COVID 19 in the UK and occupational health and safety -
predictable but not inevitable failures: what can we do
Andrew Watterson, Occupational and Environmental Health Research Group, Stirling
April 7th v5 2020. Technical Report Number 29 updated.
The physician, pathologist and social epidemiologist, Rudolf Virchow in the nineteenth
century observed that medicine was a social science and politics was nothing more than
medicine on a grand scale. Tackling epidemics of occupational disease in this context is
therefore as much about the politics and economics of occupational health and its
organisation as it is about the science.
The public health precautionary approach and related “prudent pessimist” philosophy
which is geared to preventive actions on occupational hazards seems most likely to
succeed in curtailing old epidemics and preventing new ones occurring. Its emphasis is far
less on defining occupational diseases and far more on identifying hazards and ensuring
their removal or the introduction of very large control measures to control potential risks
from hazards. Yet the UK system currently relies on tracking outcomes - occupational
diseases - rather than risks. (Watterson 1999. Why we still have old epidemics and
endemics in occupational health.)
“Based on other countries’ experiences, health care workers have been among the bulk of positive
COVID-19 cases. We need to protect all of our health care workers, especially those at the
frontline, because losing any of them means many COVID-19 patients will not receive the care
they critically need. Protecting our health care workers means giving them the tools and gear they
need to fight the virus. Losing any lives to the pandemic is devastating and society will be put at
greater risk of losing more if we unnecessarily sacrifice health care workers lives by not given them
the protection they need”. (Dr Bianca Frogner 2020 in USA)
Across the world dedicated health and social care professionals, emergency workers, key support
workers, service and other workers in our societies put their lives at risk to combat the COVID-19
pandemic. Nothing should distract from their efforts. For these workers to be effective it is vital to
protect their health and safety now and not in the unspecified future and in unspecified ways.
Failure to do so is ethically and morally wrong and will already have had repercussions for society
with increased morbidity and mortality. The threat to worker health and safety has not been
theoretical since December 2019 and so there has been and is no justification for inaction now.
Numerous lessons will be learnt, too late in many cases, about how we managed the UK COVID-19
pandemic and frequently ignored both early warning and early guidance. These are not new
pandemic lessons. Solutions to preventing risk from pandemic hazards have been known and
advocated in global and national agencies and by NGOs for many years. We can plan for military
activities over decades, spend many billions of pounds on military equipment including personal
protective equipment (PPE) and training and launch huge expensive vanity projects in the UK. It
should therefore be unproblematic to spend just millions of pounds planning in advance for a
specific pandemic ‘war’ by addressing occupational health and safety needs for health and other
workers through effective resources, staffing, training, procedures and stored equipment. Adequate
supplies of PPE, early and proper planning, risk assessment and management to protect worker
health and safety and the public health and are comparatively cheap as is basic regulation and
The UK pandemic is also occurring against a background of years of cuts in the health and social care
sectors and decades of cuts specifically in the occupational and environmental health and safety
sector. In all parts of the UK in late March 2020 there are still major challenges to protect all workers
from COVID-19. These ongoing health and safety challenges, some deep rooted and others easily
fixed quickly, include the need for better occupational health surveillance, more and extensive
testing, tracking and tracing along with the ‘shutdown’ measure now belatedly in force. They also
require politicians and scientific civil servants to act openly and urgently.
Many press conferences in March 2020 held by UK and devolved governments, when frequent and
difficult questions have been asked about the numbers of health and other workers who contracted
COVD-19 during work or work-related activities, often elicited no answers at all. Questions have
been asked about PPE supply, provision and suitability for key workers, and in early March non-
specific answers were given with no clear time-lines. Daily stories of UK health and emergency
workers making their own PPE, buying PPE from chain stores and sourcing their own sanitisers
provided a damning indictment of the state of occupational health and safety across this country.
This paper examines the occupational health and safety issues faced by all workers in a pandemic;
the state of knowledge about coronavirus in the context of the health and safety responses from
international agencies; and how UK politicians, government bodies, health professional bodies,
employers, non-governmental organisations & trade unions responded & should now respond.
International agencies have done better than the UK government & many scientific civil servants.
Some UK professional bodies have produced extensive health and safety advice and called for
improved PPE, others have been less active. NGOs and trade unions have generally been a very good
source of information on pandemic risks and acted early in analysing what was needed and why.
This paper examines in a rapid review a range of the occupational health and safety issues raised by
the pandemic COVID-19 drawing on global and UK reports and guidance, technical investigations
available up to March 31 2020. It additionally offers a snapshot of web-based grey literature
produced in the same period by or commenting on key organisations. The link between worker
health and public health is unescapable now (Berkowitz 2020).
COVID-19 has both similarities and differences with influenza. Both viruses cause respiratory disease
but there are important differences between the two viruses and how they spread. Both are
transmitted by contact, droplets and fomites (WHO 2020c). With mortality rates higher for
COVID-19 than flu, the importance of having effective health and safety measures becomes even
greater. Many of the general precautions needed to protect workers from pandemics like COVID-19
were identified after the flu pandemics in the 2000s and the Ebola outbreak in 2018. There has been
a widespread global recognition that a pandemic like COVID-19 would emerge but precisely what it
would entail and when it would happen was not known. Although there have been multiple global
problems and global failures in dealing with pandemics, important advice from international bodies
and important lessons from other countries in the frontline of the COVID 19 epidemic have still been
ignored and decisive action delayed by countries within the UK for reasons that are currently not
Recognition of any virus and its gene mapping are obviously critical to testing which in turn is critical
to screening which is critical to identifying and implementing effective occupational health and
safety measures as well as selecting and sourcing sufficient and suitable personal protective
equipment. These things are inter-twined . However, in the public domain questions of testing and
tracing are sometimes viewed as public health matters alone and may not be recognised as major
occupational health and safety influences. The occupational health and safety of health workers,
emergency workers and other key workers involved in dealing with the pandemic has not been as
well served as it should have been. It is still not. This paper focusses only on the occupational health
and safety and related dimensions of the pandemic.
The impact of COVID 19 has been unprecedented but not at all unexpected in several respects and
planning and responses have frequently varied from country to country. Corona viruses were first
isolated in 1937 in birds and in the 1960s there was evidence of human coronaviruses (Medical
News Today nd). By 2019, the US Centre for Disease Control was monitoring the outbreak of COVID-
19 in Wuhan, China. The first reported COVID case from a person infected in the UK was on February
29th 2020 (BBC 2020 February 29th) The exact timing and type of pandemic would not have been
known but the pandemic warnings came in 2019 and were acted upon relatively quickly in China,
Taiwan, South Korea and Hong Kong in ways that reduced the public health mortality and morbidity
figures at that stage especially in the latter two countries. The response to the COVID-19 pandemic
threat in parts of Europe and the USA was far tardier. Reflecting on the failures of dealing with the
Ebola outbreak, in the context now of Covid 19, two US researchers observed the following. “ We
don’t need another set of ‘lessons learned.’ We know what needs to be done. To fail to act is not
only an act of negligence; it is blood on our hands” (Diamond and Woskie March 2020) . The UK
actions we still need to take on protecting the health and safety of all workers from COVID are
equally clear and at present look far short of being adequately realised.
There are suggestions that we are ‘all in this together’ and that no one is responsible for the
pandemic impacts and related health and safety failings. Both statements are untrue. The
distribution of risks from COVID-19 is not equal across UK society. In addition to the high risks faced
by health and social care professionals in acute, primary care and community settings, evidence is
emerging for example that low-paid women in the UK are also at high risk of COVID-19 exposure
(Booth 2020) along with low paid workers elsewhere in our gig economy. The UK government has
called for all its citizens to act responsibly to stem the mortality from the pandemic.
