Managing COVID-19 risks in the workplace

Employers, or persons conducting a business or undertaking (PCBU), have a duty under OSH or WHS legislation to eliminate or, if that is not reasonably practicable, minimise the risks, of COVID-19 at the workplace as far as is reasonably practicable.

In addition to your obligations under the OSH or WHS legislation, you must also comply with any public health orders issued by the WA Department of Health. For example, if there is a vaccination mandate applicable to your workplace, you must comply with it. You may find that when you then assess risks and identify practicable controls for COVID-19 for OSH or WHS purposes, some controls have already been implemented. However, only implementing controls mandated by the WA Department of Health may not be sufficient to meet your OSH or WHS duties.

This guidance is intended to assist employers/PCBUs in Western Australia to manage these risks to reduce exposure to the COVID-19 hazard.

Employers/PCBUs must consult with workers on work health and safety issues, including reducing the risks from COVID-19 in the workplace.

Risks should be managed with regard to the hierarchy of control measures (Figure 1), which identifies the types of controls that are generally more effective. A combination of control measures is typically required to minimise the risks of COVID-19.

Note: Under the Occupational Safety and Health Act 1984 (OSH Act), employers have a general duty of care. Once the Work Health and Safety Act 2020 (WHS Act) commences in WA, the term ‘person conducting a business or undertaking’ (PCBU) is used instead of ‘employer’ in most circumstances. General duties in relation to COVID-19 are similar under both Acts.

hierarchy of control 2022
hierarchy of control 2022, by WorkSafe
Hierarchy of control

Table 1 provides examples of control measures for COVID-19 using the hierarchy of controls. It should be noted that control measures are selected based on the risks at the workplace, so not all workplaces require the same control measures.

Workplace controls are selected based on the specific risks and take into consideration the practicability of implementing specific control measures. It should be noted that not all control measures are reasonably practicable in all circumstances; for example, there may be supply issues around accessing a particular control which mean that it is not practicable to obtain it for a period of time. There is a requirement to regularly review your control measures as the practicability and effectiveness of controls may change over time.

Note: Guidance on the practicability of controls is available in the Model Code of Practice: How to manage work health and safety risks.

Examples of control measures

Elimination

Table 1 - Examples of control measures

Category

Example control measures 

Elimination Physically remove the hazard
  It may not be practicable to eliminate the risk of COVID-19 in the workplace at times of significant community transmission. 

Isolation

Table 2 - Examples of control measures
Category Example control measures
Isolation Isolate the hazard from people 
 

Work at home and use virtual meetings instead of face-to-face meetings.

In healthcare settings, assess patients for COVID-19 illness, or consult other patients or clients, using telehealth (virtual) appointments instead of face-to-face appointments.

Use quarantine or isolation systems while individuals are at higher risk of contracting COVID-19; e.g. workers who have recently travelled from an area with high levels of community transmission could work at home for a week rather than interacting with other workers in person. This control requires a risk assessment for the specified travel. 

Ensure those with COVID-19 do not attend the workplace (where practicable, noting some workplaces accommodate or treat people who may have COVID-19).

This control is more effective where systems of early identification of cases are in place, which may include the use of Rapid Antigen Tests (RATs) [1] for workers, where practicable, and travel risk assessment.

It is unlikely to be practicable to require visitors to undertake a RAT. 

The Australian Health Protection Principal Committee (AHPPC) is the key decision-making committee for health emergencies and provides guidance on circumstances where RATs may be used, including:

  • as a diagnostic test for someone at high risk of having COVID-19
  • to manage outbreaks
  • to provide early case identification in high risk settings.

It should be noted that if RATs are used in a workplace context (e.g. to screen workers in high risk settings), the employer/PCBU may choose to use a sampling approach rather than wholesale testing.

[1] The TGA provides guidance on RAT processes and protocols to safely conduct RAT at workplaces. They also provide a list of approved RAT kits. Testing kits that have not been approved by the TGA are not to be used in Australia. If you determine that rapid antigen testing of your workforce is required for your business, you must provide the TGA approved tests.

Use CCTV to monitor higher risk areas of the workplace rather than monitoring in person using security workers (e.g. quarantine facilities).

 

Engineering controls

Table 3 - Examples of control measures
Category Example control measures
Engineering controls

Implement a vaccination program for workers. 

Promote the uptake of vaccination among workers and visitors.

Optimise ventilation and air quality, including:

  • Fresh air intake
  • Air flow rates
  • Air filtration systems
  • Use of air purifiers

Identify alternative or supplementary ventilation options for workplaces ventilated only by reverse cycle heating/cooling systems to manage air quality, as these do not introduce fresh air.

Check on ventilation outcomes, for example use a carbon dioxide monitor (noting that outdoor carbon dioxide levels are around 400 ppm).

Use negative pressure rooms for COVID-19 positive patients or residents.

