Covid-19 Policy statement

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Table of Contents

1. Policy overview

2. Policy statement 

3. Objectives 

4. Policy Principles 

5. Understanding the risks to our workplace 

6. Clients and Visitor interactions 

6.1 Office visitor register

6.2 Asking clients screening question 

6.3 Framework for client service during COVID-19 

7. Supporting the health and safety of employees in the workplace

7.1 Vaccination 

7.1.1 Vaccination register 

7.1.2 Future recruitment of roles 

7.2 Physical distancing 

7.3 Regular and thorough hand washing as well as good hygiene in the workplace 

7.4 Make sure the work environment in clean 

7.5 Face Masks 

7.6 Travelling to and from work 

7.7 Support for employees 

8. Responsibilities 

8.1 Chief Executive Officer 

8.2 Managers

8.3 Employee 

9. Definitions 

10. Monitoring, evaluation and review 

11. Further information, additional resources & associated documents 

CONTENTS

1. Policy overview

Scope and purpose of this policy

At Caritas Wellness the health and safety of our employees, clients and “others” we may engage with is of primary importance.

Through this COVID-19 Safe Workplace Policy, Caritas Wellness recognises it’s responsibilities under the NSW Work Health and Safety Act 2011 to ensure a safe working environment and will support and protect our employees, clients, stakeholders, and the workplace by managing the risk as far as reasonably practicable to ensure our workers are safe and well.

Applicability and target groups

All Caritas Wellness employees must comply with this policy. Therapists should ensure that all are aware of and understand how to apply this policy.

If you are unclear or are unsure about how to apply the policy, contact Paul Nierves.

Legislative environment

• Work Health and Safety Act 2011

• Work Health and Safety Regulation 2017

• Code of Practice - How to manage work health and safety risks (SafeWork Australia)

2. Policy statement

Caritas Wellness, including all managers, therapists, and others must work together to reduce the spread of COVID-19 while at work. A risk management approach must be used to eliminate and/or minimise the risk of spreading or contracting COVID-19 in the workplace so far as is reasonably practicable.

The objectives of this Policy are to, as far as reasonably practicable:

• Achieve a safe and healthy workplace

• Consider the risks of COVID-19 in the context of our work activities, the people we work with, the places where we work and the nature of our work

• Involve our employees and other stakeholders in the development of this Policy through consultation and communication

• Identify, control and monitor the effectiveness of COVID risks in the workplace

• Enhance our employee’s knowledge through continuous, timely and accurate information and education on COVID risks

4 COVID-19 Safe Workplace Policy

3. Objectives

Our aim is that:

• We have a safe work environment and comply with our work health and safety duties.

• Managers consult with employees to understand concerns they may have about returning to the workplace and work together to ensure the workplace is COVID safe.

• Employees raise any work health and safety concerns with their Health and Safety Representatives (HSR) or manager.

• We conduct risk assessments to manage the risk of COVID-19 entering and spreading in the workplace and implement control measures to eliminate and/or minimise these risks so far as is reasonably practicable.

• Risks are assessed that result from any changes to work practices, procedures, the work environment, and from public health information, and are communicated with employees and HSRs about any changes that have been put in place or updated.

• All employees are aware of COVID-19 symptoms such as fever, cough, sore throat, shortness of breath, runny nose, loss of taste or loss of smell in themselves, colleagues, clients and stakeholders

• Employees advise their Manager if they:

✓ are unwell or experiencing symptoms of COVID-19

✓ have been in close contact with a person who has COVID-19 or

✓ have been tested for COVID-19 and direct them to stay home

• Employees understand their workplace entitlements if they have COVID-19 symptoms or they are required to self-quarantine (such as access to paid leave).

4. Policy Principles

Our COVID Safe Workplace principles underpin our whole approach to managing the risk of COVID and apply to all decisions regarding our risk assessments, effective controls and supporting employees.

Committed

Caritas Wellness strongly supports our workforce to be protected by way of the highest control measures (applying the Hierarchy of Controls) available in safeguarding themselves, their families, our clients and the community in general.

We will consult with our workforce, contractors and others regularly to make sure that the controls implemented to reduce the risks of COVID-19 are understood and workers can participate in decisions around those controls.

Safety first

We strive to achieve the highest level of protection and therefore recognise the higher the control measures put in place for employees, the better we can reduce the risk to our employees catching and/or transmitting the virus to each other, and to our clients both directly and/or indirectly.

Supportive

We support a risk assessment for employees who are not vaccinated in the context of their role, interaction with clients, colleagues and communities, and the available risk controls to provide as much protection as we can to our clients and their communities, and to our employees and their families.

