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COVID-19 building risk assessment

COVID-19 building risk assessment to comply with government guidelines on opening and managing The Pensions Regulator's (TPR) main building, Napier House, to make it COVID secure.

COVID-19 risk assessment relating to the re-occupation of Napier House

Accountability and declaration of the persons undertaking and reviewing this assessment

Name Position Date
Risk Assessment completed by Mel Gordine-Tyler Facilities Adviser – Health and Safety (H&S) 3 June 2020
Reviewed by Amy Hines Facilities Manager 4 June 2020
Reviewed by Kevin Sinkfield Lead Specialist – Strategy and Risk 15 June 2020
Reviewed by Amy Hines (AH) Facilities Manager 15 September 2020
Approved by Helen Aston Executive Director, Corporate Services 15 September 2020
Approved by Charles Counsell Chief Executive Officer 21 September 2020

To be reviewed when government guidance changes or every three months.

Record of reviews

Name of reviewer Reason Date
M Gordine-Tyler Distancing from GOV.UK guidelines changed – no changes made to risk assessment. 5 July 2020
M Gordine-Tyler Meeting rooms updated to reflect decision to close all on floors Fifth/Fourth/Third/Second/First. 9 July 2020
M Gordine-Tyler Section 13 updated with regard to Air Conditioning (AC) use in line with new guidance.
Section 12 updated with regard to washrooms and flushing with lids closed in line with new guidance.
10 August 2020
M Gordine-Tyler Section 12 review – removing the use of hand dryers and showers.
Section 13 review of comms room – only recirculating air from the AC, limit to one person, IT to decide who.
18 August 2020
M Gordine-Tyler Section 14 – cafe update – use of app to order, food prepped in a different branch, cafe to be staffed by one person. 25 August 2020
M Gordine-Tyler Section 10  additional day janitor to be employed to increase cleaning and cover reactive cleaning along with increased cleaning of touch points. 25 August 2020
M Gordine-Tyler Final run through to change recommendations that have now been actioned. 2 September 2020
M Gordine-Tyler Additional note on desk fan use. 7 September 2020 
A Hines Section 14 – cafe to remain closed. 15 September 2020 
M Gordine-Tyler Update regards face coverings  Sections 3 and 6. 24 September 2020 

TPR's main building, Napier House - COVID-19 building risk assessment summary

A risk assessment has been carried out on TPR's main building, Napier House.

The purpose of this was to assess how the building can be re-opened to allow staff back to work in the office. The current risk of staff coming back is assessed as High to Medium but with the control measures identified this will be reduced to Medium.

We do not envisage being able to bring the risk down any lower whilst the pandemic is still present in the UK, we cannot remove the risk, only reduce it. Current government advice is to continue working from home if you can do so, and this should still be maintained. TPR will carry out individual risk assessments on those who feel that they cannot work safely from home to ascertain the suitability of returning to the office and if it is found that they can then the building risk assessment would need to be adhered to.

After the initial assessment it has been decided that TPR can safely accommodate up to 98 people max, 12 of these would need to be fire wardens and three first aid trained so that we can continue to comply with our statutory duties regards safety in the workplace. This number factors in two support staff from IT service desk and two from Facilities.

Once the actions identified within this risk assessment are implemented TPR will be COVID secure and can rightfully display the government's suggested certificate.

Mel Gordine-Tyler
Facilities Advisor – H&S

Area of risk, who may be 
harmed and how
Existing control measures Further action/control measures required Responsible person Action 
by when

1. Napier House: access and egress

All staff but specifically:

  • vulnerable staff with health conditions as per government and NHS guidelines
  • pregnant employees, Black Asian and Minority Ethnic (BAME) staff, contractors, security, cleaners and anyone else who visits the premises

How staff may be harmed

High traffic areas with a greater risk of contamination due to shared surfaces and equipment, transmission of droplets from coughing or sneezing or improper hygiene control.

