growth, housing and environment · then they must provide sufficient information to cover all work...

Growth, Housing and Environment

Construction Sector – C19 Construction Work Permit Application

Guidance

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Issued 12th May 2020

Last Updated 26th May 2020

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Version 1.3.2

Application Guidance (v1.3.2) 20/05/20

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Contents

1. Introduction .................................................................................................................................... 3

2. Basic Questions ............................................................................................................................... 3

2.1. Which construction works require a permit? ......................................................................... 3

2.2. Which construction works are excluded or exempt? ............................................................. 4

2.3. Who should apply for the permit? .......................................................................................... 4

2.4. Does the permit cover the entire project? ............................................................................. 4

2.5. Should the application cover the site’s sub-contractors and trades? .................................... 4

2.6. Does the permit cover construction workshops? ................................................................... 5

2.7. Should there be a COVID Appointed Person (or other additional resources)? ...................... 5

2.8. What should you do once a permit is granted? ...................................................................... 5

2.9. What should you do if site plans change? .............................................................................. 6

3. Application Preparation .................................................................................................................. 6

4. Key Risk Guidance ........................................................................................................................... 8

4.1. When to travel to work (social distancing and Self – Isolation) ............................................. 8

4.2. How to travel to work ............................................................................................................. 8

4.3. If someone falls ill at work ...................................................................................................... 9

4.4. Driving at work ...................................................................................................................... 10

4.5. Site access and egress points ................................................................................................ 10

4.6. Hand washing ........................................................................................................................ 11

4.7. Toilet facilities ....................................................................................................................... 11

4.8. Rest areas .............................................................................................................................. 12

4.9. Changing facilities, showers and drying rooms ..................................................................... 13

4.10. Work planning to avoid close working (i.e. closer than 2 metres) ................................... 14

4.11. First Aid and Emergency Service response ....................................................................... 16

4.12. Cleaning ............................................................................................................................. 17

5. Further Reviewer Notes ................................................................................................................ 18

5.1. The Role of the Reviewer ...................................................................................................... 18

5.2. The Review Process ............................................................................................................... 18

5.3. Reviewers will challenge ‘generic’ application material ....................................................... 18

5.4. Reviewers will challenge ‘optimistic’ or ‘simplistic’ thinking ................................................ 18

5.5. Reviewers will challenge a lack of detail ............................................................................... 19

5.6. How the reviewer marks the application .............................................................................. 19

5.7. Withheld applications ........................................................................................................... 20

5.8. Appeals and escalation ......................................................................................................... 20

5.9. Permit revision applications .................................................................................................. 20

Appendix 1: Examples of site specific application information ............................................................ 21


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1. Introduction

In response to the COVID 19 global pandemic and recent ‘lockdown’ of the construction sector, the

Government of Jersey has introduced the ‘Covid-19 (Construction Work) (Jersey) Regulations 2020’

(hereafter called the COVID-19 Regulations) to ensure, through a construction work permit regime,

administered by Growth, Housing and Environment (GHE) (on behalf of the Minister for Health) that

sites re-operate with the right social distancing and hygiene safeguards in place. These requirements

are to protect both workers and the public.

This guide sets out the main criteria that are currently taken into consideration on making an

application for a construction work permit, how the application will be assessed and how construction

sites should approach limiting the risks of spreading Covid-19. The guide includes key questions that

the reviewers of applications will need addressing in any submission to highlight key points that should

be properly covered.

These COVID-19 Regulations are monitored by the Building Control Section of GHE and are

complementary to the ‘Health and Safety (Management in Construction) (Jersey) Regulations 2016’

and Building Bye-Laws. They do not supersede or impinge on the operation of this non COVID

legislation and it remains a requirement of all sites granted a COVID 19 ‘construction permit’ that all

other requirements under Jersey Law are met.

Where in the course of a contractor (or their commercial partner) planning to operate or re-operate

their site a conflict arises between COVID 19 and other safe working requirements, this may be an

indication that the works (or an element of those works) must for the time being be deferred until

social distancing and hygiene requirements make that work possible without such a conflict.

The current requirements of the ‘construction work’ permit regime are set out in the ‘Construction

Work (Jersey) Order 2020’. These requirements are likely to remain in place throughout each level of

Jersey’s Safe Exit Framework.