After the pandemic has ended, it will be important to examine why the UK government did not
behave responsibly in planning and preparing for the pandemic that was globally predicted. The
argument has been made by the UK politicians and their chief medical and scientific advisors that
decisions about pandemic policy and their slow responses have been made solely on the basis of
‘the accepted science’. This argument was readily accepted and repeated by the politicians leading
the three devolved administrations. Whether this was always and consistently evidence-based
policy-making or at times policy-based evidence presentation reflecting special policy advisor and
non-scientific views will become clear over time. What is certainly the case is that decisions about
containment, testing and tracing had a profound effect on the health and safety of key staff and on
mortality and morbidity of the public in March 2020. Dither and delay has proved lethal and by the
third week in March, the expert UK view from those who were researching pandemics was that we
had lost at least nine weeks to prepare more fully for the public health outbreak (Sridhar 2020).
Preparations for the pandemic in the UK
It is already clear that UK government policy did not draw on and use the global empirical data and
WHO advice available from January 2020 onwards about both virulence, spread and control of
COVID-19 and information about best practice on PPE and other health and safety issues (Horton
2020: Sridhar 2020; Diamond and Woskie 2020). This does not of course mean that all the COVID-19
answers were available early in 2020. At the same time, there was no consensus in the scientific
community about the best approach to the pandemic and UK and NHS policy and occupational
health and safety practice has been changing regularly in March 2020 depending it would seem on
these different scientific approaches, the pressure from health and emergency staff faced with the
realities of failing government policy and public and media pressure. On occasions the UK
government bowed to this pressure. The timeline graph below identifies the extent of the UK delays
on early warnings. German researchers had developed a test to identify the virus within weeks in
early 2020 and tested many before the UK even started to get its act together and the Chinese
government had apparently worked out a very effective strategy to contain the virus. Testing and
containment of course are also highly effective mechanisms for preventing occupational health and
safety problems as well as protecting public health: the two things go hand in hand.
Until the disease emerged in China, the exact type of coronavirus was not known. However, planners
and researchers had identified the coronavirus group as a likely source of a future pandemic. Dealing
with flu and coronavirus hazards requires certain basic health and safety equipment. Particular
groups of workers may require a variety of personal protective equipment (PPE) – respirators,
masks, shields, gowns, gloves and so on depending on the job they do and the level of contact they
have with patients and the wider public. Immediately questions then arise about the supply,
suitability, availability, maintenance, storage and replacement of PPE. Such questions are standard
ones faced on a daily basis by occupational health and safety practitioners. Not all but many
answers are currently available although China has not yet resolved the merits of various types of
PPE for health staff when they found evidence for effectiveness lacking (Wang Q et al 2020).
Different standards for PPE also apply in different countries (Holland et al 2020).
In 2009 and 2015, researchers looked at the potential demand for and type of PPE needed including
respirators and surgical masks during a hypothetical influenza pandemic (Hashijura M et al 2009 ;
Carias et al 2015). They were clear respirators were an important component of the infection
control strategy and there were major logistical challenges in producing the numbers of respirators
and masks needed. Again, this is an early warning of what sort of planning and preparation on the
PPE front for health workers and others was needed. In March 2020 in the UK, months after the
pandemic appeared in China, it is self-evident that the lessons have not been learnt.
On the evidence currently available, it is difficult to dispute the conclusions of Dr Richard Horton in
the Lancet about the pandemic. He observed the Chief Medical Officer, the Chief Executive Officer of
the NHS in England, and the Chief Scientific Adviser in England had a duty in January “ to
immediately put the NHS and British public on high alert. February should have been used to expand
coronavirus testing capacity, ensure the distribution of WHO-approved PPE, and establish training
programmes and guidelines to protect NHS staff. They didn't take any of those actions. The result
has been chaos and panic across the NHS. Patients will die unnecessarily. NHS staff will die
unnecessarily. It is, indeed, as one health worker wrote last week, “a national scandal”. The gravity
of that scandal has yet to be understood” (Horton 2020: The pandemic is likely to prove one of the
worst failures ever to protect the occupational health and safety of health, emergency, social care,
service and other workers across the UK.
COVID transmission may occur by multiple routes. Research from China showed the virus could be
transmitted through the touching of contaminated surfaces, viral aerosolization in a confined space,
and contact with infected people who had no symptoms (University of Minnesota 2020). Knowledge
of these routes should have informed decisions weeks ago in the UK about occupational health and
safety precautions, availability of sanitisers, what PPE was needed, by whom and in what settings.
Information from Italy has provided further information about the occupational health and safety
risks run not just by health workers but many other key workers such as the police and support
workers in different settings. In the USA, researchers are noting that pre-pandemic training and
occupational health capacity in nursing facilities, long term care, prisons and home care where
transmission will occur was abysmal. UK readiness has been claimed but not evidenced.
It is entirely predictable that multiple work locations would be hit by the pandemic in the UK and it is
important to re-assess the pandemic planning currently in place as well as to carry out reviews after
the pandemic has ended.
This is because evidence has emerged in the last month that health and safety procedures and
equipment across the UK in these non-hospital/ primary care settings has been inadequate. Health
and safety shortcomings have not been picked up by governments or regulators across the UK but
for example by workers and their unions UNISON, and GMB in Scotland in social care settings with
regard to risk assessments and suitability of PPE. Up to March 31 across the UK , there has been
confusion about testing capacity and timetables: problems with PPE availability, distribution and
suitability for acute and primary care workers; and serious concerns about appropriate PPE and
supply of sanitisers for social care workers.
The occupational health and safety responses to COVID-19 and earlier flu epidemics from
international and UK organisations
Occupational health and safety is too often viewed as a cost and a burden on industry not an
investment because the human and economic costs of failures to protect workers can be offloaded
on the victims, their communities and the NHS. The costs are externalised and so we all pay for bad
employer and bad business practices. Health and safety is frequently hidden away or sometimes
used by governments to mount ideological and not evidence-based attacks on so-called red tape –
elf and safety parodies. It can be considered marginal, primarily affecting industrial and construction
workers. Ignoring workplace health and safety and cutting budgets of those agencies who deal with
workplace health and safety has ironically been frequently viewed as a ‘safe’ option because few
people would be affected by such cuts. This was never the case because poor occupational health
and safety through disease and injury adds to NHS treatment costs and patient numbers.
The COVID pandemic has made the links between occupational health and safety and wider public
health very stark indeed. It has also highlighted the fact that not only the health and safety of health,
social and emergency workers is critical to fighting the pandemic but so too is the health and safety
of key workers in the service, retail , transport, distribution and manufacturing sectors.
Pandemics inevitably raise important questions about the role of global agencies such as the WHO
and ILO and national governments and their agencies in terms of regulating, reducing or ending
movement of peoples during a pandemic and at what stage such decisions should be taken drawing
on what information. UK professional bodies, employer groups, trade unions and non-governmental
organisations have also explored what should and could be done about COVID-19 health and safety.
This section therefore briefly outlines and examines some of the work of these bodies on the
International agencies have a key role to play in disseminating information. Their work is usually
based on careful study of past problems and likely future threats to global health. These agencies
themselves may be seriously under-staffed, under-funded and under-resourced which limits what
they can do and there may be other problems relating to their effectiveness ( Ladou et al 2018).
Nevertheless, they still produce the most comprehensive and practical advice about the best public
health policies for nations to adopt when faced with pandemics and did so on COVID-19.
1.The World Health Organization (WHO)
The WHO has been able to disseminate valuable COVID information, based on its earlier work as well
as the Chinese and South Korean experiences, to many other countries in 2020. Along with other
international agencies it identified a range of appropriate measures necessary to deal pandemics
involving planning and equipping health staff with suitable health and safety equipment.
Prior to 2019, it produced a manual, the Health Wise Action Manual: Work Improvement in Health
Services, to guide health workers on a range of topics including the control of occupational hazards
and improving workplace safety (WHO 2014). Reports from a number of UK workplaces in 2020
would seem to indicate UK COVID practices fell short of this WHO guidance.
In 2018, the WHO with the ILO, produced a manual specifically addressing occupational safety and
health in public health emergencies and the steps needed to protect health workers and responders
(WHO 2018a). It included guidance for employers on their rights and duties and information for
workers on their rights. One chapter was devoted to occupational health and safety in
communicable disease outbreaks including Ebola and contained information about hand hygiene,
risk assessment for the appropriate use of PPE; cleaning and disinfection of the patient environment
and patient-care equipment; laundry and waste management; and respiratory hygiene. In the same
year WHO produced key facts on ‘Managing epidemics’ including information on worker health and
safety planning and PPE (WHO 2018b). Again, in the UK reports on COVID that have emerged from a
wide number of workplaces including hospitals and primary care practices show such advice,
procedures and information available from WHO at the time were not always used and followed.