The building is closed as all staff working from home for the foreseeable future with a few exceptions noted below:

  • removed entry access on cards for all staff except core IT and Facilities team members and two Building and Maintenance (BAM) engineers carrying out daily Preventative Planned Maintenance (PPM)
  • one day a week, on a Wednesday, Facilities, IT Service desk, security, maintenance and the day cleaner are all at Napier House. Strict social distancing is practiced.
  • ad hoc supervised access for other staff is permitted on a Wednesday, to undertake business critical activity only, not to sit and work
  • staff who come in on a Wednesday are treated as visitors – new procedure in place
  • all staff to use hand sanitizer on arrival, then are directed to the cafe area to wait until called by either the IT or Facilities team
  • seating in cafe area spaced out at two metre distancing, all excess chairs removed

Before opening the building to more staff, the following will be implemented:

  • protection screens for the reception desk – a Perspex screen has been built around the front and side of reception to give protection to reception security. Staff will have to stand back and speak from a 'Stop and wait' sign clearly marked on the floor.
  • reception security sign visitors in and explain the distancing rules
  • waiting area reduced to one chair and table to allow greater floor space for clear and distanced access and egress
  • adapt second door in reception with a mechanical opener, so door can be used as an exit point – swipe point installed to ensure contactless egress
  • mark doors into Napier House Entry and Exit allowing a one-way system to be in operation
  • reception security to operate the doors by push button under the desk to allow access, this will eliminate pin and swipe entry thus removing a frequent touch point
  • reception security to manage access, ensuring one person enters at a time and that the reception is clear before the next person enters
  • directional floor signs installed to show flow of pedestrian traffic both inside and outside of the building. Signage shows the queuing system for entering the building.
  • flexible working arrangement will promote stagger arrival times to avoid all staff arriving at once
  • instruction and training for reception security of new control measures for entering and leaving the building
  • access to upper floors via separate stairwells, North stairwell to go up, South stairwell to go down, signage in place
  • central staircase only for access from the carpark in to the building
  • lifts limited to one person at a time and as such, priority given to those with a greater need who cannot use the stairs without significant effort or risk to health. Clear signage in place.
  • access cards restricted to the floor the individual is working on and the ground floor, staff will not be able to freely walk around the building
  • clear signage in reception and throughout the building to indicate to staff and visitors the need for maintaining distancing and hygiene routines
AH and Management (MGT) 1 September 2020

2. Getting to and from Napier House

Transmission from droplets from coughing or sneezing or improper hygiene control infection due to possible prolonged contact with members of the public.

Effective social distancing is a key element in reducing the transmission of COVID-19 but this is difficult to manage on public transport.

Government guidelines on face coverings should be followed.

Affects all returning staff.

  • Staff should avoid the use of the public transport where ever possible and consider cycling, use of a car or walking if they are attending Napier House on a Wednesday.
  • Where travel on public transport cannot be avoided staff are advised to follow government guidance, wear face coverings and to carry and use hand sanitizer.
  • If a staff member's only option is public transport and they are not comfortable with the use of this, then consider that they should continue to work from home.
  • Hand sanitizer will be available in reception and staff are required to use this before proceeding further into the building, it is recommended staff also use this when leaving the building.
  • Parking at Napier House will be offered to support those who would normally use public transport – Staff can apply for a parking space at Napier House. The criteria to access parking, in priority order are:
    • accessible parking/blue badge holders
    • anyone who already has an allocated parking space
    • anyone who meets the criteria within the existing policy but had chosen not to apply for a parking space
    • people who would normally rely on public transport
  • The number of spaces is limited and if demand exceeds supply this approach will be revisited.
  • Access to a parking space is on a temporary basis and could be removed at short notice.
All staff Ongoing

3. Social distancing

Risk of transmission from droplets from coughing or sneezing or improper hygiene control infection due to possible prolonged contact with other staff members.

Effective social distancing is a key element in reducing the transmission of COVID-19.

Affects all returning staff.

