Article

Risk assessments for staff

Details of vulnerable groups when considering risk assessments for staff during the COVID-19 pandemic.

13 June 2022

All employers have a legal duty to carry out suitable and sufficient risk assessments, where there is a risk to the health, safety, and welfare of employees when they are at work. 

Risk assessments are part of the management of risks in the workplace, enabling employers to decide upon reasonable steps to protect their staff. It allows employers to fulfil their legal duty of care to protect their staff from harm, injury, or illness.

In response to COVID-19, certain groups are more vulnerable to serious illness (and death), so risk scoring and individual risk assessments will help employers to assess the level of risk to their workforce.

This page contains guidance for NHS organisations on how to continue to enhance their existing risk assessments for COVID-19, as well as general guidance on risk assessments. This guidance is applicable, with appropriate local adaptations, in all healthcare settings.


Current COVID-19 guidance 

The UK Health Security Agency (UKHSA) has issued updated national infection prevention and control guidance and COVID-19: information and advice for health and care professionals which needs to be followed by all NHS organisations. This guidance confirms the importance of overall workplace assessment management, and monitoring of risks in the context of managing infectious agents. This is based on application of measures, as prioritised in the hierarchy of controls. It also outlines that an individual risk assessment is required for health and care staff who may be at high risk of complications. Employers should:

  • discuss and complete a risk assessment(s) with employees who may be at high risk of complications from respiratory infections such as influenza, and severe illness from COVID-19 (for example, people who are pregnant and black, Asian and minority ethnic staff)
  • ensure that advice is available to all health and care staff, including specific advice to those at risk from complications. Bank, agency and locum staff who fall into these categories should follow the same deployment advice as permanent staff.

As part of this new guidance, NHS England and NHS Improvement (NHSEI) has published a letter on the next steps on infection prevention and control, which outline the key changes for healthcare staff, patients and visitors regarding the wearing of face masks, and also advises on visitation procedures.

There is no longer a legal requirement for people who have tested positive with COVID-19 to self-isolate, however, public health advice for people with any of the main symptoms of COVID-19 or a positive test result is to stay at home and avoid contact with other people. Due to the higher risk nature of health and social care settings, the advice for staff members working in these settings has not changed. However, note that the guidance for inpatient isolating procedures, employers should refer to the COVID-19: information and advice for health and care professionals guidance.

Read the Novel coronavirus (COVID-19) standard operating procedure guidance for more information on what staff need to do if they receive a positive COVID-19 test. This guidance replaces previous standard operating procedures (SOPs), lateral flow device (LFD) use in NHS trusts and primary care, and use of LFD for vaccination sites. 

 

  • The UKHSA identify people who are at higher risk from COVID-19 and other respiratory infections as:

    Organisations should consider these issues in relation to people in their workforce who may be at higher risk if they contract COVID-19. These issues, where identified, should always be discussed between those managing services and individual workers, who will take advice from occupational health and HR colleagues where necessary. 

    Employers will need to take into account government advice on vulnerable workers. All new staff should be encouraged to disclose any medical condition that might compromise their health. There may be particular concerns regarding the discussions between those managing services and their team members regarding their health conditions which would normally only be discussed with the worker’s primary care or occupational health advisor.  

    Organisations will recognise that some team members will have health concerns that they may not wish to discuss with their manager. In this situation a review by the organisations occupational health team or other relevant person may be appropriate.

    Age

    There is evidence that COVID-19 has a greater impact in older age groups. Therefore, these staff may be more at risk as a result of increased age and likelihood of long-term conditions. Employers will need to consider this and take into account government advice on vulnerable workers.

    Although the risks of severe COVID-19 increases with age, it should be noted adverse outcomes relating to COVID-19 occur at an earlier age in people from ethnic minority backgrounds. Employers should consider the intersectionality of their staff when carrying out risk assessments. 

    Pregnancy

    Pregnant people, at whatever stage of pregnancy, are classed as at-risk and a risk assessment/risk assurance conversation is to be carried out.  Previous government guidance has been withdrawn and has been replaced with guidance for people previously considered clinically extremely vulnerable from COVID-19

    Guidance for pregnancy and COVID-19 can be found on the NHS website.   You can find more information on the Royal College of Obstetricians and Gynaecologists (RCOG) website to help inform your risk assessment and the Royal College of Nursing has guidance on individual risk assessments during COVID-19.

    The Royal College of Midwives and Royal College of Paediatrics and Child Health, also have information and guidance to support you.


    Underlying health conditions

    In supporting workers with underlying health conditions, please see our section on supporting vulnerable staff for further guidance on those classified at being at higher risk, those at increased risk due to complex health problems, and those with underlying health conditions. For these staff, undertaking a risk assessment will enable appropriate support and steps to be taken.  