By January 2020 the WHO was producing documentation and checklists for all countries on risk
communication and community engagement readiness and response to the 2019 COVID pandemic .
This was relevant to ensuring the health and safety of communities and health workers (WHO
2020i). In February 2020 WHO produced guidance on getting workplaces ready for COVID-19 (WHO
As WHO indicated “ Employers should start doing these things now, even if COVID-19 has not
arrived in the communities where they operate. They can already reduce working days lost due to
illness and stop or slow the spread of COVID-19 if it arrives at one of your workplaces”.
Basic information about ensuring workplaces were clean and hygienic, promoting regular and
thorough hand-washing by employees, contractors and customers and pitting sanitizing hand rub
dispensers in prominent places around the workplace was listed. In the UK in March 2020 it was
clear that in many workplaces including hospitals, these basic steps had not been taken and there
appeared to be little sign of inspection and action by regulators to improve conditions to protect
workers faced with COVID-19 threats.
The WHO also produced COVID-19 pandemic guidance on the rights, roles and responsibilities of
health workers, including key considerations for occupational safety and health (WHO ndi) . The
WHO indicated “ health worker rights include that employers and managers in health facilities:
assume overall responsibility to ensure that all necessary preventive and protective measures are
taken to minimize occupational safety and health risks; provide information, instruction and training
on occupational safety and health, including; refresher training on infection prevention and control
(IPC); and use, putting on, taking off and disposal of personal protective equipment (PPE); provide
adequate IPC and PPE supplies (masks, gloves, goggles, gowns, hand sanitizer, soap and water,
cleaning supplies) in sufficient quantity to healthcare or other staff caring for suspected or
confirmed COVID patients. ….. consult with health workers on occupational safety and health
aspects of their work and notify the labour inspectorate of cases of occupational diseases; not be
required to return to a work situation where there is continuing or serious danger to life or health,
until the employer has taken any necessary remedial action; allow workers to exercise the right to
remove themselves from a work situation that they have reasonable justification to believe presents
an imminent and serious danger to their life or health. When a health worker exercises this right,
they shall be protected from any undue consequences.”
Accounts from UK health professionals, paramedics and emergency workers dealing with known
and suspect COVID patients through much of March 2020 reveal that many of these WHO-listed
workers’ rights were not observed and are still not being observed by some health and social care
An open distance learning course was then developed by WHO to provide a general introduction to
COVID-19 and emerging respiratory viruses for public health professionals, incident managers and
personnel working for the United Nations, international organizations and NGOs. The course
included hazards, risks and preventing and responding to the viruses with information about PPE
(WHO ndii). By 2020, WHO provided further technical guidance on COVID-19 with regard to infection
prevention and control (WHO ndiii). This contained the health worker exposure risk assessment and
management tool relevant to COVID. The tool looked at PPE use, had hygiene and general
procedures. Additional information was provided on PPE, advice on masks and other related
matters. It is quite clear in the UK from numerous reports that this WHO advice and guidance was
not followed in a range of hospitals and health care settings and for a range of workers.
Finally the WHO/World Bank Global Preparedness Monitoring Board reports (GPMB nd; GPMB
2019; Johns Hopkins 2019) all raised the lack of global preparedness for a respiratory global
pandemic. Issues around PPE for health workers were specifically touched up.
The 2019 report was widely covered in the UK press. These WHO reports and earlier ones were
therefore less a case of the writing was on the wall about pandemic threats, rather they show they
were on multiple big screens everywhere illuminated not for months but years. Yet the UK
government still did not act upon them appropriately.
2.The International Labour Organization (ILO)
The ILO, a tripartite body of employers, employees and governments, has the global lead to produce
conventions on working conditions including occupational health and safety and to produce reports
on these topics.
Some of this work has been done with other international bodies such as the WHO and is discussed
in the section above. If you do not protect the workforce in a pandemic you do not protect the
public. The ILO Decent Work and Fair work agendas argue for both effective health and safety
standards for workers and decent wages and conditions including sick pay and social welfare
support. In the UK, the top down economic measures initially produced by the government in
response to COVID-19 neglected the most vulnerable low paid workers, the precariat, on zero hours
contracts in the gig economy. These workers , without an economic safety net, are forced to
continue working often in hazardous conditions and without proper protection in a COVID-19
pandemic. The ILO has a bottom up approach and has been working on social welfare proposals to
help the precariat during the pandemic.
In 2019, the ILO published guidelines on decent work in public emergency services (ILO 2019). The
guidelines are relevant to UK emergency workers such as paramedics, ambulance crews, police and
firefighters dealing with COVID. For the ILO ensuring decent work for these employees meant
addressing PPE needs properly along with reducing such factors as occupational stress. Yet in March
2020, there have been a swathe of reports from UK emergency workers indicating these type
guidelines have not been fully met.
By March 18 2020, ILO was assessing the effects of COVID on global labour markets especially for
more vulnerable workers (ILO 2020). They noted : “ unprotected workers, including the self-
employed, casual and gig workers, are likely to be disproportionately hit by the virus as they do not
have access to paid or sick leave mechanisms, and are less protected by conventional social
protection mechanisms and other forms of income smoothing. Migrant workers are particularly
vulnerable to the impact of the COVID-19 crisis, which will constrain both their ability to access their
places of work in destination countries and return to their families”. In the UK significant numbers of
workers still fall into these groups. The ILO was unequivocal in calling for policy responses that
firstly made sure :” workers and employers and their families should be protected from the health
risks of COVID-19. Protective measures at the workplace and across communities should be
introduced and strengthened, requiring large-scale public support and investment” (ILO 2020). There
is some considerable way to go before the UK can be said to have achieved this first policy objective.
The second objective of effective economic support for workers affected by COVID-19 is even
UK Government policy
The UK government determines the national health, social care and workplace health and safety
policies and related infrastructure and other spending. Its priorities and projects provide both the
frame and main engine within which we need to assess the impact of COVID on our society. The
Government, through its policies, determines what health and safety laws and regulations we have
and hence the funding and direction of the regulators who deal with occupational health and safety.
It is difficult to escape the conclusion that such policies are ideologically driven and are neither
evidence-based nor evidence-informed. Successive governments have run down the budget of
regulators and implemented a deregulatory and reduced regulation approaches to workplace health
and safety openly and also covertly( Watterson and O’Neill 2012).
A range of legislation exists in the UK to protect the health and safety of workers including the 1974
Health and Safety at Work Act through specific measures such as the Control of Substances
Hazardous Health Regulations (COSHH) revised and amended over the years and risk assessment
and risk management requirements. Specific regulations give safety representatives in unions or as
employee representatives rights to information and training, time off for inspections and
investigating workplace incidents, injuries and diseases.
Critically safety reps have rights to be consulted and rights to sit on safety committees. This is where
pandemic plans by employers should have been brought for scrutiny from and input by workers. In
addition the UK still has a suite of European Union Directives in force as regulations relating to
managing health and safety, controlling working hours and dealing with PPE and other equipment.
These and other regulations, codes and guidance notes provide a framework for the Health and
Safety Executive in Great Britain to inform, advise and enforce GB health and safety laws in most
large workplaces and hospitals, and local authorities and monitor , inspect and if necessary issue
improvement and enforcement notices and prosecute employers who breach the law. Local
authority-based inspectors may enforce health and safety laws in smaller workplaces. Some leisure
and shops etc.
Issues of NHS preparedness to deal with UK health needs generally and a pandemic in particular
have long been raised. Problems including provision of PPE have occurred over the last four or five
years (Merrick 2020, Sridhar 2020) and significant problems relating to health and safety as well as
public health protection emerged in the 2010s.