  • Signage reminding about the need for social distancing is in place.
  • All staff regularly in the building on a Wednesday have been briefed on the requirements.
  • Social distancing refers to people being required to maintain a minimum distance of two metres from each other, wherever possible.
  • Staff are required to practice effective social distancing while in and around the workplace, while involved in work activities and when travelling to and from work, whenever possible, by:
    • avoiding non-essential contact with others
    • offices and work spaces set up to support recommended distancing, desks which can be used clearly identified
    • clearly marked one-way systems on the ground floor and stop and wait signs will be in place for all washrooms, kitchens and ‘pinch point’ areas. Additional distancing signage will be in place on all floors
  • A maximum occupancy of 98 desks has been established.
  • Signage will be displayed in all common areas reminding staff of the key infection prevention requirements, including the need to maintain safe distancing.
  • Staff will be expected to wear a face covering when in shared spaces, unless they are exempt from needing to do so for health reasons, as defined in government guidance.
  • This includes (but is not limited to) as staff enter and leave the building, in staircases, corridors, kitchens, bathrooms, and whilst at the printers. This is to protect all colleagues.
  • Staff do not need to wear a mask while sat at a desk or when seated in the cafe to eat.
  • Staff will be required to provide their own face coverings at work, however if a member of staff arrives without a mask then disposable masks will be available from reception or Facilities.
All staff Ongoing

4. Staff member present at work with COVID-19 symptoms

All staff, contractors, cleaners and visitors but specifically BAME and vulnerable staff with health conditions as per government and NHS guidelines

High traffic areas with a larger risk of contamination due to shared surfaces and equipment, transmission from droplets from coughing or sneezing or improper hygiene control.

  • All staff are currently working from home.
  • Any staff member that is part of critical services working in the building on a Wednesday must stay at home and follow the self-isolation rules if they have symptoms.

If a member of staff becomes unwell in the workplace with Coronavirus symptoms (a new, continuous cough or a high temperature, loss of taste or smell) they should go home and follow government advice to self-isolate, the following actions should be taken within the workplace.

The Incident Response Protocol should be invoked:

  • all staff may be asked to leave the immediate area of the building so that a deep clean of the area can take place
  • all surfaces that a symptomatic person has come into contact with must be cleaned and disinfected, especially objects visibly contaminated with body fluids and all potentially contaminated high contact areas such as toilets
  • public areas where a symptomatic individual has passed through and spent minimal time, such as corridors, but which are not visibly contaminated with body fluids, to be cleaned thoroughly as normal
  • cleaning staff should use disposable cloths or paper roll and a combined detergent disinfectant solution at a dilution of 1000 parts per million
  • cleaning staff must wear appropriate PPE as directed by the risk assessments and method statements provided by Churchill cleaning
  • waste from cleaning of areas where symptomatic person has been (including disposable cloths and tissues) should be 'double-bagged' and tied off; placed in a secure holding area for 72 hours before being disposed of in general waste
All staff and Facilities team for cleaning Ongoing

5. Fire

Risk of transmission from droplets from coughing or sneezing or improper hygiene control infection due to possible prolonged contact with other staff members during an evacuation and at an assembly point.

  • Napier House is currently closed with minimal staff on site.
  • Existing fire evacuation rules still apply.
  • Two fire wardens per floor will be required to ensure cover. This will mean an overall headcount of 12 wardens on site at all times that the building is fully occupied to the current maximum capacity, this will be co-ordinated daily by Facilities.
  • Publish information on fire warden locations on the intranet to inform staff of where and how to contact their fire wardens.
  • Review and update Fire Risk Assessment.
  • There are no changes to the fire evacuation process - staff should head to the nearest exit as per normal, using all staircases, preservation of life superseded infection risk.
  • With a reduced headcount, a maximum of 98 staff members, two engineers, two cleaners and one security guard will be at the assembly point.
  • Wardens must remind staff to distance themselves whilst waiting at the assembly point.
  • At no time should any fire doors be propped open to aid in ventilation.
MGT Ongoing

6. First aid provision

All first aiders through responding to first aid incidents may come into contact with a COVID-19 infected person.

