Below are the comments from QMUCU regarding the institution-wide Covid-secure risk assessment. Our feedback begins with general comments, after which comments are organised by hazard as listed in the risk assessment.
General comments
Consultation arrangements
There is ongoing correspondence regarding the inadequacy of current consultation arrangements for Health and Safety, and these discussions will continue outside of consultation on this specific risk assessment. However, in the context of this specific consultation, it should be noted that:
- Guidance on return to campus, including the university “Covid Code” were circulated to all staff before trade unions were consulted.
- Campus unions made a request to schedule a meeting to discuss updates to the Covid-seure risk assessment – a request which we were told would be granted – but we have instead only been provided with a short, unscheduled window to provide written comments. The consultation should be extended to allow for this meeting.
- When this risk assessment was distributed to trade union reps for comments, it was sent to an outdated list. This excluded two UCU H&S reps from the circulation, including the UCU H&S officer. The other two reps were on annual leave at the time of circulation, so it is only by luck that QMUCU has had sight of this risk assessment within the time allowed for consultation.
Methodology and evidence
This risk assessment is presented as a draft and does not yet include judgements about risk levels after controls, presumably because these controls are still to be finalised. However, other local risk assessments as well the extant institution-wide risk assessment have made judgements about post-control risk levels or about what levels are acceptable. It is important for trade unions to know what hazard levels are expected after these controls are implemented. Moreover, we need to know how these judgements have been made. What methodology is used to determine risk levels? What evidence are these judgements based on? What particular government guidance and scientific research do they draw on?
QMUCU does not regard government guidance as an acceptable standard and calls on Queen Mary to commit to higher standards which draw on additional scientific research from relevant authorities (e.g. Independent SAGE, the WHO, the US CDC, the BMA/BDA, the Royal Colleges) as well as on expertise from among its own academic staff.
UCU’s Five Tests
UCU has identified five tests which it believes must be met before return to campus can begin. These can be read in detail here, but for reference they are:
Test 1: Sustained reduction in numbers of Covid-19 cases and infection rates
Test 2: Coherent planning for social distancing
Test 3: Comprehensive testing and contact tracing
Test 4: University-wide strategies for safe returns and continuing health and safety
Test 5: Protection for those most vulnerable to Covid-19
These tests inform the basis of our approach to the return to campus. In our view, there has been insufficient progress made either nationally or locally for a widespread return to campus at QMUL.
Comments on specific hazards:
COVID-19 virus exposure and transmission in the workplace
Ventilation
It is reassuring to see that the university is proposing to assess ventilation arrangements in some indoor spaces and to include this in its assessment of risk. This should be treated as a matter of the highest importance and urgency. Many buildings and rooms on the QMUL estate have historically suffered from poor ventilation (for example, the Bancroft Building), which has previously led to staff reporting negative health effects. The rising available evidence for aerosol transmission makes ventilation quality a critical part of making any use of campus facilities safe. QMUCU suggests the following measures be taken as part of the risk assessment and the forthcoming EAF review:
- Ventilation rates for all spaces should be measured, recorded, and made available to campus unions.
- The weather/seasonality/temperature dependence of ventilation arrangements needs to be assessed. Some ventilation arrangements which are possible in the summer (opening windows, high AC usage) may become unsustainable by winter. Alternatives such as portable HEPA filters should be used where necessary.
- EAF should refer to this Covid-19 Airborne Transmission Estimator Tool prepared by leading scientists on aerosol circulation. By entering key data about parts of our estate (room size, number of people, length of activity, ventilation rate), the tool can provide an estimate of transmission probability in a given space.
- A maximum acceptable transmission probability should be agreed with campus unions. Where the risks are too high, the space should not be used.
- All HVAC systems should be fitted with filters which are grade MERV-13 or higher.
- Any building wide ventilation systems with settings to adjust the rate of outside air intake should be set to take in the maximum amount of air from outside.
Face coverings
QMUCU believes that face coverings should be mandatory in all indoor spaces on campus (except for those exempted on health or other grounds). Face coverings are not a substitute for other control measures, but they should be considered as a stackable control measure which can very practicably be added to minimise risk. This is especially important while much is still unknown about the extent and methods of virus transmission. Accordingly, Queen Mary should provide masks to all those arriving on campus, together with instructions on their proper use. Allowances should be made for the difficulty of wearing masks for long periods, which may require adjustments to shift patterns and appropriate opportunities for regular outdoor breaks.