2. Basic Questions

2.1. Which construction works require a permit?

A permit is required for all “relevant construction work” having the same meaning as the ‘Health and

Safety (Management in Construction) (Jersey) Regulations 2016’, i.e. any work of construction,

alteration, conversion, fitting-out, commissioning, renovation, repair, maintenance, de-

commissioning, demolition or dismantling of any structure, and includes: -

➢ the demolition or dismantling of a structure and the removal from the relevant construction site of any product or waste resulting from the demolition or dismantling;

➢ the assembly of prefabricated elements to form a structure or the disassembly of prefabricated elements which, immediately before such disassembly, formed a structure;

➢ the installation, commissioning, maintenance, repair or removal of mechanical, electrical, gas, compressed air, hydraulic, telecommunications, computer or similar services that are normally fixed to a structure; and


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➢ any work of excavation, landscaping, preparatory work, or site preparation carried out for the purpose of any work or activity referred to in this definition (otherwise than in this sub-paragraph).

2.2. Which construction works are excluded or exempt?

The following construction works do not require a permit:-

➢ A person carrying out work in the property where they live.

➢ Works undertaken by 2 or less individuals at a construction site at which no other person is present and those individuals are able to maintain a social distance of at least 2 metres and they comply with any other guidance issued by the Medical Officer of Health.

➢ Emergency repair or maintenance works by more than 2 individuals (but no more than is

strictly necessary other than the persons who reside at that site) and those individuals are

able to maintain a social distance of at least 2 metres and they comply with any other guidance

issued by the Medical Officer of Health.

2.3. Who should apply for the permit?

The Minister may grant a permit, in relation to relevant construction work to be undertaken at a

construction site identified in the permit, to a person who is a commercial client or a relevant

contractor in relation to that work.

2.4. Does the permit cover the entire project?

The scope of the permit’s permission will be based on the application material provided. For example

if the applicant wishes the permit to cover the full scope of construction works from start to finish

then they must provide sufficient information to cover all work stages, e.g.:-

• building demolition

• site preparation / road access

• civil / utility works (on site)

• ground works / foundations / ground slab

• structure / enclosure

• roofing

• building fit out

• highway tie- in

Therefore, documents such as site plans, COVID procedures and risk assessments provided must

address site and activity changes over time. If the applicant can’t provide or foresee all of the site’s

stage requirements then it is advisable to focus the application on the more immediate activity and

submit a further permit application later.

2.5. Should the application cover the site’s sub-contractors and trades?

Yes, all construction activity on the site that forms part of the relevant construction work (to which

the permit relates) should be included in the application. The COVID 19 Regulations makes it an

offence to allow another person to undertake restricted construction work, or to fail to take

reasonable steps to prevent that, so all work needs to be covered!


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2.6. Does the permit cover construction workshops?

No, the construction work permit only applies to the ‘construction site’ as defined by the ‘Health and

Safety (Management in Construction) (Jersey) Regulations 2016’. In these Regulations, “construction

site” means any place where construction work is being carried out, including areas used for the

storage of plant and/or materials. This does not include a place where elements are manufactured

off-site or where construction material is stored as stock for sale or for hire.

2.7. Should there be a COVID Appointed Person (or other additional resources)?

There is no requirement in the COVID-19 Regulations for an appointed person to co-ordinate pre-

construction and construction phase COVID related measure, although it is important to make sure

that any additional measures you need to introduce to manage the risks of COVID-19 are properly

resourced and do not compromise the other every day risks you need to manage. Experience has

shown that it may be necessary to provide additional resource otherwise for ‘major construction

projects’ as defined by the ‘Health and Safety (Management in Construction) (Jersey) Regulations

2016’ there will be an appointed ‘Health and Safety Project Coordinator’ and such COVID duties will

fit within this role.

2.8. What should you do once a permit is granted?

The permit holder will be emailed a permit certificate (PDF) and an approved site notice poster (PDF)

with relevant permit’s details. Care should be taken to note any specific conditions on the permit

certificate and communicate them to key site personnel. The approved notice must be displayed at all

times on the outside of the site so as to be clearly visible to persons outside of the site. If more than

one permit under the Covid-19 (Construction Work) (Jersey) Order 2020 is issued for the site, the

permit holder must ensure that all notices are displayed.