  • Napier House is currently closed to all but IT and Facilities Service desk, and BAM Engineers.
  • IT are trained as one day appointed first aiders and Facilities hold FAW certificates
  • Three first aid at work trained staff should be available at all times it is fully occupied to the current maximum of 98 staff. This will be co-ordinated by Facilities.
  • All first aiders will be informed of current process in case of accident/injury to member of staff during this time.
  • Publish this on the intranet to inform staff of how to contact their first aiders.
  • Review and update First Aid Risk Assessment.
  • Wellbeing room: to be closed until it has been deep cleaned after anyone with suspected symptoms has used this.
  • Ensure first aiders on site are fully aware of how to treat a colleague with COVID-19 symptoms.
  • Where two metre distance can’t be maintained face covering should be worn by the first aider and the individual who is unwell (face coverings are available in all first aid boxes and in the wellbeing room).
  • All first aiders to be made aware of the updated guidance from St John Ambulance with regards to CPR (rescue breaths should not be carried out on a casualty during the COVID-19 outbreak). 
  • Re-iterate to all staff about being symptom aware and that they are not to come to the office if they are experiencing any of the following:
    • new, continuous cough: this means coughing a lot for more than an hour, or three or more coughing episodes in 24 hours (if you usually have a cough, it may be worse than usual)
    • high temperature: this means you feel hot to touch on your chest or back (you do not need to measure your temp)
    • loss or change to your sense of smell or taste: this means you've noticed you cannot smell or taste anything, or things smell or taste different to normal
    • for addtional information staff should refer to the NHS Symptoms check and Self-isolation guidance.
MGT Ongoing

7. Office floors

High traffic areas with a larger risk of contamination due to shared surfaces and equipment, transmission from droplets from coughing or sneezing or improper hygiene control.

Staff not maintaining correct social distancing.

  • Essential staff from IT and Facilities are in but are limited to the ground floor only.
  • All floors, with the exception of the ground floor, are closed off to staff but are still being cleaned.
  • To maintain two metre social distancing, a maximum of 98 desks can be used.
  • Floor plans have been amended to show available desks. These will be published in all lift lobbies and on Atlas, all unavailable desks with be rendered unusable by removing chairs.
  • Hot desking is not permitted, 'one desk, one person'. Desks will be allocated to those approved to work in the office
  • All keyboards removed from desks, everyone to use personal issue equipment.
  • Wipes available on every useable desk for staff to wipe down before work.
  • Desks will be cleaned every evening with the appropriate cleaning sprays.
  • Photocopier points will be limited to one person at a time and will be included in the touch point cleaning routine, wipes will be available to clean before and after use.
  • Distancing signage will be evident to remind staff of the two metre rule. Stop and wait signs at kitchens and copier rooms.
  • Clear desk policy in place, keyboard, mouse and cups should be stored in lockers overnight, failure to do so could be in breach of the new procedures put in place to aid in keeping infection risk down. Any items remaining at the end of the day will be removed.
AH, MGT and BAM September 2020

8. Meeting rooms

All staff through proximity and prolonged contact from face-to-face meetings in closed rooms.

  • Meeting rooms are currently closed for use. All meetings are being held virtually.
  • Room capacity will be altered to allow adherence to social distancing guidelines of two metres in Regent and Brunswick, Palmeira and BN1. Excess chairs will be removed. Staff should not add additional chairs to rooms to extend capacity.
  • All meeting rooms should be booked in advance to ensure appropriate cleaning between meetings can be carried out. Meeting rooms should be booked through Service Now.
  • All other rooms not in use and locked.
  • Where possible doors should be left open during meetings to encourage good ventilation.
  • Continue to hold meetings virtually unless it is impossible to do so, and the meeting is business critical.
  • Hold essential meetings in well ventilated rooms with appropriate social distancing in place – limit numbers to essential attendees only.
  • Rooms to be cleaned at regular intervals throughout the day.
  • Cleaning wipes provided in each room, staff encouraged to wipe down before and after any meetings including phones, remote controls, pens. Excess equipment removed.
  • Atlas updated with the new capacity figures and information provided to all staff working in the building and placed clearly in each meeting room.
  • Pods will not be available.
MGT, AH, BAM September 2020

9. Stairwells

All staff and visitors from increased traffic due to limitations on use of lifts.