Neutral pressure rooms should be used if negative pressure rooms are not available.

Do not use rooms under positive pressure for COVID-19 positive patients or residents as air containing viral particles will move away from their room and potentially towards work areas.

In workplaces where patients/residents may have COVID-19, ensure airflow in workstations moves air away from the worker towards patients/residents.

Use counter screens (e.g. acrylic screens) to reduce the risk of small particles from a client or member of the public being inhaled by a worker; e.g. from a cough/sneeze/speech.

Locate workstations to reduce risk; e.g. away from areas frequented by higher risk people.

 

Administrative controls

Table 4 - Examples of control measures
Category Examples control measures
Administrative controls Change the way work is done
Effective policies and procedures

Designate someone to lead the management of COVID-19 risks at the workplace.

Regularly review procedures as new or updated guidance or new control measures become available.

In higher risk workplaces (eg hospitals, quarantine facilities, ports), designate workplace zones based on risk, and ensure appropriate controls are used in each zone.

Develop a vaccination policy for workers and visitors. 

Implement procedures in relation to a good standard of cleaning.

Implement policies and procedures on training requirements, based on risk.

Ensure appropriate information is provided to external clients, visitors and other stakeholders who interact with the workplace. This may be via signage, email, advertising or other communication methods. 

Reduce the movement of workers between multiple locations/worksites.

Implement a policy on not attending work when unwell. Such policies are more successful when supported by suitable pay and leave arrangements.

Implement a requirement for workers to notify their employer immediately if they:

  • test positive for COVID-19
  • have been a close contact including:
    • a household member or intimate partner of a person with COVID-19 who has had contact with them during their infectious period
    • someone who has had close personal interaction with a person with COVID-19 during their infectious period; i.e. they had:
      • at least 15 minutes face-to-face contact where a mask was not worn by the exposed person and the person with COVID-19; or
      • more than two hours within a small room with a case during their infectious period, where masks have been removed for this period
    • someone who is directed by WA Health that they are a close contact.

Implement a plan for managing a positive case at the workplace.

Implement a plan for a workplace outbreak with a large proportion of workers either COVID-19 positive or required to isolate. 

mplement a policy in relation to proactively testing workers in higher risk situations; e.g. prior to and after travel, before attending a vulnerable location/workplace, where the worker conducts high risk work tasks (such as caring for or working with COVID-19 positive people), or where there are other individual risk factors. The ability to proactively test workers will depend on the availability and practicability of accessing tests (e.g. RAT). If you, as an employer/PCBU, determine that the use of RAT is required to implement a safe system of work, you need to supply the RAT kits. 

Manage infection risks

Keep COVID-19 positive and unaffected patients or residents separate. 

Manage visitors, clients and other external people based on risk.

Provide hand hygiene facilities and supplies and consider supplying masks where practicable. 

Provide information to workers and others about safe mask use, mask handling and disposal, hygiene measures and physical distancing. 

Maintain physical distancing and provide information to people at the workplace on this requirement. This may include floor marking, signs or other communication. It should also include a review of the maximum capacity for meeting rooms and lunch rooms. 

Manage cases in the workplace

The employer/PCBU’s response to suspected or confirmed cases in the workplace should include:

  • define the affected work area and identify affected workers (all workers who had contact with the case, taking into account the definition of close contact at that time. Take a precautionary approach.
  • direct affected employees to leave the workplace (avoid public transport) and self-isolate at home pending further advice from the WA Department of Health [2]  
  • communicate with other workers. Advise of the case (without providing the person’s name), identify who should isolate, who should monitor for symptoms, advise of any areas of the workplace closed and the cleaning that has been conducted.
  • Arrange for the affected areas of the workplace to be thoroughly cleaned.
  • Contact workers in isolation to check in with them.
  • Let workers in isolation know the timing for their return to the workplace, in line with WA Department of Health advice.
  • Provide access to an employee assistance program, if practicable.

Note:  In the event of a suspected or confirmed COVID-19 case at the workplace, State of Emergency and Public Health State of Emergency Declarations applicable in Western Australia may require employers/PCBUs to take specific response actions.

[2]  - Contact the Coronavirus Helpline on 13 268 43

Manage work related psychosocial hazards

Employ sufficient workers to avoid excessive workload, or consider what tasks may be deferred if workload is too high and more workers cannot be obtained.

Provide workers with regular breaks.

Assess support and resources available to workers who may be under work-related or other stress, which could be related to the pandemic. For example, is there access to an employee assistance program? 

Implement policies and procedures on required standards of conduct and how to raise and resolve workplace or interpersonal issues; e.g. grievance procedures, contact persons who can help workers identify options to resolve a concern.

Support contact tracing Support rapid contact tracing by prominently displaying a check-in point with QR Code and manual sign-in sheets at each workplace, and reminding everyone to use it each time they are at the workplace. 