Example of permit certificate: Example of approved site notice:


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2.9. What should you do if site plans change?

Significant changes in construction method, scope or phasing will not be covered by this permit. Such

changes are subject to a further permit (variation) application (via gov.je) by the permit holder in

advance of changes occurring.

3. Application Preparation

The applicant must submit the following ‘site specific’ COVID 19 construction information:

Standard Applicant Documents:

➢ Site layout plan showing vehicle / bike parking, ingress/egress, toilets, hand washing, rest areas, work / team zoning, first aid, etc.

➢ Covid 19 Site specific procedure plan (this may include adapted method statements if relevant)

➢ Covid 19 Project and site specific risk assessment (this may be included in any wider risk assessment document)

➢ Site induction documents (LARGER SITES ONLY)

➢ Site monitoring documentation (LARGER SITES ONLY)

Note: for further examples of the type of information that should be provided within documents see

Appendix 1: Examples of site specific application information

Preparation of the above documentation should be based on an assessment of how the applicant

intends to undertake their construction works safely by ensuring the right social distancing and

hygiene safeguards in place (through clear site procedures and distancing measures). This is best

achieved by working through the guidance in ‘Section 4’ and addressing each of the key risk areas in

turn.

The applicant must provide clear documentary evidence of their thinking as the application reviewer

will ask these basic questions. Does the applicant have:-

A. Sufficient understanding of social distancing and hygiene risks and requirements for the specific site or phase of works in question?

B. Adequate (proposed) procedures and controls to implement social distancing and hygiene requirements on the site or during the phase of works in question?


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Summary of key risk areas

Summary of key risk areas When relevant?

1. When to travel to work Always

2. How to travel to work Always

3. Procedure if someone falls ill at work Always

4. Driving at work Always

5. Site access and egress points Always

6. Hand washing Always

7. Toilet facilities Always

8. Rest areas Generally only relevant to larger sites

9. Changing facilities, showers and drying rooms

Generally only relevant to larger sites or those dealing with contamination issues

10. Work planning to avoid close working (i.e. closer than 2 metres)

Always

11. First aid and emergency service response Always

12. Cleaning Always


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4. Key Risk Guidance

This guidance is based on ‘version 3’ (issued on 14th April) of the ‘Construction Leadership Council's’

(CLC) guidance ‘Construction Sector - Site Operating Procedures Protecting Your Workforce During

Coronavirus (Covid-19)’:-

4.1. When to travel to work (social distancing and Self – Isolation)

CLC Guidelines: Workers should not travel to site for work unless they are compliant with social

distancing and self-isolation guidelines (summaries below).

Workers should NOT come to site IF:-

➢ Their work can be carried out from home

➢ They have a high temperature or a new persistent cough OR is within 14 days of the day when the first member of their household showed symptoms of Coronavirus (Covid-19).

➢ They are at increased risk of severe illness from Coronavirus (Covid-19) by virtue of their age, underlying health condition, clinical condition (or are pregnant).

➢ They are identified as extremely vulnerable by their GP, etc.

➢ They are living with a person who is at increased risk of severe illness, or an extremely vulnerable person.

GOJ Reviewer Questions: Does the application show sufficient understanding of this requirement (check the risk assessment) and does it detail adequate procedures and measures to ensure that workers will understand and apply them (check the site induction / monitoring documents)? For example:-

➢ Has the applicant considered asking workers, as they arrive on site (before entry) and leave, to confirm that they are symptom free? And use a thermometer gun to check worker’s temperature?

4.2. How to travel to work

CLC Guidelines: Wherever possible workers should travel to site alone using their own transport. If workers have no option but to share transport:-

➢ Journeys should be shared with the same individuals and with the minimum number of people at any one time

➢ Good ventilation (i.e. keeping the windows open) and facing away from each other may help to reduce the risk of transmission

➢ The vehicle should be cleaned regularly using gloves and standard cleaning products, with particular emphasis on handles and other areas where passengers may touch surfaces


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Sites should consider:-

➢ Parking arrangements for additional vehicles and bicycles

➢ Other means of transport to avoid public transport e.g. cycling

➢ Providing hand cleaning facilities at entrances and exits. This should be soap and water wherever possible or hand sanitiser if soap and water are not available

GOJ Reviewer Questions: Does the application show sufficient understanding of this requirement (check the risk assessment) and does it detail adequate procedures and measures to ensure workers will understand and apply them (check the site specific procedure and site plan)? For example:-

➢ Has the applicant identified ways to support workers travelling to work using their own means (walk, cycle or car) to reduce the need to travel by public transport? For example, has the applicant tried to ensure sufficient worker car / bike parking (to encourage lone occupancy rather than car sharing). If space for this is not available consider staggering start and finish times?