    As well as the UKHSA list above, it is important to consider and support all your staff within your organisation and carry out suitable and sufficient risk assessments, where there is a risk to the health, safety, and welfare of employees when they are at work. 

    Ethnic minority staff 

    Evidence shows that ethnic minority groups are disproportionately affected by COVID-19, particularly those with comorbidities who are presenting adverse outcomes at a younger age. The reasons for this are not yet fully understood, but the health inequalities present for ethic minority groups have long been recognised.

    Within the NHS, 40 per cent of doctors and 20 per cent of nurses are from ethnic minority backgrounds, as are substantial numbers of health care support workers and ancillary staff.

    Organisations should ensure that line managers are supported to have sensitive and comprehensive conversations with their ethnic minority staff, recognising the long-standing context of the poorer experience of ethnic minority staff in all parts of the NHS. They should identify any existing underlying health conditions that may increase the risks for them in undertaking their frontline roles, in any capacity. Most importantly, the conversations should also, on an ongoing basis, consider the feelings of ethnic minority colleagues, particularly regarding both their physical safety, their psychological safety, and their mental health.

    Vaccination hesitancy is much higher amongst people from some ethnic minorities.  Line managers should be mindful and sensitive when having risk assessment conversations. The legitimate concerns and information needs of people from ethnic minority backgrounds should be listened to with respect, and practical support offered to any health care worker to help them decide on their vaccine uptake.

    Weight

    There is emerging evidence to suggest that one of the risk factors for becoming seriously unwell with COVID-19 is being obese. Some people, such as people from the Asian ethnic group and older people, have comorbidity risk factors that are of concern at different BMIs. Occupational health advice might be required when considering risk factors in these groups, even in people not classified as overweight or obese.

    It is helpful for employers to ensure those managing services are aware of emerging evidence-based guidelines for them to be prepared to have sensitive conversations with staff where this is identified as a risk factor and anxieties exist. 

    NHS England and NHS Improvement are offering all England based NHS staff living with obesity a 12-week weight management programme to provide support needed to stay active.

    Disability, health conditions or impairments that affect day to day living

    In line with agreed policies and legal protections, many staff who have underlying health conditions or impairments may be able to continue successfully in work through the application of reasonable adjustments. Some of these adjustments will be formally agreed and some informally adopted by staff to suit their own circumstances. It is possible that the current situation of the COVID-19 pandemic could bring further challenges for some staff with health conditions and/or impairments in terms of amending/altering any reasonable adjustments. This should be assessed and explored as part of any risk assessment process.

    Some staff with health conditions and/or impairments may have a weakened immune system, leaving them more vulnerable to getting an infection. There may be issues associated with personal protective equipment (PPE) and those with a mental health condition may feel increased levels of anxiety and stress.


    Government advice on vulnerable workers  should be followed and every effort made to encourage all staff to disclose any medical condition that might compromise their health. For existing staff, undertaking a risk assessment will enable mitigating factors and additional support to be explored.

    Gender

    There was some emerging evidence to suggesting that COVID-19 may impact more on people born to the male gender, so employers may need to review the approach they have taken in relation to risk assessment in light of this.

    However, research also suggests that people born to the female gender are more susceptible to suffer from long COVID, which is a factor to be considered when female employees are returning to work. Our web page on supporting recovery after long COVID will help inform risk assessment considerations and reasonable adjustments to be madeThe Faculty of Occupational Medicine (FOM) has updated their guidance aimed at managers and employers, to assist them in facilitating the return to work of staff members who were unable to work due to long COVID. This guidance includes a set of practical steps, a state of fitness for work, and supplementary policy and guidance documents. 

    Religion or belief

    COVID-19 may continue to coincide with specific religious events – some of which may require staff to fast. This may have an impact on the ability of individual members of staff to perform their role fully, especially when wearing the highest levels of PPE. Those managing services should have a thorough and comprehensive conversation with individual staff about how they will cope in these circumstances and consider what adjustments could be made. 

    Employers should also consider the need for staff generally to be able to take time to conduct spiritual/religious reflection away from the frontline. 

  • Implementing risk assessments

    Support and advice

    It will undoubtedly be necessary to supplement individual discussions with workers, with the established collective representation processes in place within organisations. This will help organisations understand areas of concern for their teams and identify where individual colleagues may be finding it hard to speak up. It could include:

    • trade union colleagues and local partnership forums. These an invaluable source of support and their expertise and insights should be used in constructing local approaches to risk assessment. Employers can access a summary of principles from NHS trade unions on health and safety risk assessment and vulnerable workers (including BME staff groups) during COVID-19
    • other networks, such as those for black and minority ethnic (BME) or disabled staff, will also be an important area of support and insight to organisations
    • occupational health teams, chaplains, and freedom to speak up guardians are good sources of advice and insight
    • advisory functions (where available) including HR, infection prevention and control, health and safety, and governance.

