We have updated this checklist to support leaders in putting in place appropriate measures that will keep students and staff safer. The Welsh Government’s Framework permits leaders to adopt additional proportionate safety measures where they wish to do so. This checklist sets out a range of measures that we urge settings to adopt as standing practice, subject to review at half-term.
The Welsh Government has chosen to remove most requirements for safety measures in schools and other settings, a decision which could lead to an increase in Covid cases and disruption. However, there is a Framework in place, for mitigations to increase, if the risk level nationally or locally increases.
We acknowledge that the situation in respect of Covid-19 has changed, across the education service and in the wider community, because of the implementation of the vaccination programme.
However, rates of Covid-19 infection in the wider community are higher than this time last year, and the vaccine has not yet been offered to many pupils. We believe, therefore, that effective safety measures remain important, in order both to reduce the extent to which the virus is spread within schools and colleges and within the wider community, and to reduce the extent that staff and students are absent due to Covid or suffer its ill-effects, including those of Long Covid.
Whilst we acknowledge the Welsh Government Framework, we are concerned that the “risk ratings” for levels of the virus set by Welsh Government remain unclear. Therefore, we ask leaders to implement the proportionate measures set out in our checklist as a preventative step to reduce the chances of outbreaks. We have updated this checklist to support leaders in putting in place appropriate measures that will keep students and staff both safe. The Welsh Government’s Local Covid 19 Infection Control Decision Framework for schools from Autumn 2021 permits leaders to adopt additional proportionate safety measures where they wish to do so. This checklist sets out a range of measures that we urge settings to adopt as standing practice, subject to review at half-term.
Using this advice
This joint advice aims to help union reps to understand the current Welsh Government advice (found here) and ensure that appropriate risk assessments and safety measures are in place which make the workplace as safe as possible.
It also aims to help leaders with their difficult responsibilities, by providing comprehensive advice and supporting them to ensure confidence through full consultation and communication.
It is aimed specifically at schools, but its principles can and should be applied in other settings.
Union workplace reps and health and safety reps should seek regular meetings with their workplace management in order to review safety issues, including Covid-19 safety issues. If members have concerns about safety measures proposed or areas not addressed, then support will be available from their union.
The Welsh Government advice continues to emphasise the importance of risk assessments that are regularly reviewed and updated.
The joint unions recommend that leaders consider the following when considering and reviewing risk assessments:
- The risk assessment process should have considered all the areas identified in Welsh Government advice and in joint union advice (see below), fully evaluate the risk of harm, including local prevalence, and identify the measures to apply in each area.
- Risk assessments should be conducted and reviewed in consultation with union reps/health and safety reps and staff.
- Agreed safety measures should be reviewed whenever national or local guidance changes, local rates increase, or new variants become prevalent.
- Revised procedures should be clearly communicated to staff, students, parents/carers, contractor staff, visitors and visiting workers.
- The position of the most vulnerable staff should be adequately considered through individual risk assessments.
Question to reps and members:
- Are you and your colleagues satisfied with the risk assessment process, or do you feel the situation is unsafe due to omissions or errors in the process and measures adopted?
Social distancing and safety measures
Safety measures in relation to Covid-19 have addressed a range of inter-connected factors – in particular the mixing and distancing of staff and students and measures to reduce the risk of transmission such as face coverings, ventilation etc.
The Welsh Government has removed the recommendation for students to socially distance or stay in bubbles. Face coverings are only advised for students, staff and visitors in classrooms or communal areas when the circulation of the virus is ‘high’. Other measures such as improved ventilation and maintenance of cleaning and hygiene regimes continue to be recommended as an essential part of systems to restrict transmission in educational settings.
However, the Welsh Government has been clear that settings can choose to apply safety measures they think necessary depending on their local risk and circumstances. Each setting and each classroom are different. We advise members to consider the following issues and then decide collectively whether working arrangements are satisfactory. If not, seek to raise these issues with management through the channels which should be in place already, and if necessary, seek our support.
- Social distancing measures that limit interaction and reduce the risk of virus transmission without causing disruption to ordinary activities should continue to be maintained as far as possible.