In addition the evidence from the US and elsewhere about the need for respirators and other
equipment to deal with pandemics appears to have been ignored in the UK. Evidence that cost
rather than public health and workers’ health and safety dominated decisions not to purchase PPE
for health workers has emerged. On March 28th it was reported that an urgent letter had been sent
to the English Minister of Health by the Local Government Association and the Association of
Directors of Adult Social Services (ADASS) requiring sufficient supplies of good quality personal
protective equipment (PPE) immediately amid growing concern for staff who have worked closely
with suspected Covid-19 patients ( Busby 2020) .
England's Deputy Chief Medical Officer, Dr Jenny Harries, said on March 20, 2020: “The country has a
perfectly adequate supply of PPE.” To quote the Lancet, “ she claimed that supply pressures had now
been “completely resolved. I am sure Dr Harries believed what she said. But she was wrong and she
should apologise to the thousands of health workers who still have no access to WHO-standard PPE. I
receive examples daily of doctors having to assess patients with respiratory symptoms but who do so
without the necessary PPE to complete their jobs safely. Health workers are challenged if they ask for
face masks. Even where there is PPE, there may be no training. WHO standards are not being met.
Proper testing of masks is being omitted. Stickers with new expiry dates are being put on PPE that
expired in 2016. Doctors have been forced to go to hardware stores to buy their own face masks.
Patients with suspected COVID-19 are mixing with non-COVID-19 patients. The situation is so dire that
staff are frequently breaking down in tears. As one physician wrote, “The utter failure of sound clinical
leadership will lead to an absolute explosion of nosocomial COVID-19 infection.” Front-line staff are
already contracting and dying from the disease. (Richard Horton Lancet 28 March 2020]
Dr Harries, on March 26 at a press conference covered by BBC TV was not in a position to state how
many doctors and other health care staff were either sick or self-isolating due to COVD- 19. She also
stated that testing and other equipment had been ordered and planned for ahead but due to the
global pandemic, several countries including the UK were having difficult sourcing equipment.
In which case the planning had failed in terms of PPE, testing, tracing and containment whereas in
Taiwan and South Korea, faced with the pandemic weeks and months earlier than the UK, testing
and containment had been introduced at the start and has apparently proved more effective.
In Northern Ireland, it has been reported that PPE from China had been ordered for front line
workers but not yet delivered. No detail was available on how much had been ordered or when it
would arrive and when it would be available for us by those front-line workers ( BBC March 28th
The Scottish Government was guided by Westminster in terms of the slow response initial response
to COVID-19 but then started to act much quicker, within the limit of its powers, in terms of an
earlier shutdown/lockdown policy and advice about staying at home and social distancing. In April
the unions for example welcomed the stronger guidance issued by the Scottish Government to
construction firms during the COVID-19 pandemic, which clarified what was essential works and, in
the event of construction sites ceasing work, indicated workers’ pay must be protected (Unite
2020a). There have still, however, been problems in Scotland relating for example to PPE and other
equipment for health, social care and other essential workers. Over 630 Scottish police officers had
already received PPE by March 27th including FFP3 masks, gloves, boot covers and goggles. Other
Scottish front-line officers were expected to get PPE from 30th March onwards (Press Association
March 27th 2020). However, the Scottish Police Federation reported on 28th March that the
Federation itself and not the Scottish Government was providing hand sanitisers to all its members
(BBC Radio Scotland)
UK government agencies
1.The Health and Safety Executive (HSE)
HSE has responsibility for regulating workplace health and safety in England, Wales and Scotland
including hospital and many other workplaces where COVID-19 may be a threat to health and safety
directly and indirectly through staffing levels, stress and fatigue. There is a separate body for
workplace health and safety in Northern Ireland - HSENI. All the general provisions of health and
safety legislation would apply to identifying, monitoring and controlling the risks that flow from any
pandemic hazards in the workplace. HSE also produces extensive information on the web and
standard guides to managing health and safety and carrying out risk assessments which are easy to
follow although they may be harder for some employers to implement (HSE 2013: HSE 2014 rev
2019 ). These laws and guidance should have ensured many of the easily remedied health and safety
problems of reducing COVID exposures, so visible every night on UK TV, were addressed but they
were not. For example pictures of call centre and production workers in close proximity or health
workers without any or any effective PPE were shown. What HSE has been doing, could do, should
do and will be doing to protect workers from COVID-19 during the epidemic merits urgent
HSE also inputted various documents produced by the DHSS, PHE and other departments linked to
preparing for pandemic flu in the 2010s. For example in 2014 HSE flagged a Cabinet Office four-page
checklist for business on pandemic flu preparedness (Cabinet Office 2014). The checklist was sparse
in detail and had less than a quarter of a page on planning with the rest geared primarily to what to
do in a pandemic. HSE produced its own more useful pandemic material on its web page at least
from 2014 onwards but for obvious reasons could not refer to COVID at the time. This was its
“Pandemic Flu - Workplace Guidance”, the latest version of which was apparently put on the web on
26th November 2019 (HSE 2014/2019). PHE material is again referenced but in addition HSE note n
risk assessment under COSHH for a range of workers who might foreseeably be in contact with
‘droplets from coughs and sneezes on surfaces, used tissues/clothing ‘. The workers listed as
examples of those who could be exposed included cleaners; prison staff or residential care workers
in direct contact with sick people. This begs the question about what employers did in their
pandemic risk assessments, if any planning, for these and other groups of workers and if HSE ever
monitored employer actions.
However, HSE stated COSHH did not cover employees who were exposed to a disease which is in
general circulation and so may happen to be in the workplace, HSE did recognise there could be
‘indirect health and safety consequences of such a pandemic which do impinge on Health and Safety
legislation (Health and Safety at Work etc Act 1974 and the Management of Health and Safety at
Work Regulations 1999 in particular) for example the redeployment of workers to unfamiliar tasks
or to lone or remote working as a consequence of a depleted staff resource due to sickness
HSE has provided limited information on COVID-19 itself and frequently refers workers to Public
Health England guidance and guidance from the various health departments across the UK for
detailed information on health worker PPE (HSE nd). The major early action of HSE that has been
publicised during the pandemic appears to be an exemption permitting the manufacture and supply
of biocidal hand sanitiser products in the UK using various chemicals (HSE 2020a) . This was due to
the great demand for biocidal hand sanitiser product. What else HSE has done specifically to protect
workers from COVID is unclear. It has certainly not been widely publicized at the moment. HSE
remarkably appeared to have ‘gone missing’ during the start of the COVID-19 pandemic beyond a
little information on drivers and a little information on health surveillance guided it would seem by
PHE . Yet interventions on ensuring suitable PPE is available to staff and ensuring health and safety
standards and good practice are being observed for COVID in all workplaces could not be more
critical for health and other workers, patients and the public.
In response to a letter from the Hazards Campaign discussed in later sections, the HSE on 2nd April
2020 clarified and confirmed what actions HSE had taken on the COVID-19 pandemic . This response
noted HSE were still helping to further clarify the position about essential work and those working
away from home. It is not obvious the extent to which the HSE were consulted on such measures
and why they have not had a public voice in press conferences to address the many occupational
health and safety concerns raised by workers about the pandemic in the way PHE, the NHS and even
the scientific advisor to the MOD has had. It seems the HSE role was marginalised because, on the
risk of transmission, it recognised the overall Government strategy was to tackle COVID as a public
health issue. HSE stated “The Department of Health and Social Care (DHSC), working closely with
Public Health England (PHE) and the devolved administrations is the lead Government department
for the UK’s response”. In addition, the HSE noted key guidance came from these bodies as well as
BEIS. This gives the impression that the health and safety of workers, so seriously under threat
during and due to COVID, was effectively side-lined. That impression is in some respects confirmed
by HSE’s observation that if an employer is following the relevant PHE guidance for their sector in
terms of controlling the public health risks, they will be taking reasonably practicable precautions to
control workplace risks”.
On 2nd April 2020 HSE circulated further COVID information in its weekly newsletter but stressed its
policy would be ‘flexible and proportionate’ (2020b). In a pandemic when health care and other
workers lives are threatened by a lack of or inadequate health and safety equipment and flawed
procedures, many would expect ‘proportionate’ to mean great activity on COVID-19 in inspecting,
monitoring, advising and where necessary enforcing regulations against bad employers. This could
include HSE ensuring it had additional staff and resources in this time of national crisis to do its work
and the operation of an effective HSE helpline. Similar provision is needed too for local authority
health and safety inspectors and environmental health officers.