➢ Will parking arrangements ensure social distancing (e.g. such as vehicles facing in the same direction) with relevant direction signs.

4.3. If someone falls ill at work

CLC Guidelines: If a worker develops a high temperature or a persistent cough while at work, they

should:-

➢ Ensure their manager or supervisor is informed

➢ Return home immediately

➢ Avoid touching anything

➢ Cough or sneeze into a tissue and put it in a bin, or if they do not have tissues, cough and sneeze into the crook of their elbow.

They must then follow the guidance on self-isolation and not return to site until their period of self-

isolation has been completed.

GOJ Reviewer Question: Does the application show sufficient understanding of this requirement (check the risk assessment) and does it detail adequate procedures and measures to ensure workers will understand and apply them (check the site specific procedure and site induction / monitoring documents)? For example:-

➢ Has the applicant ensured that all staff on site are accounted for (via a log) and they understand what is expected of them (who to inform, where to go on site to wait for collection) should they fall ill?

➢ Has the applicant considered the best options for getting sick workers home (ideally by a household member), or taken home by the person that brought them (if car sharing - not encouraged), or otherwise by another site team member (if willing) with the vehicle window open and using RPE, etc.? Use of public transport or taxi are a last resort.


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4.4. Driving at work

CLC Guidelines: When travelling at work or between site locations, workers should travel alone. If

workers have no option but to share a vehicle, then they should:-

➢ Share with the same individuals and with the minimum number of people at any one time

➢ Wherever possible maintain a distance of two metres and avoid touching their faces

➢ Wash their hands for 20 seconds using soap and water (or hand sanitiser if soap and water are not available) before entering and after getting out of the vehicle

➢ Maintain good ventilation (i.e. keeping the windows open) and face away from each other during the journey

➢ Regularly clean the vehicle using gloves and standard cleaning products, with particular emphasis on handles and other surfaces which may be touched during the journey.

GOJ Reviewer Questions: Does the application show sufficient understanding of this requirement (check the risk assessment) and does it detail adequate procedures and measures to ensure workers will understand and apply them (check the site specific procedure and site induction / monitoring documents)?

4.5. Site access and egress points

CLC Guidelines: Sites should:-

➢ Stop all non-essential visitors

➢ Consider introducing staggered start and finish times to reduce congestion and contact at all times

➢ Plan site access and egress points to enable social distancing – you may need to change the number of access points, either increase to reduce congestion or decrease to enable monitoring, including in the case of emergencies

➢ Allow plenty of space between people waiting to enter site

➢ Use signage:-

o Such as floor markings, to ensure 2 metre distance is maintained between people when queuing;

o Reminding workers not to attend if they have symptoms of Coronavirus (Covid-19) and to follow guidelines.

➢ Remove or disable entry systems that require skin contact (e.g. fingerprint scanners) unless they are cleaned between each individual use

➢ Require all workers to wash their hands for 20 seconds using soap and water when entering and leaving the site

➢ Regularly clean common contact surfaces in reception, office, access control and delivery areas e.g. scanners, turnstiles, screens, telephone handsets and desks, particularly during peak flow times

➢ Reduce the number of people in attendance at site inductions and consider holding them outdoors wherever possible, ideally maintaining 2 metre distancing.


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➢ Where loading and offloading arrangements on site will allow it, drivers should remain in their vehicles. Where drivers are required to exit their vehicle, they should wash or sanitise their hands before handling any materials

➢ Consider arrangements for monitoring compliance.

GOJ Reviewer Questions: Does the application show sufficient understanding of this requirement (check the risk assessment) and does it detail adequate procedures and measures to ensure workers will understand and apply them (check the site plan, site specific procedure, site induction / monitoring documents)?

