Safer working environment for staff and passengers
As a minimum we expect:
- the application of public health and safety measures, such as physical distancing that address staff arriving and leaving the workplace, in the workplace and in works vehicles and for passengers whilst queuing or travelling on the network
- enhanced hygiene regimes in workplaces, public areas and on vehicles and vessels.
On 10 July the Scottish Government granted an exception to enable the public transport sector to operate reduced physical distancing of 1 metre in the public area of stations, airports and enclosed ferry terminals as well as public transport vehicles and vessels provided that appropriate mitigation measures are in place as a consequence of a risk assessment by the operator. In all other parts of the public transport network all reasonable steps should be taken to ensure physical distance of at least 2 metres.
You should advise staff and passengers on ways of maintaining physical distancing from others as much as possible. There are situations where this may not be possible, for example when boarding or alighting, during security checks, on busier services, busier times of day, when walking through interchanges and when undertaking essential maintenance work that requires two or more people for the task.
Where physical distancing in carrying out work appears not to be possible the risk assessment should assess whether activities can be redesigned so as to ensure the work can proceed in a different way whilst maintaining the required physical distance between staff. If it can be redesigned you should document a justification that describes why the process has changed from usual practice and that you can ensure that usual Health and Safety considerations are applied. If the task cannot be redesigned then it should be adapted to ensure physical distancing is adhered to as far as possible by minimising the time spent at less than the required distance and keeping groups of staff in consistent teams that are as small as possible (cohorting). For example, keeping maintenance crews working together, rather than mixing crew members on different shifts. You should document and regularly review revised procedures.
In some situations environmental changes within a vehicle may be appropriate, such as the installation of protective barriers or safety screens between the driver and passengers. This is a decision for the relevant licensing authorities, operators and the firm or individual to make based on their own assessment of risk. You should contact the licensing authority before any such measures are installed to check that they will permit the installation and that it will meet their requirements.
When creating, agreeing and maintaining clear rules for staff and passengers that meet physical distancing guidelines you will need to take into account those staff or passengers with specific needs or protected characteristics as well as some groups of people who process information differently or may not be able to distance from others.
Personal Protective Equipment (PPE)
The Scottish Government is continuously looking to improve the supply and distribution of the protective equipment that is so vital in the fight against coronavirus (COVID-19). Guidance for non-healthcare settings from Health Protection Scotland provides up to date guidance and information on general principles of infection prevention and control and health protection measures. PPE should be worn in line with health and safety requirements.
PPE is the last step in the hierarchy of risk and other control measures should be considered before the application of PPE. The non-healthcare settings guidance states that occupations should continue to use PPE as per local policies i.e. business as usual. The exception is where a risk assessment of the setting indicates that a higher level of contamination may be present or there is visible contamination with body fluids, then the need for additional PPE such as an apron and gloves should be considered.
PPE protects the user against health or safety risks at work. It can include items such as safety helmets, gloves, eye protection, high-visibility clothing, safety footwear and safety harnesses. It also includes respiratory protective equipment; such as face masks. Where PPE is required, it must be of a sufficient PPE standard to protect the wearer and employers must ensure that it is available.
This guidance describes the steps you need to take to manage coronavirus (COVID-19) risk in the workplace. This includes working from home and staying 2 metres away from each other in the workplace. When managing the risk of coronavirus (COVID-19), additional PPE beyond what employees are usually required to wear for their job role is not beneficial. This is because coronavirus (COVID-19) is a different type of risk to the risks employees normally face in a workplace, and needs to be managed through physical distancing, hygiene and fixed teams or partnering, not through the use of PPE.
Unless employees are in a situation where the risk of coronavirus (COVID-19) transmission is very high, your risk assessment should reflect the fact that the role of PPE in providing additional protection is extremely limited. However, if your risk assessment does show that PPE is required, then you must provide this PPE free of charge to workers who need it. You must also consider any training necessary to manage the risks of misuse, the risks of wearers failing to observe social distancing while wearing a mask and correct disposal of masks. Any PPE provided must fit properly.
A face covering must be worn by anyone using a passenger transport service or a passenger transport service premises that is available for the public to use. A face covering is defined as any type of protective clothing which covers a person’s nose and mouth, this can include a scarf, face mask or any type of appropriate cloth or textile covering.
Scientific evidence on the benefits of wearing face coverings on public transport is limited at present, however initial findings suggest that there may be a benefit to wearing a facial covering when entering an enclosed space such as a public transport vehicle or in a railway station, bus station, enclosed ferry terminal or airport where physical distancing is more difficult and where there is a risk of close contact with multiple people thus increasing the risk of possible transmission.