The HSE by April 2 did issue more guidance for example on The Reporting of Injuries, Diseases and
Dangerous Occurrences Regulations 2013 when (1) an unintended incident at work has led to
someone’s possible or actual exposure to coronavirus. This must be reported as a dangerous
occurrence (2) a worker has been diagnosed as having COVID 19 and there is reasonable evidence
that it was caused by exposure at work. This must be reported as a case of disease. (3) a worker dies
as a result of occupational exposure to coronavirus. However, at the end of March 2020, the line was
still only that ‘ HSE will consider a range of actions to improve control of workplace risks’, ranging
from the provision of specific advice to employers through to issuing enforcement notices’. In the
light of well-publicised breaches of government COVID advice and the obvious implications for
worker health and safety and need for urgent action, it remains a major cause for concern in the first
week of April 2020 that HSE still appeared passive.
2.Public Health England (PHE) and the English Department of Health and Social Care (DHSC) . PHE
has the de facto lead for COVID including , it appears, on occupational health and safety for health
professionals. Hence HSE on its COVID web page refers to PHE material and links (PHE 202) . PHE has
produced guidance for health professional since January 2020 and in addition it has produced a
series of guides on PPE including fitting and use (PHE nd).
The advice has at times been queried by clinicians in the field and revised at times for reasons that
have not yet fully emerged but were considered to be lower PPE standards than those in WHO
guidelines. There is likely to be considerable debate and scrutiny after the pandemic has ended
about HSE ceding effective oversight of COVID occupational health and safety for health
professionals to PHE and what did or did not work well in protecting all health workers from COVID.
This follows the reports from clinicians that “ Doctors are angry about Public Health England’s new
advice issued last week which reduces the level of the PPE that staff need to wear. Medics believe
the change in advice was driven by the lack of equipment rather than a change in the clinical
evidence about the risks from the virus “ (Campbell and Busby 16 March 2020).
The HSE should have an active role at the moment in disseminating authoritative COVID information
about PPE and wider health and safety matters to all workers in all sectors across the UK. This will
allow them to check that all is well and hence re-assure workers who may be worried and, where
there are problems, to identify remedies. This will complement positive actions on COVID and not
3.Health Protection Scotland (HPS)
HPS has issued a range of guidance on COVID. This includes general information and specific
guidance covering health protection teams, primary and secondary care workers, those employed in
pharmacies, working as opticians and optometrists . Some specific PPE information and references
to aerosol generating procedures are also included ( HPS nd; HPS2020ai,ii,iii). The problems with UK
advice on PPE for health and social care staff that emerged in early 2020 were tacitly acknowledged
when HPS produced new guidance on April 2nd 2020 on PPE following an urgent review on behalf of
the 4 countries of the UK (HPS 2020b). The new guidance included information on the type of PPE to
use in secondary, primary and community care settings, when to wear it, when clinicians need to
wear a higher level of protective equipment, and in which settings along with detailed advice around
risk assessing use of PPE in a range of different clinical scenarios, including community settings, such
as care homes and caring for individuals in their own homes. However by April 7th 2020, across the
UK, there still continued to be questions raised about the access and suitability of PPE for health and
social care professionals.
4. The NHS.
The NHS in England, Scotland and Wales at all levels has relied on PHE for advice about PPE but all
parts of the NHS are still covered by UK health and safety legislation and subject to inspection,
monitoring and enforcement by HSE. Throughout the early part of 2020 and up to March 31 2020,
there have been numerous reports of problems with the lack of PPE, the distribution of PPE and
suitability. These are ‘live’ issues and matters that require urgent action but despite assurances by
UK government and devolved government ministers and advisors that these PPE problems have
been resolved, they persist. There are reports from a range of sources at the end of March that
frontline doctors treating COVID-19 patients and some GPs have been gagged from speaking about
PPE shortages with some claiming managers have threatened their careers (Lintern 2020). NHS
England has acknowledged that it was controlling media communications to ensure the public
received “clear and consistent information”. As the chair of the UK Doctors’ Association, Dr Rinesh
Parmar observed “ we are seeing draconian measures used to gag doctors and nurses on the
frontline. The NHS will only benefit if we learn from each other’s experience. If we are unable to
share our learning then patients will be put at risk” (Lintern 2020). After the pandemic all the policies
and practices of all levels of the NHS with regard to their health and safety practice, procedures and
policies will need to be examined including their impact on patient care and public health.
5. Local authorities across the UK and their environmental health officers should have a role to play
in addressing COVID health and safety issues but these are not discussed in detail here.
Trade unions and professional bodies
Trade unions frame many of their responses to workplace hazards in terms of the need for
employees to have decent work and fair work So, the hazards of COVID-19 are viewed as
preventable. Where workers are affected, their employment rights, job security and access to sick
pay and support should be protected and applied. Some of the information and advice available on
COVID occupational health and safety from major trade union and professional bodies are briefly
reviewed below. All raise concerns that may range from major to minor but the overall picture that
emerges for the unions is one of flawed government, NHS and employer policies, long delays, run
down services, limited or non-existent resources that individually or together have seriously
impacted on the health and safety not just of front-line clinical staff but also workers in a wide range
of other sectors and occupations.
The TUC has produced a range of information on COVID including planning advice, health and safety
information, employment rights and links to resources including standard government advice (TUC
2020). Case studies on workplace hygiene are provided along with detailed information on PPE.
The organisation also flags up the need for specific precautions relating to ‘public-facing workers’ , a
group that has been neglected both by employers and sometimes governments in terms of risk
assessments and PPE. As the TUC notes: “Workers in public-facing roles will also be on the front-line
of responding to COVID-19 and helping to limit its public health impact. Specific risk assessments
under Control of Substances Hazardous to Health Regulations 2002 (COSHH) should be performed in
The STUC approach to COVID has been to work with government to press for measures which will
protect public health, to support unions and non-unionised workers to avoid unnecessary risk and
unfair detriment and to ensure that employers face up to their responsibilities (STUC 2020). They
also want measures put in place by the Scottish Government on pay, sick pay, hours, and paid care
for those affected by COVID. They have consistently flagged the occupational health and safety
threats that Scottish workers continue to face when dealing with COVID-19 especially PPE issues.
The GMB represents members for example in the health sector, social care, local authorities ,
manufacturing and services where there are numerous COVID-related occupational health and
safety issues. They will advise and represent members in these locations and have produced a
detailed briefing for members on COVID-19 (GMB 2020). This provides information on the law and
worker rights, on symptoms, transmission, precautions and risks. There is specific information about
what PPE should be supplied, what face masks in addition to other actions their employer should
take to protect their health and safety.
GMB have catalogued some of the many wholly avoidable health and safety problems that workers
have faced when faced with possible coronavirus exposure.
These have included access to PPE for hospital porters, lack of protective clothing and sanitisers for
hospital workers, ambulance workers left with no hand sanitisers , wipes and masks and faulty
testing gear, airport staff with no gloves or sanitisers and gig workers abandoned and penniless
when faced with coronavirus threats. At the end of March, 500 ASOS workers walked out over what
the GMB alleged were failures by the company to properly implement COVID-19 social distancing
measures or to provide workers at its site in Grimethorpe, South Yorkshire, with protective masks
and hand sanitiser (Chapman 2020). When unions like GMB raise concerns about COVID-19 and PPE,
they are frequently described as unhelpful by employers which, in the circumstances is not a
response that seems appropriate.
The GMB press office produced a series of reports on PPE and related COVID problems. On 3rd April
2020, GMB raised concerns that Stirling Council frontline staff did not have the personal protective
equipment (PPE) to guard against the coronavirus. The GMB said that it had asked Stirling Council to
provide staff risk assessments for council cleaning, catering and roads workers after the first
confirmed case of Covid-19 in Scotland was announced at the beginning of March. It estimates that
there were still hundreds of catering and cleaning staff working at Stirling Council premises at the
time. The Council described the union request as ‘unhelpful’. Ambulance workers at St Helier
hospital who raised concerns about a lack of PPE were 'scapegoated’ for the shortages by managers
according to the union on 6th April 2020. Also on 6th April, there were reports an ambulance driver
with Covid symptoms was refused a COVID test as 'too expensive'. Staff raised concerns that full
PPE was not being provided for workers transporting patients.