4.6. Hand washing


➢ Allow regular breaks to wash hands

➢ Provide additional hand washing facilities (e.g. pop ups) to the usual welfare facilities, particularly on a large spread out site or where there are significant numbers of personnel on site, including plant operators

➢ Ensure adequate supplies of soap and fresh water are readily available and kept topped up at all times

➢ Provide hand sanitiser (minimum 60% alcohol based) where hand washing facilities are unavailable

➢ Regularly clean the hand washing facilities

➢ Provide suitable and sufficient rubbish bins for hand towels with regular removal and disposal.


4.7. Toilet facilities


➢ Restrict the number of people using toilet facilities at any one time (e.g. use a welfare attendant) and use signage, such as floor markings, to ensure 2 metre distance is maintained between people when queuing

➢ Wash or sanitise hands before and after using the facilities

➢ Enhance the cleaning regimes for toilet facilities, particularly door handles, locks and the toilet flush

➢ Portable toilets should be avoided wherever possible, but where in use these should be cleaned and emptied more frequently

➢ Provide suitable and sufficient rubbish bins for hand towels with regular removal and disposal.


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What the ‘Guidance Construction (Jersey) Regulations 2016’ says (USE AS A LOWER BENCHMARK FOR COVID 19 PROCEDURES)

Toilets: Portable chemical toilets are a last resort, and are only acceptable where it is not reasonably practicable to provide more suitable facilities.

The number of toilets required will depend on the number of people on site and the type of facilities provided. Where portable toilets are provided, a minimum ratio of 1 toilet to 7 persons is recommended if the portable toilets are emptied once a week - note during COVID 19 a maximum ratio of 1 to 5 is preferred! Men and women may use the same toilet if it is in a lockable room and partitioned from any urinals, otherwise separate toilets should be provided. Adequate supplies of toilet paper should always be available.

All toilets must be adequately ventilated, lit and maintained in a clean condition. The frequency of cleaning will depend on usage – basic daily cleaning during COVID 19 will NOT be sufficient.

(Toilet specific hand) washing facilities: Washing facilities should be provided next to the toilets. These should include:

• a supply of clean hot and cold running water. If mains water is not available, water supplied from a tank may be used

• soap or other suitable means of cleansing

• towels or other suitable means of drying

GOJ Reviewer Questions: Does the application show sufficient understanding of this requirement (check the risk assessment) and does it detail adequate procedures and measures to ensure workers will understand and apply them (check the site plan, site specific procedure, site induction / monitoring documents)? For example:-

➢ The applicant must provide a clear justification for not meeting the above minimum welfare requirement and any alternative arrangements must be reasonable and fair to workers, for example just sending them down the road to the nearest public toilet facility is not in the majority of cases an acceptable alternative.

➢ To create sufficient facilities, applicants may suggest using toilet rooms within a completed part of a building on the construction site, provided they can show that there will be a minimum 2 metre social distancing when accessed / in use?

4.8. Rest areas

CLC Guidelines: Where possible, workers should be encouraged to bring their own food. They should

also be required to stay on site once they have entered it and avoid using local shops.

➢ Consider increasing the number or size of facilities available on site if possible

➢ The capacity of any rest area should be clearly identified at the entry to each facility, and where necessary attendants provided to supervise compliance with social distancing measures

➢ Break times should be staggered to reduce congestion and contact at all times

➢ Drinking water should be provided with enhanced cleaning measures of the tap mechanism introduced (or personal bottled drinking water provided).


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➢ Frequently clean surfaces that are touched regularly, using standard cleaning products e.g. kettles, refrigerators, microwaves

➢ Hand cleaning facilities or hand sanitiser should be available at the entrance to any room where people eat and should be used by workers when entering and leaving the area

➢ A distance of 2 metres should be maintained between users, wherever possible

➢ All rubbish should be put straight in the bin and not left for someone else to clear up

➢ Tables should be cleaned between each use

➢ Crockery, eating utensils, cups etc. should not be used unless they are disposable or are washed and dried between use, or workers bring their own

➢ Consider arrangements for monitoring compliance.