Accordingly, on train services, bus services and on the Edinburgh Tram and Glasgow Subway, as well as in taxis and private hire vehicles, on aircraft taking off and landing in Scotland and in bus stations, railway stations, subway stations, enclosed ferry terminals and airports face coverings must be worn by passengers and staff. On ferry services face coverings must also be worn by passengers and staff unless the ferry, or part of the ferry which is open to members of the public, is entirely outdoors or physical distancing of two metres can be maintained. Ferry operators as part of their risk assessment will determine where on their vessels face coverings are to be worn.
Staff are not required to wear a face covering in non-public areas of a station, ferry terminal or airport unless the risk assessment of the operator determines that they should be worn. Staff are also not required to wear a face covering on a vehicle where they are physically separated by way of a partition from other passengers or staff by means of, for example, a protective screen. An illustrative example of the latter might be a driver of a vehicle in a cab or behind a Perspex screen on a bus or in a taxi.
Following the First Minister's statement to Parliament, regulations were laid on 15 October to bring the rules on wearing face coverings in workplace canteens into line with rules in restaurants and cafes. Accordingly, as of 16 October, anybody in a workplace canteen will have to wear a face covering when they are not seated at a table - for example if they are queueing, or are entering or leaving the canteen or going to the bathroom.
A further change took effect on Monday 19 October which requires face coverings to be worn in other communal workplace areas such as corridors.
The responsibility for complying with these measures rests with individuals. But employers are urged to take steps in their workplaces to explain and promote the new regulations. The new rules are a proportionate additional step, which will help employees to keep themselves and their colleagues that bit safer.
Operators of services, stations, ferry terminals or airports should note that the requirement to wear face coverings applies to all persons where the public are present and therefore, for example, contractors performing duties on behalf of the operator such as cleaning services on a train or persons making deliveries within a public area are equally required to wear a face covering.
The wearing of a face covering can be uncomfortable and may not be appropriate for long durations of time, employers should therefore consider providing opportunities for staff to take relief in non-public areas. When wearing a face covering on a public transport service or at a public transport station, ferry terminal or airport staff should take into account the needs of passengers, particularly those with hearing impairment and those who lip-read, and remove the face coverings, as necessary, to provide advice, information or assistance. There will also be instances where staff will have reasonable cause to remove a covering for a temporary period which might be, for example, to address public safety or injury, such as the dispatch of trains or buses.
Operators should strongly consider displaying prominent signage on trains, buses, trams, subway carriages, taxis and private hire vehicles and at entrances to, and within, stations, ferry terminals and airports that face coverings must be worn, the exemptions that apply (in general terms) and that face coverings should be reused, if appropriate, or disposed of safely Ferry operators should equally consider displaying prominent signage advising whether and where face coverings must, or need not, be worn on the vessel. Staff and passengers should be advised that for children under 5 years of age and for those people with health conditions who cannot put on, wear or remove a face covering because of any physical or mental illness or impairment or disability or without severe distress an exemption applies. Emergency responders and constables acting in the course of their duties are equally excluded from this requirements. A full list of exemptions are outlined in more detail in the Regulations.
Operators and staff may enquire as to why passengers are not wearing face coverings and remind them of their legal obligations and in doing so they are expected to be sensitive in their dealings with passengers as many illnesses or disabilities are hidden. There is no obligation on a passenger to produce a doctor’s letter or any form of notification to confirm that they have a reasonable excuse not to wear a face covering. The emphasis throughout this crisis is to explain the reasons why particular measures are in place and encourage appropriate behaviours and a sense of collective responsibility. Enforcement is seen as a last resort and in respect of the wearing of face coverings is a matter for Police Scotland and the British Transport Police.
People may remove their face covering if they need to take medication or to eat or drink where reasonably necessary. People can remove a face covering temporarily to comply with a request by a relevant person or another person acting in the course of their duties. An example of such a circumstance might be when a relevant person, such as Border Staff or Police or a ticket examiner, needs to check identity.
Passengers are expected to provide their own face coverings. A face covering is not a surgical or other medical grade mask but a facial covering of the mouth and nose, for example a scarf. Operators may wish to have their own stocks of cloth or textile face coverings available as an initial encouragement to those passengers without face coverings.
The wearing of face coverings by passengers or staff must not result in any reduction by operators in their risk mitigation measures such as physical distancing, hand washing and respiratory hygiene.
Employees when they are performing duties on a public transport service or in a public area of a station, enclosed ferry terminal or airport must wear a face covering. Employers should support their workers in using face coverings safely and provide advice, if requested, on applying and removing the covering.