Consistent and aligned

Our principles are in keeping with the Government’s direction as well as being consistent with the research, science and with other Public Sector Agencies.

5. Understanding the risks to our workplace

Identifying and controlling risks to employees, and other persons connected to the workplace, arising from exposure to COVID-19 within Caritas Wellness involves:

• Closely monitoring official advice, such as updates from the NSW Government and Department of Health and the Public Health Orders

• Reviewing measures for infection control, including educating employees on best practice

• Ensuring employees are aware of the isolation/quarantine periods in accordance with advice from the Department of Health

• Providing clear advice to employees about actions they should take if they become unwell or think they may have the symptoms of Covid-19.

• Considering how our work activities put employees or other people at risk and the development of controls i.e. social distancing at reception, phone services instead of face to face;

• Contingency planning to manage employees’ absences and plans to manage change in workloads

• Providing employees with information and links to relevant services should they require support 

• Undertaking COVID-19 Safe Workplace risk assessment and regularly reviewing and monitoring controls

• Managing the risk of client contact during COVID-19 Delta Variant 

• Regularly surveying employees to consult with them on their wellbeing and appropriate strategies to mitigate risk.

6. Clients and Visitor interactions

Keeping employees safe in their daily interactions with Clients and/or Visitors is one of Caritas Wellness’ key client service principles.

Taking additional precautions in allowing clients or visitors to re-enter the workplace is important for Caritas Wellness in limiting exposure to COVID-19 in the workplace.

6.1 Office visitor register

Each non-employee (and non-client) that comes into a Caritas Wellness practice must have their details recorded in the Office Visitor Register. Employees need to fill out this form for any visitors, including contractors to the office each day.

6.2 Asking clients screening question

Caritas Wellness employees have the right to ask clients and visitors to provide information in advance. The screening questions are based on NSW Health guidelines and relevant public health orders that are drafted to ensure no visitors/clients /staff visit the office who are an immediate COVID-19 exposed risk.

6.3 Framework for client service during COVID-19

Caritas Wellness is taking a phased approach to contact with our clients and stakeholders depending on the risk being posed by COVID-19.

A framework with five (5) levels has been developed to provide a guide to the protocols and approvals required for:

• seeing clients in person in an office during COVID -19.

7 COVID-19 Safe Workplace Policy

The Manager determines the level based on the level of risk in the community and associated NSW Health advice.

This means we will be flexible to move up or down levels at short notice. The levels of contact reflect safe working for our employees in a time of rapid change.

7. Supporting the health and safety of employees in the workplace

7.1 Vaccination

Caritas Wellness has determined that being COVID-19 vaccinated is a conditional requirement for all employees to protect the health and safety of the community and workplace.

We have taken a risk management approach to determine the control measures implemented to prevent workplace transmission of COVID-19 and acknowledge that SafeWork NSW considers vaccination a high order risk control measure against disease.

There may be medical reasons that will prevent some employees from receiving a COVID-19 vaccine. These employees will need to provide medical evidence in the form of a contraindication certificate in the form approved by the Chief Health Officer that indicates they are not able to get vaccinated.

Other employees may have a protected attribute that may prevent some employees from receiving a COVID-19 vaccine. These employees may need to provide supporting evidence.

8 COVID-19 Safe Workplace Policy

Caritas Wellness will support an individual risk assessment for employees who are not vaccinated (for example due to medical contraindications or protected attribute) of the risk based on:

a. The role they have at Caritas Wellness including where they perform that role

b. Their extent to which they have contact with clients and other employees, and others we contract to do our work such as private practitioners

c. To what extent the risk based on the assessment of (a) and (b) can be controlled by PPE and/or testing and/or other means

d. Based on (a), (b), and (c), a decision is made as to whether that employee can continue to safely perform their function. (Considerations given to role redesign, re-deployed, or do they need to be supported to job seek for a period of up to three months before exiting Caritas Wellness employment).

7.1.1 Vaccination register

Caritas Wellness will keep a vaccination register of employee’s vaccination status to support the conditional requirement for all employees be vaccinated to protect the health and safety of the community and workplace.

The information will be kept securely in accordance with Health Records and Information Privacy Act 2002 and access limited to nominated officers in HR and Executive

7.1.2 Future recruitment of roles

All Caritas Wellness recruitment actions will establish the same level of protection with regards to COVID-19 safety protocols and as such will expect all applicants to be vaccinated if suitable to do so.

7.2 Physical distancing

General considerations

• cease shaking hands to greet others;

• avoid non-essential travel;

• when on site, restrict your movements in the workplace to the bare minimum required

Common areas

• eat lunch at your desk or outside rather than in the lunchroom;

• limit food handling and sharing of food in the workplace;

Meeting and Conference rooms

9 COVID-19 Safe Workplace Policy

Most meeting rooms within Caritas Wellness Office have the room capacity listed. Employees must check this prior to room use to ensure appropriate physical distancing.