4.9. Changing facilities, showers and drying rooms


➢ Consider increasing the number or size of facilities available on site if possible

➢ Based on the size of each facility, determine how many people can use it at any one time to maintain a distance of two metres

➢ Restrict the number of people using these facilities at any one time e.g. use a welfare attendant

➢ Introduce staggered start and finish times to reduce congestion and contact at all times

➢ Introduce enhanced cleaning of all facilities throughout the day and at the end of each day

➢ Provide suitable and sufficient rubbish bins in these areas with regular removal and disposal.

GOJ Reviewer Questions: (Generally relevant to larger sites or those dealing with contamination issues): Does the application show sufficient understanding of this requirement (check the risk assessment) and does it detail adequate procedures and measures to ensure workers will understand and apply them (check the site plan, site specific procedure, site induction / monitoring documents)?


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4.10. Work planning to avoid close working (i.e. closer than 2 metres)

CLC Guidelines: Sites and work need to be planned and organised to avoid crowding and minimise the

risk of spread of infection. Sites should remind the workforce (e.g. at daily briefings) of the specific

control measures.

Where it is not possible to follow the social distancing guidelines in full in relation to a particular

activity, sites must consider whether that activity needs to continue for the site to operate. If so the

hierarchy of controls in the table below must be used (and any sector-specific guidance) to risk assess

the activity. All mitigating actions must be taken to reduce the risk of COVID 19 transmission.

Hierarchy of Controls

Eliminate ➢ Workers who are unwell with symptoms of Coronavirus (Covid-19) should not travel to or attend the site

➢ Rearrange tasks to enable them to be done by one person, or by maintaining social distancing measures (2 metres)

➢ Avoid skin to skin and face to face contact

➢ Stairs should be used in preference to lifts or hoists and consider one ways systems

➢ Consider alternative or additional mechanical aids to reduce worker interface

Site Meetings (but if absolutely necessary):

➢ Only essential participants should attend

➢ Attendees should be at least two metres apart from each other

➢ Rooms should be well ventilated / windows opened to allow fresh air circulation

➢ Consider holding meetings in open areas where possible

Reduce Where social distancing measures (2 metres) cannot be applied:

➢ Minimise the frequency and time workers are within 2 metres of each other

➢ Minimise the number of workers involved in these tasks

➢ Workers should work side by side, or facing away from each other, rather than face to face

➢ Lower the worker capacity of lifts and hoists to reduce congestion and contact at all times

➢ Regularly clean common touchpoints, doors, buttons, handles, vehicle cabs, tools, equipment etc.

➢ Increase ventilation in enclosed spaces

➢ Workers should wash their hands before and after using any equipment

Isolate Keep groups of workers that have to work within 2 metres:

➢ Together in teams e.g. (do not change workers within teams)

➢ As small as possible

➢ Away from other workers where possible


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Control Where face to face working is essential to carry out a task when working within 2 metres:

➢ Keep this to 15 minutes or less where possible

➢ Consider introducing an enhanced authorisation process for these activities

➢ Provide additional supervision to monitor and manage compliance

PPE Sites should not use RPE for Coronavirus (Covid-19) where the two metre social distancing guidelines are met.

➢ Where it is not possible to maintain a two metre distance, each activity should be risk assessed using the hierarchy of controls and against any sector-specific guidance, mindful that masks (RPE) are the last resort in the hierarchy

➢ Re-usable PPE should be thoroughly cleaned after use and not shared between workers

➢ Single use PPE should be disposed of so that it cannot be reused

➢ Where personnel are required to work in specific environments (e.g. where persons are shielding, with symptoms, or confirmed Coronavirus (Covid-19) cases may be present e.g. healthcare or in a home environment) additional PPE should be considered specific to the Coronavirus (Covid-19) risk

Behaviour The measures necessary to minimise the risk of spread of infection rely on everyone in the industry taking responsibility for their actions and behaviours.

Please encourage an open and collaborative approach between workers and employers on site where any issues can be openly discussed and addressed.

GOJ Reviewer Questions: Does the application show sufficient understanding of the 2 metres minimum social distancing requirement (check the risk assessment) and does it detail adequate procedures and measures to ensure workers will understand and apply them (check the site specific procedure, site induction / monitoring documents)? For example:-

Risk management

➢ Has the applicant identified where tasks will sit on the hierarchy of control decision making (in respect of distancing). For example, do they recognise the need for work sequencing, or to provide PPE / RPE in certain cases, or to defer certain works (that can’t be carried with adequate social distancing)? If not then it is advisable to challenge the applicant to see if they have really considered the issues correctly.

