The document outlines the structures and roles for managing COVID-19 compliance at a workplace. It establishes a COVID-19 Compliance Officer who is responsible for developing health and safety measures. It also establishes a COVID-19 Manager to enforce preventative measures and ensure compliance. Response Team Members assist the Compliance Officer and Manager. The plan includes screening employees, managing confirmed/suspected cases, cleaning, distancing measures and communicating protocols. Concerns discussed include not overburdening existing safety representatives and committees with COVID-19 responsibilities and ensuring their normal roles are still prioritized alongside the new risks.

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COVID-19 Structures
COVID-19
Manager
COVID-19
Compliance
Officer
COVID-19
Response Team
Member /
Suitable person
/ employee

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COMPLIANCE: Structures- COVID-19 Compliance Officer
COVID-19 Compliance Officer is
responsible to:
Manage the phased-in of
return of employees from other
provinces, metropolitans and
district areas
Develop measures to ensure
that the workplace meets the
standards of health protocols,
adequate space for employees
and social distancing measures
for the public and service
providers
Ensure adherence to the
standards of hygiene and health
protocols relating to COVID-19
at the workplace
The development and
implementation of a COVID –
ready plan for the phased-in
return, of employees to the
workplace, prior to reopening
for business
The COVID-ready plan must
correspond with Annexure E
and should be retained for
inspection by the DoEL

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38 No. 43258 GOVERNMENT GAZETTE, 29 APRIL 2020
ANNEXURE E
WORKPLACE PLANS
Regulation 16(6)(b)
A COVID-ready Workplace Plan must be developed prior to the reopening of an enterprise employing persons or serving the public.
For small business, the plan can be basic reflecting the size of the business, while for medium and larger business, a more detailed written plan should be developed
given the larger numbers of persons in the workplace.
The Plan for medium and large businesses must include the following:
1. The date the business will open and the hours of opening;
2. The timetable setting out the phased return-to-work of employees, to enable appropriate measures to be taken to avoid and reduce the spread of the virus in
the workplace;
3. The steps taken to get the workplace COVID-19 ready;
4. A list of staff who can work from home: staff ho are 60 years or older; and staff with comorbidities who will be required to stay at home or work from home;
5. Arrangements for staff in the establishment:
a. Sanitary and social distancing measures and facilities at the entrance and exit to the workplace;
b. Screening facilities and systems;
c. The attendance-record system and infrastructure;
d. The work-area of employees;
e. Any designated area where the public is served;
f. Canteen and bathroom facilities;
g. Testing facilities (for establishments with more than 500 employees);
h. Staff rotational arrangements (for establishments where fewer than 100% of employees will be permitted to work).
6. Arrangements for customers or members of the public, including sanitation and social distancing measures.

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COMPLIANCE: Structures: COVID-19 Manager
• Ensure continued compliance the COVID-19 PLAN
set forth by the COVID-19 Compliance Officer
• Ensure that all employees are well versed in all the
identified risks that COVID-19 poses within the
working environment
• Enforce COVID-19 related preventative measures
in all areas of the workplace with all employees
• Ensure that, as far as is reasonably practicable, the
workplace remains current with updated
legislation measures and developments related to
COVID-19.
• Ensure that a distancing of minimum 1.5 meters is
maintained throughout the workplace by all
employees and visitors or alternatively ensure
adequate screening or barriers are in place to prevent
the spread of the COVID-19 virus
• Communicate as frequently as is necessary with SHE-
Committees and Representatives on all COVID-19 -
related health safety matters, facilitating feedback
and ensure that clear records are kept thereof
• Encourage employees to work from home as much
as possible
• Ensure continuous cleaning and de-sanitizing of all
relevant areas of the workplace

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COMPLIANCE: Structures: COVID-19 Manager
• Avoid any grouping of employees, visitors and
contractors workplace by ensuring
implementation of strict Workplace Distancing
Protocols & Standard Operating Procedures (SOP)
• Facilitate the implementation and management of
the Screening Process for all staff, contractors &
visitors
• Manage the process to follow if an employee is
confirmed or suspected to have COVID-19 in the
workplace
• Ensure that Medical Surveillance of recovered
employees are recorded.
• Determine the area of floor space in square
meters and calculate how many employees,
visitors, contractors and customers will be
allowed to be on the premises
• Take steps to ensure that persons queuing
inside or outside the premises are able to
maintain adequate distancing measures
• Provide hand sanitisers for use by the public
and employees at the entrance to the premises
• Assign an employee or any other suitable
person, as the compliance employee/s, who
must assist in the day to day requirements of
COVID-19 Compliance

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COMPLIANCE: Structures: Response Team Member/Suitable
Person/Employee
COVID-19 Response Team Member has the duty to:
Assist and support the
COVID-19 Compliance
Officer and/or COVID-19
Manager/s
Participate in educating
all employees on the
company’s COVID-19
preventative measures
Assist with on-going
communication to all
employees regarding
COVID-19 preventative
measures as required
Contribute to the
implementation and
evaluation of COVID-19
processes and protocols
Assist with Operating
Procedure & Medical
Screening Procedure of all
staff, visitors and
contractors
Contribute toward the
restriction of grouping in
the workplace, and
applying strict physical
distancing rules
Assist in managing the
protocols of confirmed or
suspected COVID-19 cases
in the workplace