  • No existing control measures in place as the building is closed to all but a very small number of employees.
  • Additional hand sanitizer dispensers outside each floor level entrance.
  • Clear directional signage and route markers in place as well as stop and wait signs at ‘pinch points’.
  • Increase cleaning in these areas, paying special attention to all touch points, swipe readers, hand rails, door handles, door release buttons.
DT – Churchill Cleaning, AH, BAM September 2020

10. Cleaning

All staff through improper cleaning schedules and practices or failure to use correct cleaning products to deal with enveloped viruses

  • Existing cleaning routine reduced to Wednesdays only due to minimal occupancy.
  • All touch points cleaned on a rotational basis throughout the day.
  • Kitchens and bathrooms cleaned twice a day.
  • Anti-viricidal surface wipes readily available.
  • Hand sanitizer readily available at all access and egress points.
  • Facial tissues readily available.
  • Undertake a deep clean of the building before opening to more staff.
  • Frequency of cleaning in kitchens, washrooms, high traffic areas and touch points throughout the day increased.
  • Cleaning materials used are sufficient to disinfect effectively and do not in themselves present further hazards.
  • Careful disposal of all cleaning materials used in a suspected infection zone, double bag and store for 72 hours before adding to the general waste.
  • Additional day janitor employed to increase cleaning and cover reactive cleaning along with increased cleaning of touch points
DT – Churchill Cleaning, MGT, AH September 2020

11. Kitchens

All staff through shared use of utensils and, surfaces and dispensers. Also a high traffic area heavily used throughout the day

  • All staff keep their own crockery and cutlery and are to wash these up and store in lockers overnight.
  • Cups must not be left on desks, the cleaning team will not touch these items, employee responsibility.
  • Cupboard doors, worktop surfaces, taps, fridge handles, water dispenser units cleaned on a regular basis by the in-house cleaning team.
  • Soap, hand sanitizer and hand towels available
  • Remind staff of good hygiene when accessing items in the fridge, hands must be washed before and after handling any items.
  • All cupboards cleared of all items to reduce risk of shared item contamination.
  • Wipes available to wipe down water dispensing machines. Staff to wipe these down before use every time.
  • Kitchens are limited to one person at a time. Directional floor signs will indicate a 'Stop and wait' area.
  • Staff to wash and dry their own cups, cutlery and place in their lockers. Any items left in the kitchens will be removed.
MGT, BAM, MA September 2020

12. Washrooms and showers

All staff, contractors, cleaners, cafe staff and visitors but specifically – BAME and Vulnerable staff with health conditions as per government and NHS guidelines.

High traffic route with increased risk of transmission through prolonged contact with others.

  • Washrooms are cleaned twice a day.
  • Washrooms closed off for use to deal with any maintenance issues.
  • Showers are closed as too high a risk to manage effectively and on a cost effective basis.
  • Evidence has shown coronavirus to be present in faeces which increases risk of infection in these areas if not maintained correctly or staff do not employ proper hygiene practices. Clear signage regards hand washing in place.
  • Staff limited to 'one in, one out'. Staff cannot enter the washroom and maintain a two metre distance so should wait outside until safe to enter.
  • Clear signage on all washroom doors stating stop and wait must be adhered to.
  • Showers closed as the ability to control the risk here is not viable currently.
  • Gender neutral and Female washrooms will be limited to one cubicle to ensure safer distancing at the sinks.
  • Men’s washrooms limited to one user at a time, urinals taken out of service.
  • Hand towels available in all washrooms, hand dryers taken out of action.
  • Instruct staff that washrooms are not to be used as changing rooms or applying makeup to allow flow of access.
  • Upscale cleaning rota to increase cleaning routine.
  • Signage asking staff to close the lids of toilets before flushing to minimise the release of droplets and droplet residues from air flows.
AH, MGT, DT – Churchill Cleaning and BAM Ongoing

13. Air handling and ventilation

Through the possible distribution of droplets from infected staff member/s through the buildings air handling system and air conditioning.