    In terms of deploying workers returning to healthcare settings, risks should be assessed at the occupational health screening stage and deployment decisions should take account of this.

    Undertaking risk assessments

    It is recommended that employers undertake the following steps, in addition to targeted discussions with staff representatives and workers in higher risk areas.

    • Reflect on the intelligence available regarding the organisation. This would include data on absence due to COVID-19, any worker deaths due to COVID-19, staff survey data, NHS Workforce Race Equality Standard (WRES) and Workforce Disability Equality Standard (WDES) data, and any pulse survey data.
    • Consult with staff networks, trade unions and other key stakeholders for support and advice regarding the approach to be taken to risk assessment and agree how a continued dialogue can be maintained.
    • Communicate to all workers, whatever their professional background or work area, describing the approach being taken to risk assessment, reassuring them as to the nature of the assessment being undertaken and the support available to them. The organisation’s policy regarding confidentiality should be clearly stated (and complied with).
    • Share the agreed local risk assessment tool or guidance with all team members to help them identify whether they are in an at-risk group.
    • Explain the need for staff to discuss any concerns as a result of the risk assessment guide or any concern or anxiety they might have with their manager (and offer them alternative routes of support prior to these discussions).
    • Agree alternative routes through which individuals might raise concerns or flag the need for a risk assessment discussion.
    • Provide guidance to those managing services regarding the follow-up conversations about risk with their team members, including the potential responses to protect or support staff.

    Line managers should be aware that there are multiple factors to consider in the COVID-19 work or return to work risk assessment. These include community infection levels, individual vulnerability, workplace / commute transmission risk, workers' concerns/expectations and more recently, vaccination and previous COVID-19 infection.

    Risk assessment conversations

    Organisations should regularly talk to staff through one-to-one conversations about how they are, and if they need any support to improve their working experience. Risk assessment discussions should be purposeful, supportive and specifically designed to review physical and psychological risk factors to an individual, as well as their personal circumstances.

    All staff should be encouraged to disclose any medical condition that might compromise their health and ability to work safely. The ethics committee of the Faculty of Occupational Medicine, has clarified that:

    "Both the employer, through line managers, and the employee have a duty of care to protect themselves, and their patients, for instance, the public, from harm. The health status of the employee is important to this. It would not be considered unethical to ask that the relevant part of personal clinical information is shared. If practically speaking this cannot be done via occupational health, because of the volume of work and other priorities, then, subject to line mangers being cautioned about sensitivity and confidentiality, this enquiry, by managers, would not be unreasonable."

    Notwithstanding this advice, organisations will recognise that some team members will have health concerns that they may not wish to discuss with their manager. In this situation, a review by the organisation’s occupational health team or another relevant person may be appropriate.   
     
    Where there are disagreements about the conclusions reached between those line managing services and staff, locally agreed grievance resolution processes will of course apply. 

    For more information on the current COVID-19 information for NHS staff please read our latest (updated 20 April 2022) COVID-19 guidance for our NHS people.

  • Organisations should gather the relevant information as outlined above, through one-to-one conversations with their teams. Those managing services should listen carefully to concerns and provide support and consider adjustments or redeployment for any staff who are identified as being at greater risk. Adjustments may include:

    1. Limiting duration of close interaction with the patient (for example, preparing everything in advance away from them).
    2. If possible, maintaining a two-metre distance from the patient. Where this is not possible, and there is a risk the patient is positive for COVID-19, wear an FFP3 mask.
    3. Avoiding public transport/ rush hour through adjustments to work hours. 
    4. Asking patients to wear a mask for staff member interaction.
    5. Asking that only the patient is in attendance for home visits/ outreach where possible.
    6. Providing surgical masks for staff members for all interactions with patients or specimens.
    7. Redeploying staff to a lower-risk area.
    8. Advising staff to leave the area for 20 minutes when aerosol generating procedures (AGP) is undertaken on suspected/ confirmed COVID-19 patient.
    9. Encouraging remote working.
    10. Varying work patterns. 
    11. Ensuring the NHS organisation is following infection prevention and control measures.

    Additional support through employee assistance programmes, occupational health or chaplaincy teams may also be appropriate. Managers should seek and follow occupational health advice where appropriate.

    Employers can enhance local approaches by signposting to a range of national health and support available to NHS staff during COVID-19 being provided by NHS England and NHS Improvement.

    Ongoing actions

    Leadership teams should keep their workplace and workforce risk assessments up to date as part of a continuous process in keeping our staff safe. Employers should ensure managers engage and communicate regularly with workers identified as being at higher risk. Risk assessments should be repeated where new information becomes available or where an individual requests a review. Organisations should also continue to consider any updates to national or local guidance regarding the testing of staff.