Unite has members in a very wide range of sectors including health and public service, labs,
construction, manufacturing, transport and service industries. It has produced some of the most
detailed guidance and checklists for trade unionists, open to all on its web pages. It covers for
example those in clinical and non-clinical settings, critical workers. For its officials and
representatives and others needing information on COVID-19 it details health and safety
requirements that apply under the Health and Safety at Work Act 1974, the Control of Substances
Hazardous to Health Regulations 2002 (COSHH) and provisions relating to biological and infectious
agents and their risk assessment. ( Unite 2020). There are sections on PPE, cleaning, canteens and
welfare facilities, home working, lone working, transport working, international working
5.Fire Brigades Union (FBU).
The emergency services like the police, fire and ambulance services have a critical role to play during
the pandemic. The FBU has produced generic guidance on COVID-19 for its members (FBU 2020i)
and has also flagged the problems of the lack of testing which is needed to determine which of their
members who are or have been self-isolating have COVID-19.
Failure to test people for COVID-19 has seriously affected staffing levels in the brigades. This
jeopardises the health and safety of its members in operational settings (FBU 2020ii). Similar
problems will exist in the other emergency services. The issues faced by the police service and raised
by the various police federations are discussed elsewhere in this paper.
6. British Medical Association(BMA).
The BMA and its leadership have raised numerous health and safety issues relating to COVID-19 that
their members have faced during March 2020. These have often focussed on serious PPE problems
in terms of supply and suitability (BMA 2020) but have also included risk management, health and
safety procedures, staffing, wider resource issues and stress and fatigue. Some of these are
immediate and direct health and safety issues, others affect health and safety indirectly. Staffing
levels, fatigue and stress relate to the large numbers of staff self-isolating or already ill from treating
patients with COVID. Hence the lack of past priority testing of hospital and primary care staff has
already had a damaging effect on the health and safety of the remaining workforce and on patients
and relatives. Many BMA members have echoed or pre-empted the concerns raised by Richard
Horton in the Lancet (Horton 2020) about COVID-19 policies, procedures, resources and delayed and
ineffective actions at national level in England and Scotland .
At the end of March and into April, the BMA and other medical organisations were receiving reports
that many doctors on the front line still lacked sufficient access to proper PPE, risks to GPs
continued, and workload and fatigue issues for junior doctors treating COVD-19 patients were
growing (Rimmer 2020). The editor in chief of the BMJ weighed into the debate on April 2nd 2020
with an urgent and telling plea to protect all healthcare workers based on some personal
experiences and published evidence of failures:-
“….there is real and justified fear about personal safety, fuelled by a scandalous and
widespread lack of personal protective equipment (PPE). Doctors have been reduced to
sourcing improvised eye protection, making public appeals for respirator masks, and
fundraising for supplies. Their families (my own included) are parcelling up masks and scrubs
and sending them by post, reminiscent of the parcels fondly sent to soldiers in the trenches
in the first world war. With the UK’s first reports of deaths among doctors. the BMA’s
warnings ring horribly true. Reports from the US and elsewhere are no less worrying”
7.Society of Occupational Medicine (SOM), British Occupational Hygiene Society (BOHS), Faculty of
Occupational Medicine of Royal College of Physicians (FOM).
FOM has produced a variety of guidance on COVID sometimes with other professional bodies and
societies such as the British Occupational Hygiene Society (BOHS) and the Society of Occupational
Medline (SOM). SOM, BOHS and other groups have pressed for COVID testing of all key workers and
have called for an investigation of the supply of suitable PPE for health professionals (SOM 2020a).
By April 6th 2020, SOM spoke out further on COVID with an unequivocal statement exposing failures
in UK occupational health and safety policy on COVID-19. It did not believe:
“ work related fatalities due to COVID-19 exposure is a given. The UK should have aimed for
a target of zero work caused fatalities in this pandemic within the NHS, essential services
and UK business. With proper application of controls, no worker should die of work acquired
COVID-19. SOM is campaigning to raise awareness of the risks facing healthcare and other
workers in the UK and internationally. SOM is calling for PPE to be used effectively during
the COVID-19 pandemic. The use of appropriate PPE must be supported by training, fit
testing and management of compliance. The new PPE guidance published by the
Government is an improvement but the recommendations should be considered minimum
protection. Where a higher level of protection is available, it should be used” (SOM 2020b).
SOM did welcome the fact that the HSE had provided information on when dangerous occurrences
and work-related exposure to COVID-19 were RIDDOR reportable. In addition, doctors were
reminded that if they suspect that a death from COVID-19 may be attributable to the deceased’s
employment they had a legal obligation to notify HM Coroner (or the Procurator Fiscal in Scotland).
Occupational hygienists are a key group in working out what is the best form of PPE to use for COVID
in various settings and in assessing effectiveness. One of the most useful and up to date guides to
PPE for COVID, also a source of other more detailed information on the topic, has been produced in
a journal editorial by occupational hygienists. They fill a gap that HSE does not yet seem to have
addressed (Semple and Cherrie 2020).
8.Royal College of Nursing (RCN)
The RCN position is to argue for “priority Covid-19 testing for all health care professionals, access to
adequate supplies of personal protective equipment and hand sanitiser for all nursing, midwifery,
social care and student nurse staff for use at the point of care, full occupational sick pay paid from
day 1 for all our members, with no detriment, regardless of where they work, Provision from
government and employers to ensure all nursing staff can care for their children without a loss of
income. Clarity on the measures taken to protect pregnant and vulnerable nursing staff. Stringent
measures in place to ensure the health, safety and wellbeing of staff by addressing fatigue,
hydration and issues of abuse towards staff “(RCN 2020).
9. Institution of Safety and Health (IOSH)
IOSH is the professional body for health and safety practitioners who function in the public and
private sectors as advisors on health and safety matters They have produced an information sheet
and have web links to a range of other sources on COVD-19. The organisation draws on WHO as well
as UK sources and covers preventive measures, emergency planning, managing occupational safety
resources and occupational risks to workers (IOSH 2020 nd).
This is a group that has a long history of campaigning for occupational health and safety in the UK. It
has drawn attention to the cuts in occupational health and safety regulation, monitoring, inspection
and enforcement over a several decades. Such cuts are now a major explanation for several of the
problems emerging with worker health and safety during the pandemic. The Campaign has provided
excellent, accessible and clear information on COVID-19 that is much more detailed than that
available from many employers (Hazards Campaign 2020). Risk assessment, risk management,
healthy and safe working practices and procedures, occupational health surveillance, provision of
suitable and sufficient PPE etc that have all been highlighted by Hazards Campaign do not appear to
have been applied in many health and social care settings and other workplaces where exposure to
Coronavirus could occur. Its focus has been on what employers should do to prevent transmission in
workplaces and how employees can get employers to act using such regulations as the Safety
Representatives and safety Committee Regulations, the 1974 Health and Safety at Work . It also
provides details about conditions needed get the best prevention measures in places including wider
employment protection for workers on pay and sickness absence linked to COVID impacts. Finally it
provides sources of additional information including guides and mutual aid groups.
The Campaign group raised major concerns with HSE about contradictory and flawed COVID-19
advice provided by the UK government to workers on 30th March 2020 (Letter to Martin Temple
HSE) . In particular the impossibility of keeping safe distances in some workplaces and some jobs was
highlighted as was contact of workers with materials. Sectors affected included manufacturing,
construction and warehousing for example, involves a lot of touching and handling of materials. In
most workplaces complying with the hand washing, cleaning surfaces and materials guidance would
be impossible. So the Campaign asked HSE to provide details of their actions on COVID-19 on the
“1. Remind all employers in essential and non-essential workplaces that workers health and
safety is paramount at all times, that normal health and safety duties and regulations apply
and that #Covid19 means extra risks must be assessed and prevented in usual way – by
elimination, collective control and appropriate and sufficient PPE as last resort.
