COVID-19 UK: Energy and Infrastructure – Update on Site Operating Procedures in the Construction Industry – Update

April.15.2020

The Construction Leadership Council (CLC) has now published version 3 of the Site Operating Procedures (SOPs), aimed at protecting the construction workforce during COVID-19.

What does the amended guidance cover?

The updated guidance covers how construction sites should manage risks associated with the spread of COVID-19. In particular, the rule of workers staying two metres apart should be respected as far as possible, and is supplemented by the “hierarchy of controls”. The hierarchy of controls is comprised of six categories of consideration and practical measures to adopt where social distancing is not possible, and is as follows: eliminate; reduce; isolate; control; PPE; and behaviours.

Key points to note are:

  • Risks can be mitigated through exclusionary means (such as the exclusion of workers exhibiting symptoms of COVID-19, and the avoidance of skin to skin contact) and practical measures (such as limiting site meetings to only “absolutely necessary” participants, and the use of alternative or additional mechanical aids to reduce worker interface).
  • The guidance concedes that in some cases it will not be practical to apply social distancing, and such situations should be minimised in terms of time and frequency. Similarly, such risks should be reduced by regular cleaning of common contact surfaces and equipment.

Differences from previous guidance

The striking difference between these updated SOPs and previous versions is the depth of detail now covered to ensure safety while performing work. The updated SOPs are now aligned with Public Health England (PHE) guidelines, clarifying that an ongoing monitoring exercise must be undertaken at sites where work is continuing, introducing consistency across what we have been hearing from the Government and regulators, which will no doubt be welcomed by the industry. Last week, BEIS released guidance that construction work may continue if done in accordance with the PHE social distancing guidelines wherever possible – reiterating that employers should continue to monitor ongoing arrangements to ensure the safety of workers.

The original version of the SOPs published on 23 March 2020 was much less prescriptive in terms of how recommendations could be practically carried out; the updated SOPs address many of the general principles introduced in the original SOPs by providing practical advice through the hierarchy of controls. For example, version one suggested that workers should travel to site using their own transport, which is expanded in version three to include advice for those who have no option but to use shared transport. Additional guidelines have been provided setting out when workers should and should not travel to work, adopted from advice from both BEIS and the UK Chief Medical Officer.

Practicalities

The amended SOPs should be welcomed by the industry for the practical and pragmatic advice they seek to provide (in alignment with current Government and industry guidance), especially given the confusion that was caused by the issue of the second edition of the SOPs which resulted in its swift withdrawal within hours of release.

It is notable that the amended SOPs do not advise the cessation of non-essential physical work requiring close contact between workers (which was suggested in version one) – putting the onus on those operating sites to ensure that the SOPs are being followed; counterbalancing on the one hand, the protection of workers as the paramount concern, whilst on the other ensuring continuity of work in the sector (without limiting the type of work being carried out).

For both project developers and contractors facing the question of how to proceed with projects undergoing construction, the stance to be taken in terms of ongoing work is clearer (with a greater focus on practicalities and commercial considerations) now than it has been since the beginning of the lockdown.  This should provide some relief for market players invested in renewable projects benefitting from subsidies that are striving to meet commissioning deadlines, and of course, more generally given the cost of any delay to project completion and commercial operations.  Whilst they will inevitably receive some resistance and criticism, the latest version of the SOPs should be seen as a positive step and, together with lockdowns being lifted in countries that play a key role in the supply chain, there is some cause for optimism in relation to project development and construction in the energy and infrastructure sectors.