While it is important to distinguish between certified PPE and face coverings, the wording in the risk assessment should be clarified to ensure that the phrase “QMUL does not encourage the precautionary use of extra PPE” is not read as a discouragement to mask wearing.
Track and trace
There should be proper registration of all staff, students, and visitors for each visit to campus to assist with track and trace of any suspected cases. However, data on attendance on campus should be held securely and confidentially and should not be used as part of any sickness/absence/attendance assessment, which should be reported through the usual methods.
Temperature and symptom checks
Temperature and symptom checks should be conducted for all those arriving on campus. Equipment for temperature checks is widely available and already in use in airports and many businesses. As well as online symptom checkers, symptoms should be checked by signage/interviews at entrance points to campus.
Testing
Advice should be distributed to staff and students on the nearest available testing sites to campus. The university should be planning now to make tests available to staff and students on campus. Research suggests this would be essential for any safe return to campus on a large scale. Several US colleges, including Harvard, are planning to undertake regular testing of their students as part of their plan to return to campus. Representations should be made to sector-wide bodies and the government about the importance of testing for the return to campus.
Bathroom facilities
There is no specific mention of bathroom facilities anywhere in the discussion of this hazard. These spaces are particularly difficult to deal with due to aerosol transmission and frequent shared surface contact, and they will have knock-on effects for the safety of the entire campus. If QM cannot sign off its bathroom facilities as safe or adequate due to higher demand if there are too few of them, even if the other work areas are, this means the conditions are not sufficient for a return to campus. This needs to be considered in the institution-wide RA.
Individual health questionnaires
These forms should not be held insecurely in manager email inboxes. Instead, an secure and confidential online repository should be created to which these forms can be uploaded.
COVID-19 virus exposure and transmission coming to and from work
Staff who have no practicable means of getting to campus other than public transport should not be forced to come to campus if they do not want to take it.
COVID-19 virus exposure and transmission during an emergency or incident response situation (e.g. fire evacuation)
(no specific comments)
COVID-19 virus exposure and transmission from visitors and contractors
Temperature and symptom checks should be conducted, as with staff/students above.
COVID-19 virus exposure and transmission from inadequate or insufficient environmental cleaning
A system is needed for constant communication of the time and date of the last deep clean in each space that all staff and students can access or see clearly – a paper-based system on the entrances is acceptable and perhaps even preferable to an online system, but whatever the method it must be clear and accessible to students and staff exactly when the space has last been cleaned.
COVID-19 virus transmission through handling goods, materials and other deliveries on and off campus
(no specific comments)
COVID-19 virus exposure and transmission through work-related travel
As with travel to and from campus, no one should be forced to travel on public transport if no practicable alternatives are available – it must be voluntary.
Infrastructure and maintenance health & safety issues arising from buildings that have been fully or partially closed
(no specific comments)
Psychological wellbeing of staff returning to campus / continuing to work from home
While the risk assessment refers to some of the psychological factors linked to stress and other mental health issues, it does not address the crucial link between increased workload and stress. Switching to online teaching delivery, dealing with the disruption to normal processes, trying to catch up on lost time, recovering from illness, caring for loved ones, childcare and home schooling have already increased staff workloads significantly. This burden has also been distributed unequally: there is significant evidence that the pandemic is having a disproportionate impact on women, BAME staff, staff with disabilities, those with caring responsibilities, and older staff.
There is also the prospect of significantly increased workload for many staff due to the introduction of VSS and other voluntary options, as well as the redundancy of large number of staff on fixed-term contracts or the reduction of TA/TF teaching hours. The prospect of further job losses and organisational change has created uncertainty which has added to staff anxiety significantly. This increased workload is a clear hazard which needs to be risk assessed. The HSE Management Standards approach should be used to assess current staff stress levels. This approach is common throughout the HE sector but has not been widely used at QMUL.
Although monitoring of staff wellbeing by line managers and VP Leads is listed as an existing control under the first hazard regarding home working, our members report that implementation of this has not been widespread or sufficient. Moreover, even if this monitoring has taken place in some parts of the university, this has not led to improvements because line managers are often constrained by strict control from the centre. The risk assessment claims that the university is “[e]ngaging with staff and trade union representatives through existing communication routes to explain and consult on any changes in working arrangements. Process set up and consultations have been occurring.” However, as the unions have commented repeatedly, these consultations have been inadequate and confined mainly to the Covid-JCF, which is not a safety committee and where meetings are infrequent and short. Above all, the university’s decision to renege on its recognition agreement with UCU in the middle of the pandemic and then to refuse an offer of ACAS mediation has exacerbated all of these problems.
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