2. Issue strong warnings to employers to review all Risk Assessments for the new Covid 19
risk and to introduce safe systems of work to protect workers.
3. Advise employers that if suitable and sufficient Risk Assessments show the risk of
exposure to COVID19 cannot be reasonable prevented they must stop work
4. Provide workers with information about risks to their health and what their employers
should be doing. Closure of HSE Infoline in2011 has left workers without a lifeline and
employers without advice. Surely at this time with inspectors working from home, the HSE
helpline could be reintroduced to support these workers?
5. Respond to the ‘Report a Concern’ online form by next day with enforcement action to
support workers health against employers who are breaching health and safety regulations.
Will you accept photographic evidence available which is date stamped? This could be used
to instruct employers to either improve the situation in workplaces or face Prohibition and
6. Enforce strongly the need for appropriate PPE in sufficient quantities to protect the health
of all NHS, Care and other health and essential workers who are at greatest risk of exposure
The HSE response to the Campaign points was that other Government departments determined
policy and guidance on COVID. HSE was therefore again on the margins in the crisis and would act in
ways that were reasonably practicable along the lines of the legislation. Hazards Campaign pursued
the matter with a further letter to HSE on 3rd April that highlighted the inconsistencies of
government advice on social distancing, cleaning of equipment and personal welfare facilities and
problems with the PPE advice. The Campaign specifically noted government guidance documents
stated if a ‘member of staff has helped someone who was taken unwell with a new, continuous
cough or a high temperature, they do not need to go home unless they develop symptoms
themselves’ and should ‘wash their hands’. The Campaign considered such advice would continue
the spread of the virus, put more workers at risk and appeared to be in conflict with other
government public health guidance about self-isolating to reduce risk of transmission of COVID-19.
The Campaign continues to receive reports from workers about insufficient or incorrect supplies of
PPE and lack of PPE training. They also viewed the HSE document ‘Research: review of personal
protective equipment provided in health care settings to manage risk during coronavirus outbreak
(COVID-19)’ contradictory at best.
For example they noted if FFP3 respirators were required, then there were questions about FFP2
respirators adequacy for AGP work with known or suspected patients, when exposure to high viral
load was great, or whether at the very least should only be used only for a short period of time with
The campaign further knew of many of the workers with the greatest health and safety concerns
who would be in workplaces on precarious contracts and not in a trade union- organised and
supported workplace. In these workplaces it would be impossible for these employees to resolve
COVID-19 issues ‘through speaking with their employer or trade union’ first. They would risk losing
their jobs. The HSE helpline or an alternative option must be available for worried exposed workers
but cuts had affected easy access by workers to HSE advice and support.
So for the Hazards Campaign, if the work could not be carried out safely within the COVID-19 public
health rules, then it should stop. They further considered the following should apply. No-one should
be placed at risk in non-essential workplaces and the HSE must be able to close down unsafe
workplaces to protect workers, their families and the wider public health. There should be a
recognition that vulnerable workers needed to be able to contact the HSE regardless of having
reported it to their employer first. In critical essential employment, workers must have the
appropriate PPE, in adequate supplies, necessary to keep them safe and healthy and if not, they
must be able to stop work until it is available. These calls indicate that the HSE was in many respects
viewed by worker groups such as Hazards Campaign as a passive or reactive agency unable to act
effectively for whatever reason to protect workers at risk directly and indirectly from COVID-19.
On 6 April 2020, the Hazards Campaign in a statement reflected the concerns of many workers,
trade unions, professional associations and health and safety researchers when they called for a
precautionary approach to Covid-19 risks that provides workers with the best chance to avoid
becoming infected by it. They considered employers needed to eliminate the risk of catching or
spreading Covid-19 at work by following health and safety risk-based control measures:-
a) Closure of all non-essential work that is not supporting essential workers, with workers laid off
with full pay so they can stay home and keep safe
b) Preventing exposure in essential work/supporting essential work by:
➢ Enforcing social/physical distancing
➢ Provision of physical barriers and safe systems of work
➢ Provision of the highest most protective level of PPE (including training, cleaning and
maintenance) for all workers who have to work within the 2 metre zone with people/patients as
everyone may be potentially infected. In particular:
▪ For Essential Workers (for example care workers, cleaners, prison officers etc.) this must include
disposable gloves, aprons, masks, goggles or face visors
▪ For NHS medical staff treating known Covid-19 patients this means the highest WHO standards of
respiratory, goggles or visors, disposal suits, gloves etc
c) Government (HSE and public health organisations) must immediately issue new PPE guidance for
all workers as latest updates only meet minimum standards not the highest required to fully protect
2. To attack the spread of the virus using tried and tested public health methods to test and track,
3. A health care system alongside a strategy that protects our most vulnerable, not one that leaves
health workers having to choose who has the best chance of survival.
4. The HSE to step up and enforce the duty on employers to ensure workers health and safety. All
workers need reassurance and access to information and support in the workplace, without artificial
communication barriers. The HSE to investigate quickly and close down employers who are putting
people’s lives at risk. HSE must engage with workers via new technology and social media too ensure
they get real-time information about hazards and risk on site and can respond rapidly.
This magazine has been examining the occupational health and safety policies and practices of
employers and government regulators again over many decades. It has produced an incisive,
accessible and readable analysis of the COVID failures in the UK and extensive sources of information
for workers on the pandemic from a health and safety perspective (Hazards 2020). The analysis
stresses that the pandemic could persist “ because public health was a low priority and workers did
not have the sick pay and job protection necessary to survive”. It also details the need for PPE to
protect workers worldwide from COVID-19 and describes some of the interventions from the WHO
Large and medium sized employers will have their own health and safety advisors as do bodies like
the CBI and will have worked out plans for dealing with COVID. Much of bespoke employer
information available focusses on economic and financial impacts of COVID and not on the
occupational health and safety threats to employees.
The British Chambers of Commerce has put up a web page that draws on UK Government official
guidance but does not appear to have specific occupational health and safety information of their
own on the web page (British Chambers of Commerce 2020). The Federation of Small Businesses has
a dedicated Covid web page and highlights mental health issues (FSB 2020). How successful
employer plans have been in protecting employees will be a matter for careful scrutiny after the
pandemic has ended but already it is clear there have been major failings by some employers in
protecting their staff from exposure to the virus with extensive media footage of workplaces
showing employees closely packed and lacking suitable protection and PPE where it should have
In January 2020 researchers were flagging the need for companies to update their pandemic plans
(Koonin 2020). Evidence in March 2020 in the UK indicates many companies had failed to develop
and implement effective health and safety procedures and provide appropriate equipment to
protect staff. The CBI in UK has little specific information relevant to occupational health and safety
on its COVID web page although it has working groups looking at people redeployment, keeping the
nation healthy and supporting families in hardship which may impact on health and safety. In
addition it provides an assessment of what UK business can learn from the actions of the Chinese
government to deal with COVID-19 (CBI 2020)
The mainstream media in the form of the press, TV and radio have probed and investigated a range
of COVID-19 occupational health and safety problems with some rigour, at some depth and with
considerable persistence. They have frequently proved more accurate and certainly more up to date
and often more informative than both government and scientific civil servants.
The broadsheets like the Guardian and Independent have been particularly diligent and illuminating
in investigating PPE and related problems immediately facing health workers, emergency workers
and other groups of workers too. Social media has contained accounts from these workers but has
also spread inaccurate statements primarily about fake COVID-19 treatments and useless
The paper has documented a catalogue of missed opportunities and failures by various government
bodies, agencies and organisations, and employers to plan for the pandemic and to equip staff with
the necessary health and safety equipment and procedures to protect themselves and the public
from COVID-19. It has also documented a wealth of material including reports from international
agencies, foreign governments, researchers, trade unions and NGOs that did not simply provide
early warning about the pandemic but offered important guidance on solutions to mitigate its
impacts on workers and hence wider society. The consequences of not planning, preparing including
regulating, monitoring and inspecting and acting earlier on COVID-19 will be enormous in terms of
human suffering and economic damage.