 

Personal protective equipment (PPE)

Table 5 - Examples of control measures
Category Example control measures

Personal protective equipment (PPE)

Protect workers by providing PPE and supporting its safe use

Risk assessment

Conduct a risk assessment of different workers’ requirements, based around the tasks that they undertake, the potential for exposure, duration of higher risk tasks, other risk factors such as locations worked, and the controls currently in place. 

Use the risk assessment to identify PPE requirements. You may need to review this frequently as circumstances change; e.g. the local rates of community transmission increase or decrease. 

Masks for public health reasons

Where public health requirements specify the need for masks to be used, provide workers with information to assist them select and use masks appropriately. Guidance is available here. Supervise workers to ensure they are using masks correctly.

Where masks are required for public health reasons, the employer/PCBU is not required to supply them. 

Respiratory protection program

Where respiratory protective equipment (RPE) is required to protect workers from airborne hazards, employers/PCBUs should have a respiratory protection program in place.

Training on the use and limitations of respirators must also be provided in workplaces using this control. More information on respiratory protection programs can be found in the Australian/New Zealand Standard AS/NZS 1715:2009 Selection, use and maintenance of respiratory protective equipment.

Some employers/PCBUs may be eligible for support from the WA Department of Health if unable to obtain an RPE supply. 

Disposable P2/N95 respirators

For higher risk work, a P2/N95 respirator (or higher) should be selected where reasonably practicable. Guidance on buying P2/95 masks is available from the Australian Institute of Occupational Hygienists (AIOH).

The respirator should be appropriate for the task, the correct size and fit-tested before use.

These respirators also need to be put on and taken off correctly, and user seal checked (fit checked) before each use. Further guidance on the respirator removal is here

P2/N95 respirators that have unfiltered exhalation valves or vents do not protect others in the vicinity of the wearer as aerosols may be exhaled. 

If it is not reasonably practicable to undertake fit testing prior to use, workers must do the following every time an N95/P2 respirator is worn:

  • follow the instructions on how to put on the respirator
  • perform a fit check
  • ensure that they are clean-shaven where the respirator touches the face
  • make sure no clothing or jewellery gets between the respirator and the face

Manufacturer’s instructions typically advise to replace P2/N95 respirators after each use, and other guidance indicates they should be discarded when they are dirty, damaged, or difficult to breathe through.

Re-usable (elastomeric) respirators

Half-face or full-face tight-fitting respirators consist of face pieces made of synthetic or natural rubber material. These respirators can be repeatedly used after appropriate cleaning, disinfection, storage and changing the replacement cartridges according to the manufacturer’s instructions.

Some types of non-disposable half- or full-face respirators offer higher protection than disposable P2/N95 respirators provided they are used correctly, including-fit testing. Reusable respirators also have adjustable straps that may accommodate a better fit.

Re-usable respirators that have unfiltered exhalation valves or vents do not protect others in the vicinity of the wearer as aerosols may be exhaled.

Powered air-purifying respirators

A PAPR is a battery-powered device that provides filtered air under positive pressure into either a loose-fitting hood or helmet or a tight-fitting face piece. Because the filtered air is delivered under positive pressure, the device can compensate for an imperfect seal. For this reason, a PAPR is regarded as potentially providing a higher level of protection than other RPE.

PAPRs with loose-fitting hoods do not need to be fit-tested and they can be used by workers who cannot achieve an acceptable seal due to facial hair or other reasons. PAPRs are often reported to be more comfortable than other forms of RPE.

Other PPE Other required PPE may include safety glasses, goggles, face shields, long-sleeved gowns and gloves.

 

Notifying WorkSafe of COVID-19 cases

Under the OSH Act, WorkSafe must be notified if a person dies as a result of COVID-19 contracted at work.

Once the WHS Act commences, PCBUs must notify WorkSafe when it is confirmed that a person has contracted COVID-19 through carrying out work and:

  • the person dies; or
  • the person is required to have treatment as an in-patient in a hospital; or
  • the person contracted COVID-19 while carrying out work that involves providing treatment or care to a person; or involves contact with human blood or body substances. In this case, the carrying out of work must be a significant contributing factor to the infection being contracted.

For WA mining operations, positive COVID-19 cases on-site are considered a potentially serious occurrence, and notification is required in accordance with section 79 of the Mines Safety and Inspection Act (WA) 1994 or Regulation 675V of the WHS (Mines) Regulations 2022 (once commenced). For more information on what is reportable, please refer to the recent State Mining Engineer advice distributed to all Mine Managers via the Safety Regulation System.

Further information

Western Australia

Department of Health

WA Government

WorkSafe WA

Other jurisdictions

Australian Government Department of Health

Queensland Health

Safe Work Australia

WorkSafe Victoria

Scientific literature

Science Direct

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