If a person is not wearing a face covering on public transport or in a taxi or private hire vehicle or in the public areas of a station, enclosed ferry terminal or airport without a reasonable excuse they will be in breach of the law and liable, on summary conviction, to a fine not exceeding the statutory maximum. The relevant legislation is The Health Protection (Coronavirus) (Restrictions) (Scotland) regulations 2020 as amended.
Face Covering Exemption Cards
Exemption cards are available to those staff and passengers who are exempt from the regulations. The cards are accessible from 29 October 2020 via a free helpline 0800 121 6240 or online contact form. Transport Operators and staff must be aware that individuals do not need to produce an exemption card to Transport Operators to prove they are exempt from face coverings.
The card is illustrated with a face covering and the text on the card is large enough to be read from a distance of 2 metres, thus meaning close physical contact is not required.
The exemption cards, both digital and physical, will be delivered through a third sector organisation (Disability Equality Scotland). The physical card will be posted to users and the digital card will be emailed to users as an attachment. It will not be available to download directly from the website.
The face covering exemption card does not replace other exemption cards such as the UK Government exemption card, Thistle card or Sunflower lanyard. These are all valid forms of proof of exemption from face coverings.
Staff arriving at and leaving the workplace
When arriving and leaving the workplace, there may be occasions when employees are in the same space or are using entrances and exits at the same time. You should consider opportunities to reduce risk in these situations. We expect you to consider:
- staggering arrival and departure times
- queuing management, including floor markings, signs and introducing one-way flow at entry and exit points,
- hand sanitation at entry and exit points and not using touch-based security devices (such as keypads).
- providing additional safe facilities for those using active travel means (running/walking/cycling) to access work.
Protecting staff in the workplace
Where staff are unable to work from home, you should be taking steps to reduce transmission from face-to-face interaction and enable physical distancing in the workplace, which may include public areas. We expect you to consider:
- signage which reinforces expectations of employees at relevant locations
- teams or shift groups, fixing these teams or shift groups so that where contact is unavoidable, this happens between the same people.
- ways to remove direct contact through use of drop-off points or transfer zones.
- using digital means to undertake work, where possible
- reconfiguring seating and tables to optimise spacing
- providing increased levels of hand sanitation in workspaces.
- reducing job and location rotation.
- updating first aid training.
Physical distancing of staff in work vehicles during work or travelling to/from work
Where staff are required to use works vehicles either to get to and from work or as part of their work activities you should take steps to avoid people sharing vehicles.
We recognise that there may be occasions when there is no alternative to share vehicles. This should be limited as much as possible and you should keep regular sharing to the same people each time.
Where it is not possible to keep a 2 metre distance in a vehicle, you should devise additional safety measures to minimise the risk of transmission. We expect you to consider:
- providing clear signage to outline physical distancing measures in place
- keep your distance and take care entering and exiting the vehicle
- promoting single person or contactless refuelling where possible
- using physical screening, provided this does not compromise safety
- maintain good ventilation by keeping the car windows open
- sit as far apart as possible in the vehicle, avoiding face-to-face
- using a fixed pairing system if people have to work in close proximity, for example in a vehicle
- the wearing of face coverings by all occupants unless an exemption applies
- clean your hands before and after your journey
- regular cleaning of vehicles, in particular between different users.
Protecting passenger flows
To protect passengers and staff on the transport network, it is essential, as far as possible, to enable physical distancing. You should seek to maximise physical distancing where possible. When considering interventions you should take into account, for example, different types of vehicles , vessels, car and cycle parks, service areas, station or ferry terminal concourses and platforms as well as considering how people act in different circumstances (e.g. wet weather, indoor, outdoor, security procedures). You are also advised to consider and mitigate the security implications of any temporary interventions to support physical distancing.
Particular attention should be given to queues that may occur, including at interchanges and busy times of day, or when there are unanticipated delays. It is important that passengers can queue safely (observing physical distancing where possible) and that staff stay safe while passengers queue.
Specific consideration should be given to the impacts of change on those with physical disabilities or cognitive impairments.
Across the network, we expect you to consider:
- displaying messages, signs and making announcements to discourage non-essential trips and that where possible people should work from home.
- promoting other active travel modes or other demand management techniques.
- compulsory seat reservations on long distance limited stop services to manage potential crowding.
- communicating with passengers through social media and websites and other means to help them prepare for their journeys and know what to expect, including physical distancing measures and implications for capacity in interchanges and vehicles or vessels. The manner and message of communications should take into account the needs of passengers with physical or cognitive impairments.