Lifts and lift foyers

In the lift lobby or waiting area:

• ensure you maintain a physical distance from others of 1.5 metres, to the extent possible;

• follow signage around lift waiting areas including reminders to practice physical distancing and good hygiene while waiting for and using lifts, including the requirement to wait for another lift if the lift is full;

• follow any advisory on passenger limit for each lift if available.

Within lifts:

• you must maintain physical distancing, to the extent possible. Lifts must not be overcrowded, and users should avoid touching other users;

• practice good hygiene in lifts. If you need to cough or sneeze during a journey you must do so into your arm or a clean tissue;

• good hygiene by washing your hands, or where this is not possible, use appropriate hand sanitiser, after exiting the lift, particularly if you touched lift buttons or rails;

Do not come into work, including using lifts, if you are unwell.

7.3 Regular and thorough hand washing as well as good hygiene in the workplace

Caritas Wellness has taken various measures to control the health risks to our workforces, including:

• Providing alcohol-based hand sanitiser in addition to providing handwashing facilities such as running water and soap.

• encouraging employees to maintain good hygiene by frequently washing their hands for at least 20 seconds with soap and water or use hand sanitiser. Particular attention must be taken when using the toilet and before preparing and eating food; avoid touching your eyes, nose, and mouth with unwashed hands;

• encouraging employees to actively follow good hand hygiene promoted via posters round the office in relation to COVID-19 and available from NSW Health.

• Encouraging employees to cover their cough, nose and mouth when coughing and sneezing with tissue or a flexed elbow;

• Encouraging the disposal of tissues immediately, and use of alcohol-based hand sanitiser after disposing

• Caritas Wellness will use posters and signage such as hand washing protocols to remind employees and others in the workplace of hygiene and cleaning requirements;

10 COVID-19 Safe Workplace Policy

• Avoid physically obtaining evidence such as files, briefs etc. and do so electronically if possible. If this can not be avoided, ensure appropriate hand hygiene after handling documents (see above); and

• Avoid physically sharing items e.g., pens, hybrids, keyboards.

7.4 Make sure the work environment in clean

• Managers, therapists, and employees MUST wipe high touch surfaces (e.g. counters, desks and massage tables) and objects (e.g. telephones, keyboards) with disinfectant several times a day – they are not to wait for cleaning services to do so;

• Employees are encouraged to avoid sharing equipment. Where this is not possible (such as with activity-based working, hot desking, lunchrooms) ensure equipment is cleaned appropriately between users;

• Managers are to ensure suitable cleaning equipment is provided and readily available;

• Employees are to make sure their workplace is regularly cleaned and disinfected. High touch surfaces such as door handles, lift controls and amenities should be cleaned more regularly – see Safe Work Australia cleaning and disinfecting guidance for further information.

7.5 Face Masks

Wearing a face mask helps to reduce community transmission of COVID-19. 

• Employees are encouraged to keep up to date with any changes such as localised outbreaks and follow advice and restrictions;

• Masks are available from Office Managers’ or Manager and it is important to know how to use and dispose of them correctly; and

• Employees must carry a clean face mask with them at all times and wear it if it is mandatory to wear a mask or if you cannot maintain 1.5 metres of physical distance from others.

Important: a mask is not a substitute for good hand hygiene and physical distancing.

7.6 Travelling to and from work

COVIDSafe Travel Choices can help employees make the right decisions about how and when to travel for work, as restrictions begin to ease, and we transition into the new normal.

To travel safely it’s essential for employees to plan their trip before deciding to make the journey for work, and to reconsider the times to travel if the transport network is busy. Estimated capacity information is now available in the Trip Planner and Opal Travel App for all metro and train, Opal-enabled bus, ferry and light rail services, to help employees plan ahead.

7.7 Support for employees

Employees may be anxious about the COVID-19 pandemic and have questions about how their workplace and employment may be impacted by the continuing and evolving nature of the COVID-19 pandemic.

Managers must consult with employees to understand concerns they may have about returning to the workplace and work together to ensure the workplace is COVID safe.

Employees are to be encouraged to raise any work health and safety concerns with their Health and Safety Representatives (HSR) or manager.

4. Notify: the practice manager.

5. Clean: and disinfect the room/area where the employee was isolated along with their general work area. Also, clean and disinfect the areas where the person and close contacts have been. Do not use those areas until this process is complete. Use PPE when cleaning;

6. Monitor: The employee is to remain on sick leave until they receive their test results;

Upon receipt of the test results the individual will either be advised by NSW Health to self-isolate or are cleared to return to work;

7. Inform and review: If the results are positive public health officials will advise of any additional actions Caritas Wellness need to take including notifying contacts, cleaning and the requirement to send any other employee’s home.