- Students and staff should be regularly reminded that maintaining social distancing reduces the risk of transmission.
- Arrangements such as one-way systems that minimise the extent of contact and mixing during circulation around the premises should be maintained.
- Large gatherings such as whole school or whole year group assemblies should be avoided wherever possible to reduce the risk of transmission.
- Face-to-face staff meetings and parents’ evenings should be avoided as far as possible. They should be held online wherever possible and should have appropriate social distancing maintained where there is no alternative to them being held in person.
- Staggered timings for lunch breaks, other breaks and start and finish times should be used as much as possible. These measures can have a wider benefit beyond just helping to reduce transmission risk.
- Arrangements for students and parents queuing on arrival, parents waiting to collect students, staff supervising students on arrival or departure, reception of visitors etc, should continue to maintain appropriate distancing.
- Arrangements for transport, including when travelling, boarding and disembarking should continue to be subject to regular review with mask-wearing and social distancing retained. Mask wearing is compulsory on public transport and school transport in Wales, for year 7 and above.
- Where there have been positive cases in individual groups, arrangements should be considered for limiting the interaction of the students and staff involved with other students and staff.
- In line with the Welsh Government framework, arrangements for maintaining social distancing in classrooms and elsewhere should always be considered in respect of all staff, especially those who are clinically extremely vulnerable or otherwise at significantly greater risk.
Face coverings and PPE
- Staff and students should be permitted to wear face coverings in all areas of the premises including classrooms if they wish to wear them.
- Personal protective equipment (PPE), including FFP2 or FFP3 grade masks if appropriate, should be provided for staff administering first aid, medical care or personal care activities where social distancing cannot be maintained, e.g., in some special schools and nurseries.
- Appropriate PPE should be provided for catering, cleaning, and estates staff.
- Appropriate PPE should also be considered in respect of staff who are clinically extremely vulnerable or otherwise at significantly greater risk and are working in the workplace, as part of their risk assessment.
- Secondary settings should actively encourage staff and students to wear face coverings around the premises (including in classrooms), and urgently consider the case for continuing to require their wearing, particularly in areas with high case rates. In ‘high’ and ‘very high’ risk levels, this is already recommended by Welsh Government.
Ventilation and cleaning
- Ventilation arrangements should be prioritised for the autumn term and existing arrangements reviewed to improve ventilation and ensure maximum ventilation of all spaces.
- CO2 monitors should be made available to enable regular monitoring.
- Additional measures and equipment should be introduced to aid and improve ventilation where necessary. Rooms with poor ventilation which cannot be improved in other ways should be fitted with HEPA filters (see our joint union ventilation guidance)
- Any areas identified as having unsafe levels of ventilation should be taken out of use pending improvements.
- Enhanced hygiene and cleaning regimes should be maintained throughout the premises, including arrangements for enhanced hand washing, for employing additional cleaning staff, and for additional payment to cleaning and estates staff for extra workload or hours worked.
- Contractors should be required to comply with this checklist and ensure full pay for all covid-related absences.
Question to reps and members:
Are you and your colleagues satisfied with arrangements for safety in individual classrooms and around the school/college?
Protecting staff at greater risk
Given the ongoing level of case rates, the position of staff who are at greater risk of adverse outcomes should they contract Covid-19 must continue to be properly considered and appropriate measures taken. This applies in particular to those staff identified as clinically extremely vulnerable (CEV) or unable to be vaccinated for medical reasons and to pregnant women in their third trimester of pregnancy. However, it must be recognised that all those who are at greater risk, even if fully vaccinated, will continue to be concerned that no vaccine offers 100 per cent protection against contracting the virus.
The joint unions' advice therefore is that:
- Individual risk assessments should be carried out - and reviewed where previously carried out - for staff defined as clinically extremely vulnerable (CEV) or unable to be vaccinated for medical reasons and for pregnant women in their third trimester of pregnancy.
- Consideration should be given to appropriate additional risk mitigation measures specific to the individual, including implementing additional social distancing, additional PPE such as FFP2 or FFP3 grade masks, and safer and better-ventilated working locations in the workplace.
- CEV staff should be supported to work from home by their employer where they request to do so following medical advice or an individual risk assessment.