- undertaking joint planning with other transport organisations, Regional Transport Partnerships and local authorities at transport interchanges (such as ferry terminals and railway, tram and bus stations as well as bus and tram stops) to ensure aligned approaches.
- identifying areas where there is increased risk of congestion or crowding due to reduced capacity because of physical distancing requirements and identify mitigations with other operators and local authorities. The needs of passengers with physical or cognitive impairments should be addressed in any mitigation measures.
- identifying in advance areas where queues may occur. In these and surrounding areas, consider physical infrastructure, signage, communications and other controls to achieve safe queuing such as consideration of interactions with neighbouring shops and businesses as they seek to manage physical distancing and their own queues. Liaise as appropriate with other organisations to safely manage queues and any impact on public space.
- enhancing or creating crowd management guidance for staff, assessing the staffing needs and sharing and communicating that guidance at interchanges so that all operators are apprised.
- providing guidance for staff assisting people with protected characteristics, for example disabled people, the elderly and pregnant women or when staff are providing assistance to people with luggage.
In vehicles or vessels and at service areas, stations, ferry terminals and stops we expect you to consider:
- rearranging, limiting or removing seating to try and ensure physical distancing is observed.
- using floor tape, paint or signs in passenger areas to help people adhere to physical distancing
- providing visible information on capacity limits for vehicles or vessels or lifts
- using screens to create a physical barrier between people where appropriate, such as in ticket offices.
- introducing more one-way flow through public areas and on vehicles or vessels.
- making arrangements for monitoring compliance to assist with further planning.
Cleaning and ventilation
To prevent transmission of coronavirus by people touching contaminated surfaces frequent cleaning should be undertaken of objects and surfaces that are touched regularly in work and public areas or on vehicles and vessels. The frequency of cleaning should be determined by the frequency that objects and surfaces are likely to be touched. Where operationally feasible, internal cleaning of vehicles should be undertaken at the end of journeys in addition to daily cleaning at the end of service. You should also consider the cleaning of all workstations, shared vehicles, hand tools, controls, machinery and equipment after use and between each shift and user.
Where possible, operators should ensure that a fresh air supply is consistently flowing through vehicles, vessels, carriages, transport hubs and office buildings. Particular consideration should be given to maintaining ventilation flows during the colder months when there is a tendency, for example, to close windows Fresh ventilation systems can operate as normal, but recirculating air systems may require adjustments to increase air flow and checks, for example on filters, should be conducted frequently.
Where vehicles, vessels and carriages allow for the provision of toilet facilities, operators should ensure frequent cleaning and sanitisation of such facilities in line with the operator’s risk assessment to minimise the transmission of Covid-19. Bins should be provided for the disposal of paper towels and hand washing soap should be made available. Regular monitoring of toilet facilities should be encouraged to identify and fix faults; and to maintain hygienic standards.
To encourage good hygiene you should use signage, tannoy announcements and any other relevant communication tools to remind customers and staff to maintain hygiene standards. i.e. hand washing and coughing etiquette and the benefits of washing hands before boarding vehicles or vessels. You should ensure sufficient provision of hand sanitiser for staff in work areas in addition to washrooms, and for staff within vehicles or vessels. The provision of hand-sanitisers, preferably hands-free, for use by passengers at busy stations and terminals and on vehicles and vessels is encouraged, subject to appropriate risk assessments on operational implications, including passenger flow management.
Ensure that your emergency procedures are followed during an emergency or situation requiring an evacuation. You should consider how to maintain physical distancing in these situations, recognising that people may not be able to stay 2 metres apart. You should review and update existing crowd management and emergency plans and the situations when these are instigated.
If anyone becomes unwell with symptoms of coronavirus (COVID-19) in a transport setting they should be advised to return home and follow appropriate guidance which can be found on the Health Protection Scotland COVID-19 website.
If they need clinical advice, they should go on line to NHS 111 or call by telephone 111. In an emergency, call 999 if they are seriously ill or injured or their life is at risk. Do not visit the GP, pharmacy urgent care centre or hospital.
There is currently no requirement to self-isolate if you have been in proximity with someone showing coronavirus symptoms in the workplace and have been following physical distancing measures.
Staff should wash their hands thoroughly for 20 seconds after any contact with someone who is unwell.
It is not necessary to close the transport setting or send staff home.
Any incidents of assault involving the dispersal of respiratory droplets or phlegm on staff or passengers on the transport network should be reported in the normal manner with staff and passengers prevented from accessing affected surfaces until they have been cleaned.