place to identify and record all visitors to the workplace to enable contact tracing? |
Undoubtedly, the adoption of numerous protocols and policies can be quite daunting. At Stegmanns Incorporated we are aware of this and are willing to assist you to review your policies and protocols (in the event that you are fully complaint as per our checklist) to ensure the policies meet regulated requirements. Further, if you do not have these policies in place we are able to assist with developing same based on your capabilities and your specific requirements.
For more information kindly contact Isa Vorster at isa@stegmanns.co.za.
– Published by Joba Ilesanmi