  • A - Ventilation rates – not applicable as we have a mechanical ventilation system.
  • B - Ventilation operation times – 7am to 8pm.
  • C - Continuous operation of ventilation – switches off overnight.
  • D - Window opening – Not currently opened as building closed.
  • E - Toilet ventilation – switches off overnight.
  • F - Windows in toilets – not operational – no further action.
  • G - Recirculation – Air Handling Unit (AHU) normal set point 80% fresh air 20% recirculated. Third floor and cafe AC on and recirculates air. Comms room AC on and recirculates air.
  • H - Heat recovery equipment – no devices on site – no further action.
  • I - Room level fan coils and induction units – 7am to 8pm.
  • J - Heating, cooling and possible humidification setpoints – humidifier not operational.
  • K - Duct cleaning – as per PPM schedule.
  • L - Outdoor air and extract air filters – as per PPM schedule.
  • M - Maintenance safety procedures – in line with BAM risk assessment.
  • N - Indoor Air Quality monitoring – no monitoring at present.
  • O - Air quality – no air quality checks currently in place.
  • P - Room air cleaners – none present.
  • Q - Risk of Legionellosis – cooling tower isolated and flushing regime in place.
  • A - not applicable as we have a mechanical ventilation system.
  • B - AHU running 5am-10pm.
  • C - Fan Coil Units (FCU) to run 24 hours a day.
  • D - Safety cables checked and repaired as required, wedges available to hold windows open, suitable windows identified to be opened each morning and closed each afternoon.
  • E - Toilet ventilation switch to 24 hours a day running. Advice to staff via signage to flush with the lid closed.
  • G - Set system to full (100%) fresh air. 3rd floor and cafe AC turned off. Comms room AC to remain on as isolated location with no/limited staff presence. One person to access at a time.
  • I - FCU's to run 24 hours a day. CO2 monitors not progressed at this stage as other controls identified are adequate for the restricted numbers working in the office.
  • J - No action  not a method to reduce viability of COVID.
  • K - As per PPM schedule  no increased cleaning required.
  • L - AHU and FCU filters cleaned/replaced in line with PPM schedule.
  • M - Dust masks to be worn. Double bag used filters before disposal.
  • O - Air Quality  not progressed at this stage as other controls identified are adequate for the restricted numbers working in the office.
  • P - Adequate controls in place without needing HEPA filters.
  • Q - Cooling tower reinstated.
  • Desk fans allowed as per Health and Safety Executive guidance.
MA, AH and BAM September/October 2020

14. Cafe area including stationery cupboard

All staff, contractors, cleaners, cafe staff and visitors but specifically - BAME and vulnerable staff with health conditions as per NHS guidelines

High traffic route with staff visiting IT and Facilities service desks and obtaining stationery. Increased risk of transmission through prolonged contact with others.

  • Cafe is closed for any food or drink sales.
  • Excess chairs removed to discourage staff sitting down or being able eat lunch.
  • Limited number of tables available with one chair per table, tables spaced at least two metres apart and out of the walkway areas.
  • BackWood to remain closed
  • Directional floor signs to show flow of in and out traffic.
  • Two microwaves in operation to allow for distancing.
  • Small number of tables available with one chair at each.
  • Stationery cupboard closed, table with a small number of frequently used items available. Anything else required will be requested from Facilities via Service Now.
AH, MGT, DT – Churchill Cleaning Ongoing

15. Car park access and egress

Vehicle drivers, cyclists, pedestrians and contractors accessing the swipe system to gain entry.

Possible touch point contamination.

  • Car park entry is gained via swiping of users own entry card - suggest wiping card.
  • All designated spaces will be de-allocated at this time. Staff who would normally use public transport but choose to drive instead may be allocated a parking space on a temporary basis. Spaces are limited and will need to be booked.
  • Car park entry is gained via swiping of users own entry card  suggest wiping card after use with anti-viricidal surface wipes.
  • Entry in to the building from the car park via lift or central staircase only.
  • Access to the car park from the building must be done via the lift, central stair case or by leaving the building and walking round to the car park entrance and swiping.
  • Provision of hand sanitizer dispensers in the lower basement and basement lobbies.
All staff with access Ongoing

16. Collection of train tickets

Frequent use by multiple persons of keyboard for train ticket dispenser.

  • Napier House is currently closed.
  • No train travel is currently permitted.
  • Ticket dispenser behind Perspex screen at reception, return to emailing or providing ticket reference details to security to print tickets, if travel has been permitted and is deemed safe (covered by separate risk assessment).
Reception September 2020