- Pregnant women in their third trimester should also be permitted to work from home – if this is not possible, then medical suspension on full pay should be supported.
- Individual risk assessments should also be offered to other staff previously defined as clinically vulnerable or with characteristics that may put them at significantly greater risk, such as age, ethnicity, sex and disability, and for any staff concerned about household members who may be at significantly greater risk. Such assessments should consider the same type of additional safety measures as above.
- Appropriate PPE should be provided for any staff within the workplace who are at significantly greater risk.
See our full joint union advice for medically vulnerable and higher risk groups.
Question to reps and members:
Are colleagues who are at greater risk – in particular colleagues who are CEV, unable to be vaccinated or in the third trimester of pregnancy - satisfied with their working arrangements?
Testing, tracking and isolating
NHS Test, Trace and Protect (TTP) procedures are intended to ensure that all students who test positive will self-isolate from school/college for the necessary period. The Welsh Government removed the need for schools and colleges to oversee contact tracing, but TTP will still work with the school and those who test positive to identify contacts.
If you are identified as a close contact to someone who has tested positive for Covid-19, TTP will get in touch and offer PCR testing on Day 2 and Day 8.
- All leaders should comply with the NHS process, with all staff being encouraged to use the NHS Covid-19 app in school, including in classrooms, and self-isolating (if not fully vaccinated) when notified by the app or contacted by TTP.
- Welsh Government recommends that everyone working in schools, and all young people over 12, take two lateral flow tests (LFTs) before the start of the school term. Get your LFTs delivered to you here.
- All staff and students with Covid-19 symptoms should be expected to self-isolate, in line with Welsh Government advice, for the necessary period.
- Comprehensive safety arrangements should be in place for supervising students who develop Covid-19 symptoms prior to them going home.
- Welsh Government guidance offers LFTs on a twice-weekly basis to all staff and secondary students.
- Parents and carers should be encouraged to help ensure that secondary students test with LFTs on a twice-weekly basis, or daily when someone in the class has tested positive, and that all students seek a PCR test when a household member or other close contact has tested positive, in line with Welsh Government guidelines.
- Parents should be urged to let the setting know in advance if their child is planning to attend when a household member has tested positive.
- All staff, including outsourced staff such as catering and cleaning staff, should receive full pay when required to self-isolate, without any impact on their sickness absence record.
We urge leaders to continue to inform staff, parents, and students of any positive cases, without identifying any individuals directly or indirectly. This is important so that each employee, student, and their family are aware of the local risks and know what they need to do.
Question to reps and members:
Are the processes for informing the setting about positive cases satisfactory?
Avoiding excessive workload
The Covid-19 pandemic has hugely increased workload for many staff. By now, leaders should have taken steps to ensure that revised working arrangements minimise additional workload and other measures are taken to reduce overall working time.
- Regular reviews that seek to limit and reduce staff workload should continue to be conducted.
- Steps should continue to be taken to remove unnecessary working activities altogether and conduct others in a way which avoids the need for staff to be or remain present in the workplace unnecessarily.
- Demands to work outside normal responsibilities should be kept to a minimum
- PPA time and other non-contact time for classroom-based staff should be maintained.
- Arrangements should be put in place to support staff wellbeing, such as individual counselling support.
Question to reps and members:
Have leaders taken satisfactory steps to address wellbeing and reduce workload?
In Wales, we have agreed with the WLGA a protocol on Long Covid. This means that anyone who has been medically diagnosed as having Long Covid, will not be subjected to ‘normal’ sickness absence disciplinary procedures. This has been agreed with all local authorities in Wales. Contact your local District Secretary should you need any support with this.
Punitive action under absence management or other procedures is unreasonable, given that staff may have contracted Covid-19 at work. Such procedures should not be applied to staff diagnosed with Long Covid or awaiting such a diagnosis. Absence should also not be counted against sick pay entitlements, given that Covid–19 may have been contracted at work.
Staff absences related to Long Covid should be recorded separately and not be counted towards trigger points in any absence management procedures.
Question to reps and members:
Are leaders following the above arrangements on Long Covid?