    The following steps can also be taken to ensure ongoing review of the deployment of staff from higher risk groups:

    • contacting staff in at-risk categories to ensure they are reassured and that any mitigating steps from existing risk assessment processes have been enacted
    • consultation and dialogue with trade union representatives through local partnership forums, including health and safety representatives
    • ongoing engagement with relevant staff networks to ensure that there is an ongoing awareness of any concerns, questions and advice, and they are fully informed of any escalation plans and any potential for redeployment – early and regular communication with all staff groups is crucial
    • advice from the freedom to speak up guardian to ensure that colleagues from higher-risk groups can candidly raise any concerns about the application of the risk assessment process
    • assessment of data about the local incidence of COVID-19, particularly as more information becomes available through greater access to testing.
  • Where applicable, an organisation’s board should consider the effectiveness of the deployment of their risk assessment policy but also importantly the context within which that policy is being deployed. Executive leads (that is those directors accountable for infection prevention and control, health and wellbeing, and equality and diversity) should provide evidence to the board (or relevant board committees) of:

    • meaningful engagement with staff and their representatives
    • advice of the freedom to speak up guardian regarding risk assessment
    • revised policies and approaches
    • relevant advice and guidance to managers
    • the proportion of staff who have identified as high-risk
    • analysis of the response to the identification of risk
    • other relevant data
    • revisions to the organisational WDES and WRES action plan.

    The chief nursing officer previously issued guidance on board assurance regarding infection prevention and control. 

    Boards may also want to consider hearing directly from the chairs of their staff side, staff networks and their most senior occupational health advisor regarding the effectiveness of the risk assessment approach within their own organisation.

  • There are a range of evidence-based risk assessment frameworks, matrices and tools available, developed by professional bodies, NHS organisations and clinicians. 

    The tools and resources outlined below have been developed over the course of the pandemic using the emerging evidence, however, there is no single professional consensus or agreed approach. Therefore, this section signposts to a range of tools and resources to support employers to develop local approaches to risk assessment. 

    Organisations should consider the guidance outlined here along with the full range of risk assessment frameworks, matrices and tools, and work with their occupational health department to develop and review organisational approaches to risk assessment. 

    Tools to support health and wellbeing conversations

    Based on the work of healthcare organisations in South East England, these two documents provide advice on holding health and wellbeing, and risk assessment discussions. Both documents are editable so trusts can add their logos and personalise the content. 

    Faculty of Occupational Medicine (FOM): Risk reduction framework 

    The risk reduction framework paper was developed early in the pandemic by an independent group of clinical academics and other doctors, led by Professor Kamlesh Khunti from Leicester University. The risk reduction framework published by the Faculty of Occupational Medicine (FOM) in May 2020 emphasises the importance of assessment of the workplace, and the workforce. It highlights the importance that increasing age, BME ethnicity, male gender, underlying health conditions and pregnancy have in increasing the potential risk of individuals from COVID-19. The paper suggests that risk assessments should be prioritised for staff in these groups.
     

    The British Association of Physicians of Indian Origin 

    The British Association of Physicians of Indian Origin (BAPIO) has developed a risk stratification tool, which informed the approach now being adopted by NHS Wales.
     

    Royal College of Psychiatrists

    The Royal College of Psychiatrists has published guidance on the assessment and management of risk for BME staff in mental healthcare settings
     

    NHS England and NHS Improvement: Risk assessments and beyond

    NHS England and NHS Improvement has collated a series of risk assessment examples from primary and secondary care, as well as, examples of effective education and infection control approaches.
     

    ALAMA Covid-Age Tool 

    The Covid-Age tool was developed by the Association of Local Authority Medical Advisers (ALAMA), a group of occupational physicians, clinicians and academics. The tool examines personal clinical risk factors and calculates an individual’s 'Covid-Age' as a way of quantifying risk. It is intended for use as part of an occupational health assessment of fitness for work. Assessment of work-related risks in relation to COVID-19 remains complicated. Personal or ‘clinical’ risk factors are one element in considering the reduction of risks for those working in healthcare or elsewhere. The knowledge of personal risk factors is still evolving as the pandemic continues and more is understood, but this tool is based on emerging evidence and will be continually reviewed and updated. 

    The Covid-Age tool alone does not replace the need for other elements of risk assessment and control advice. The tool could be used to support risk assessment conversations with line managers and, where clinical risks are identified, occupational health advice should be sought. 
     

    Royal College of Nursing - COVID-19 workplace risk assessment toolkit

    Alongside members of the COVID Airborne Protection Alliance (CAPA) and the British Occupational Hygiene Society, the RCN has created a COVID-19 workplace risk assessment tool .The aim of this toolkit is to support healthcare professionals consider and managing risks associated with the transmission of respiratory infections, specifically COVID-19, and aid local decision making on the level of personal protective equipment (PPE) required to protect them whilst at work.