In terms of the big picture, the precautionary principle is a key principle to adopt in both public
health and occupational health and safety along with using up to date and accessible information.
When faced with a possible pandemic, the precautionary principle should be the main principle to
guide decision-making. One of the most influential sources on the precautionary principle from the
European Environment Agency refers to late lessons from early warnings about hazards and their
risks. With COVID-19, we have had early warnings and even more important early guidance but
failed to learn the lessons again and again.
Many of the occupational health and safety threats in the UK are ongoing and unresolved months
after the pandemic started. The emergency planning that occurred in the UK in the late 2000s and
2010s has de facto proved insufficient and NHS England and PHE now accept there have been
problems with PPE supply that have been obvious to health care professionals and other workers for
several weeks. Attempts have been made across the UK in recent weeks to address lack of suitable
PPE provision to a range of groups. However, at the end of March 2020 there are still shortfalls with
supply and distribution to these groups and doctors treating COVID are dying and other health
professionals falling ill (Booth, Campbell and Weaver 2020).
Those most affected by the hazards and risks presented by COVID 19 and their representatives, and
often but not always with the most limited resources, have analysed the threats best, foreseen the
hazards and advocated the right risk assessments and risk management strategies at an early date.
UK Governments and their scientific civil servants, with significant resources and staff, have
manifestly failed to act quickly or quickly enough on the pandemic.
Yet the UK plans decades ahead for military scenarios and spends billions of pounds on equipment
and systems just in case of conflict. There is therefore no reason why governments cannot choose to
plan ahead for pandemics and spend much smaller sums on equipping health care and other
workers with the equipment and systems they need to protect the public which requires we protect
their health and safety. We owe it them and the government owes it to us.
A recent Lancet editorial on protecting health workers noted: “ Health-care systems globally could
be operating at more than maximum capacity for many months. But health-care workers, unlike
ventilators or wards, cannot be urgently manufactured or run at 100% occupancy for long periods. It
is vital that governments see workers not simply as pawns to be deployed, but as human individuals.
In the global response, the safety of health-care workers must be ensured” (Lancet 2020). However,
it is not just health care workers that need protection, the health and safety of all emergency
workers, care workers and key workers still in services, shops, offices, delivery, maintenance and
other sectors require effective health and safety protection that in places in the UK not only remains
minimal but non-existent. If we can’t protect workers, we cannot protect ourselves.
The occupational health and safety of workers, and in pandemic settings especially health,
emergency and key workers, is influenced not just by direct health and safety measures, procedures
and equipment but also by ‘indirect actions’. These include addressing staffing levels, training,
resources and so on that ensure there are sufficient staff neither overloaded nor overwhelmed,
stressed and fatigued by a pandemic. Ending cuts in the economy and addressing these structural
problems will improve worker health and safety. Operating containment policies and testing and
tracing effectively will also reduce workplace morbidity and mortality. The UK government - and
many of their scientific civil servants have been complicit in the process – has remained silent on
these big picture issues and even used the pandemic to mount further attacks on regulation and to
defend companies with records of significant public health damage.
To date there are no UK estimates for health care worker or any other group of workers’ morbidity
and mortality from COVID-19 but efforts are being made to collect such data globally. Only
occasional press reports list possible deaths of doctors from COVID. In the US, there has been some
attempt made to assess the likely numbers of health care workers contracting COVID for a whole
range of health and social care workers (Frogner 2020). Similar work should begin quickly in the UK
and widened to include those workers in other occupations where exposure might have occurred.
Actions needed now and in the near future on occupational health and safety and related matters
due to COVID-19
1. Active UK/ devolved administration interventions are now necessary using properly staffed
and resourced regulators to protect worker health and safety in the pandemic. This requires
HSE and local authorities to inspect workplaces and monitor, advise, re-assure where it is
the case, and if necessary enforce health and safety law relevant to COVID threats.
2. Reversal of the many cuts in health and other public services over the last decade or more
that impact on pandemic planning and worker health and safety should occur. This does not
mean simply reversing the cuts of the last few years. These services and the staff within
them - in adequate numbers - need to be properly resourced. That will protect their health
and safety and ensure they can then protect our public health. The two elements are
inextricably linked. COVID-19 has shown us exactly why the cuts should be reversed.
3. The police are active across the UK in enforcing COVID lockdown policies and now have legal
powers to do so under the Health Protection (Coronavirus Restrictions) Regulations 2020 in
for example England and Scotland. HSE and local authorities need to be similarly active now
and effectively regulate very visible COVID-related occupational health and safety abuses by
employers across the UK using existing health and safety legislation. In a pandemic that is
‘flexible and proportionate action’ for a regulator: ‘going missing’ is not. The morbidity and
mortality of health, social care and other key workers through poor health and safety
standards can only increase the pandemic toll on the wider public.
4. HSE and local authorities should provide their own up to date information on COVID-related
health and safety at work topics including PPE and not simply rely on PHE and HPS material.
5. A pre-occupation with better regulation and running down regulatory capacity in areas
critical to worker health and public health has proved disastrous in the pandemic. It should
cease. HSE and other regulators in local authorities should for example already have been
checking, prior to the pandemic, pandemic health and safety planning, health care PPE and
ensuring that PPE and health and safety procedures for social care staff and workers in social
care, shops, warehouses, other workplaces and transport were available, fit for purpose and
applied. It is not clear from information in the public domain that they did so.
6. Regular governmental and agency updates should be provided by the NHS, PHE and HSE on
how many workers, and in what sectors, have either contracted COVID-19 in the course of
their work or have work-related COVID-19. These updates should be accompanied by
information on the actions that the government, regulators and the employers have taken
and will take to raise health and safety standards.
7. Effective consultation between employers and their workforces about pandemic planning
and working conditions is critical. It is already clear that in some workplaces, there has been
no or no adequate implementation of healthy and safe workplace planning, procedures,
equipment and staffing. There have been major failures in terms of social distance,
screening, provision of PPE and hand sanitisers – in service and manufacturing sectors and
for a whole range of emergency and transport workers.
8. Greater improvement upstream by government and employers on early pandemic planning
must happen now measured against the WHO guidelines and good practice that has
emerged in other countries affected by the COVID-19 pandemic earlier.
9. Ensuring that all vulnerable and precarious workers in our gig economy have adequate
economic support if they must stop work is essential. Not to provide this will increase the
possibility that they will be at risk from continuing to work in hazardous settings because
they need to obtain food and pay their bills.
10. Governments and employers should support and facilitate the work of the trade unions and
NGOs who have reached employees in many workplaces with some of the best and most up
to date advice and support on COVID-19 occupational health and safety. This has been done
on very limited budgets but with great effect.
11. Full information should be provided to the public and workers as soon as it is available from
government and employers about the timetable for provision of PPE and other equipment
that influences occupational and safety and not vague references with unspecified dates.
12. There is an urgent need to provide clear information about what are the essential
occupations and sectors along with more detailed health and safety at work guidance for
employees. There has already been confusion in England especially about the operation of
construction sites during the COVID-19 pandemic.
13. Preventing transmission of COVID-19 from the public and other workers to any workforce
should be the priority by the best international means possible along with protecting
workers directly with barriers and PPE etc. In addition to applying all the lockdown steps
now advocated it should also include testing, tracing and then isolation for those with COVID
symptoms. It might also include, if the growing evidence indicates it is effective even to a
small degree to do so, the public covering up in public place when in contact with others
including workers. This would not need the type of PPE essential workers require but more
basic mask as the purpose is to prevent transmission and not to protect the wearer. PPE in
the workplace rightly should be used to protect the wearer.
14. In due course there will need to be a thorough analysis of the national and regional
performance of the UK and devolved governments during the pandemic, why some
decisions and actions varied between them and with what effect on employee health and
safety across society. Also the wisdom of the devolved administrations accepting initial UK
Government policy and agency assessments of pandemic risks should be scrutinised . The
first UK timetable for actions rather than those of the WHO with its extensive evidence-
based reports on pandemics was seriously flawed. The implications for occupational health
and safety were considerable. How well reserved agencies served devolved administrations
needs to be part of that analysis.
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