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Safety
Checklist
Nr Typical Safety Representative Check List Yes No
BUILDINGS
1 Clean and in good state of repair
2 No broken windows, doors or other openings?
FLOORS
3 Clean and free from slippery substance
4 No tripping or other obstructions hazards?
5 No holes, unevenness or structural damage?
VENTILATION
6 Sufficient natural or artificial ventilation?
7 All fans in working order
8 Free from any dangerous gasses, dust, smoke etc.?
LIGHTING
9 Sufficient natural or artificial lighting?
10 All lights in working order?
11 No straining glares or contrasts?
12 No dark or shadowy spots?
HYGIENE / COVID-19
13 All toilets, urinals and change rooms clean and hygienic
14 Kitchens and eating places clean and hygienic?
15 No eating in places not so indicated?
16 Are all sanitiser dispensers refilled and operational?
17 All social distancing procedures being followed?
18 Are all signage clear and visible?
19 Are all designated waiting area’s clearly marked?
20 Are cloth face masks being worn correctly and at all times?
21 Are all barriers in place, where the 1.5m distance cannot be achieved?
22 Are all clear barriers clean and undamaged
23 Are all areas cleaned as planned and on time?
24 Are all work area’s desks and tables kept at 1.5 meters apart?
25 Is proper hand sanitising being done frequently by all?

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• COVID-19 company policy
• COVID-19 Standard Operating Procedures (SOP)
• Visitor & employee screening
• COVID-19 PPE
• Workplace checklists – monthly / weekly / daily
• COVID-19 incident reporting and investigation
• COVID-19 posters
SHE Reps Knowledge

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COMPLIANCE: Scope of SHE Reps in the COVID-19 Sphere
Other than assisting DoEL when coming to the workplace, SHE Reps also liaise
between management and employees
SHE Reps in the workplace may be involved in:
• Assisting the employer with COVID-19 measures
• Be proactive in identifying potential COVID-19 risks in the workplace
• Attend to and investigating COVID-19 -related complaints from employees
• Assisting in the investigation of COVID-19 incidents in the workplace
• Make COVID-19 -related health suggestions to management
• Assist in the COVID-19 implementation and communication of the back-to-
work plan

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Expectations from SHE Reps must ultimately be based on their ability to handle their normal
work activities as well as keeping an eye on everyone and everything else. This is not always easy
and SHE Reps feel the additional pressure bestowed upon them
If you really want to understand what the safety culture of a company is, speak to the safety representatives.
They are at the coal face of your safety management plan.
SHE Reps spend their time doing the work as part of a team and are given the additional responsibility of
documenting issues and completing check lists, attend safety meetings and discuss safety concerns with employees
during the day. The SHE Reps frequently share the additional burden of production expectations
Challenges and Concerns

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Challenges and Concerns
Regulation 16.5 “It must appoint a manager to address employee or workplace representative concerns and to keep
them informed and, in any workplace in which an health and safety committee has been elected, consult with that
committee on the nature of the hazard in that workplace and the measures that need to be taken
The regulations speak about a COVID-19 Manager who carries the responsibility to train, monitor and advise on site.
They are to communicate with the Safety Committee as well as the SHE Reps to ensure that the latest facts on the
ground are communicated throughout the workforce. (Avoiding groupings of employees should be kept in mind)
Should additional COVID-19 -responsibilities be given to SHE Reps? Ideally not.

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Challenges and Concerns
This is distinctly different from the above, specifically speaking about an employee, not rep or
committee member, but an employee selected to perform certain duties seemingly temporarily and
only with relation to the COVID – 19 crises. It also seems that the chosen person does not have to be
permanently employed either, but suitable to expedite COVID-19 related duties. These assigned
employees will assist the COVID-19 Manager in the day to day operations pertaining to the virus.
Assign, in writing, an employee or any other suitable person, as the compliance employee, who must
ensure-
compliance with the measures provided for in
paragraphs (a) to (d); and
that all directions in respect of hygienic conditions
and limitation of exposure to persons with COVID-19
are adhered to.

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The role and responsibilities of the COVID-19 selected persons is likely to mount as more employees return to work. Training
the returning employees will require time, which should not be harvested from the SHE Rep or the Committee Members.
Selected employees or other suitable persons must be tasked with only COVID-19 related issues as they will not be as easily
distracted with their daily activities.
Manufacturing, production and the other essential services remain as dangerous now, perhaps more so now with less hands,
and should not be overlooked. The SHE Reps and Committee Members must continue with their routines as before and
COVID-19 responsibilities should preferably not be added to their portfolio if possible.
The Regulations clearly state that the Occupational Health and Safety Act and subsequent Regulations are still valid and 100%
applicable. Therefore, we must be careful not to discard our current systems and safety procedures and only focus on COVID-
19.
Challenges and Concerns

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The COVID-19 landscape seems to change continuously. At the
drop of a hat, changes might need to be implemented as the
regulations changes frequently. This will add an unnecessary
burden to the SHE Reps and the Committee Members who should
only be tasked with the communication of certain facts and
procedures to the work force.
The execution of emergency protocols should be part of
the COVID Managers’ duties and his / she assigned
suitable persons. If screening, isolating or quarantine
protocols are implemented because a positive or potential
positive person is identified, immediate action may be
required. Workstations may have to be isolated and
cleaned and departments may have to be shut down.
Hands will be required for these protocols and
withdrawing SHE Reps or other employees off machines
and production scenarios could cause problems.
Challenges and Concerns

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• SHE Reps seen as the ‘voice of reason’ among the
workforce.
• SHE Reps are the go-to person for employees.
• SHE Reps should always be available to address
COVID-19 issues (when they are responsible for this)
and not be tied up in their daily activities.
Positive Aspects

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Final Thoughts –
Safety Representative Appointment
Check your attitude!
Look at your entire
company and all its
sections and divide
the areas up in a
logical way
Keep them informed Know your staff.
Respond / Re-act to
issues immediately.
Seek external advice Train, train, train
Appreciate them!