However, consider who the person has had close contact with. If instructed by public health officials, tell close contacts they may have been exposed and follow advice on quarantine requirements.

• employees assisting a potentially infectious person should have appropriate PPE and follow hand hygiene procedures;

• consult with employees and allow them to raise concerns;

• notify SafeWork NSW. See the Incident Notification fact sheet;

• Comply with privacy obligations. Seek guidance from Inhouse Counsel; and

• Always follow the advice of health officials.

8. Responsibilities

8.1 Chief Executive Officer

It is the responsibility of the Chief Executive Officer (CEO) to ensure a healthy and safe working environment by:

• ensuring systems are in place to identify, manage and monitor health and safety risks associated with the COVID-19 disease;

• ensuring that Caritas Wellness makes available, and utilises, the appropriate resources and processes to eliminate or minimise risks to health and safety from work carried out as part of daily activities; and

• ensuring that effective support systems such as an employee assistance program are in place and accessible to employees.

• implement preventative actions to manage COVID-19 risks in the workplace;

• review investigation reports for incidents that are notifiable to SafeWork NSW and/or result in a worker’s compensation claim; and

• ensure that effective corrective action is taken following reports of COVID-19 risks.

8.2 Managers

Managers have a responsibility to:

• Proactively ensure the health and wellbeing of their employees through creating an environment where employees are encouraged to seek help when needed;

• Regularly discuss wellbeing at regular team meetings and regular individual employees’ supervision;

• ensure that all employees and other relevant stakeholders are made aware of this policy;

• identify and manage the risks related to COVID-19 in the workplace and provide individualised support to any affected employee;

• provide individual regular check-ins aligned with individual needs;

• report all occasions where evidence of health and safety COVID-19 risk is apparent; and

• provide regular check ins with all employees, especially when they are working remotely, in isolation or just not coping as well.

8.3 Employee

All employees have a responsibility to:

• understand this policy and seek clarification from management where required;

• advise their Manager if they:

✓ are unwell or experiencing symptoms of COVID-19

✓ have been in close contact with a person who has COVID-19 or

✓ have been tested for COVID-19 and have been directed to stay home

• be aware of COVID-19 symptoms such as fever, cough, sore throat, shortness of breath, runny nose, loss of taste or loss of smell in themselves, colleagues, clients, and stakeholders;

• understand their workplace entitlements if they have COVID-19 symptoms or they are required to self-quarantine;

• complete the vaccination register accurately and honestly and to ensure their details are up to date;

• support fellow team members in their awareness of this policy;

• take reasonable care of their own health and safety;

• take reasonable care that their actions do not affect the health and safety of other people in the workplace;

• take responsibility for their own health, safety and ability to perform the duties for which they are employed. This includes taking appropriate steps to address any health issues they may have/develop, if these impact on their capacity to safely perform the inherent requirements and demands of their role;

• support individuals to raise issues in supervision if they need help or are not coping;

• understand connect to support options both within Caritas Wellness and externally should early warning signs be apparent within themselves or in others;

• cooperate with workplace policies and procedures; and

• support initiatives aimed at improving COVID-19 health and safety in the workplace.

9. Definitions

Client

Caritas Wellness defines a client as a person who uses the services of Caritas Wellness or another party in a matter (e.g. a parent in a family law matter who does not have a grant of legal aid).

Manager

Is any person who has charge and direction of a work area, other persons, and/or work practices, even if the title does not contain the word ‘manager’ in it.

Risk Management

Co-ordinated activities to direct and control an organisation with regard to risk. A risk management process is the systematic application of management principles, procedures and practices to the activities of communicating, consulting, establishing the context, and identifying, analysing, evaluating, treating, monitoring and reviewing risk.

Reasonably practicable

As defined under the Work Health and Safety Act 2011.

Employee

Any person employed by Legal Aid NSW, either full-time, part-time or on a casual basis to undertake work on behalf of Legal Aid NSW.

10. Monitoring, evaluation and review

This document is to be reviewed initial in (6 or 12 months) and then every three years. Effectiveness of the policy will be assessed through:

• feedback from workers, the Health and Wellbeing Committee (if applicable), and management

• review of the policy by management and committee to determine if objectives have been met and to identify barriers and enablers to ongoing policy implementation.

11. Further information, additional resources & associated documents

• Framework for Client Service during COVID-19 Delta Variant

• Framework for a COVID safe workplace during COVID-19 Delta Variant

• Legal Aid NSW three month roadmap during COVID-19 Delta Variant