General site management

➢ Has the applicant a clear plan for work activity / team zoning, per construction area, building plot, per floor?

➢ Has the applicant demonstrated consideration of how workers will move around the site when accessing meeting points, work zones, building plots, toilets, rest areas, material stores, site offices, etc.? For example, having a one-way flow system to segregating flows of foot traffic physically or using signs and floor markings, or using waiting / passing points, having one doorway to access a building, and another to exit, having a separate staircases for going up and down, etc?


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Work space management

➢ Has the applicant demonstrated work time sequencing to avoid staff / contractors overlapping / overcrowding work spaces?

➢ Has the applicant a plan for reducing person to person contact? For example:

o discouraging non-essential trips around the site by ensuring workers have sufficient tools and materials to work for longer periods.

o making sure portable tools are not shared between different people. Where this cannot be avoided, carefully considering what controls and cleaning procedures are required.

o Identifying areas where people may have to pass things to each other, for example, drawings, materials etc. through the use of drop off points or transfer zones.

Site deliveries

➢ Has the applicant considered site deliveries and laying down areas? These should be designed to maintain social distancing. Wherever possible, using mechanical means to load and off-load deliveries. Where this is not possible, using the same pairs of people to carry out such work if 2m distancing can be maintained.

➢ Has the applicant considered methods to reduce frequency of deliveries, for example by ordering larger quantities less often?

➢ Ideally delivery staff / contractors should be made aware of rules / procedures before arriving at site. This will require supervision!

4.11. First Aid and Emergency Service response

CLC Guidelines: Site should administer first aid until the Emergency Services attend.

➢ When planning site activities, the provision of adequate first aid resources must be agreed between the relevant parties on site

➢ Emergency plans including contact details should be kept up to date

➢ Consideration must also be given to potential delays in Emergency Services response, due to the current pressure on resources

➢ Consideration should be given to preventing or rescheduling high-risk work or providing additional competent first aid or trauma resources!

GOJ Reviewer Questions: Does the application show sufficient understanding of this requirement (check the risk assessment) and does it detail adequate procedures and measures to ensure workers will understand and apply them (check the site specific procedure and monitoring documents)?


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4.12. Cleaning

CLC Guidelines: Enhanced cleaning procedures should be in place across the site, particularly in

communal areas and at touch points including:-

➢ Taps and washing facilities

➢ Toilet flush and seats

➢ Door handles and push plates

➢ Hand rails on staircases and corridors

➢ Lift and hoist controls

➢ Machinery and equipment controls

➢ All areas used for eating must be thoroughly cleaned at the end of each break and shift, including chairs, door handles, vending machines and payment devices.

➢ Telephone equipment

➢ Key boards, photocopiers and other office equipment

➢ Rubbish collection and storage points should be increased and emptied regularly throughout and at the end of each day.

GOJ Reviewer Questions: Does the application show sufficient understanding of this requirement (check the risk assessment) and does it detail adequate procedures and measures to ensure workers will understand and apply them (check the site specific procedure and monitoring documents)?:

➢ Ensure that cleaning contracts and enhanced procedures have been put in place, etc. This may include ensuring that suitable cleaning products are available for workers to use outside of the regular cleaning times (such as to disinfect sink area in rest rooms between uses).


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5. Further Reviewer Notes

5.1. The Role of the Reviewer

The role of the reviewer is to look at the application documentation and on the basis of that

documentation assess these basic questions. Does the applicant have:-

C. Sufficient understanding of social distancing and hygiene risks and requirements for the specific site or phase of works in question?

D. Adequate (proposed) procedures and controls to implement social distancing and hygiene requirements on the site or during the phase of works in question?

5.2. The Review Process

To answer the above question the reviewer will check through the application documents:

Standard Applicant Documents:

➢ Site layout plan showing vehicle / bike parking, ingress/egress, toilets, hand washing, rest areas, work / team zoning, first aid, etc.

➢ Covid 19 Site specific procedure plan (this may include adapted method statements if relevant)

➢ Covid 19 Project and site specific risk assessment (this may be included in any wider risk assessment document)


➢ Site monitoring documentation template (LARGER SITES ONLY)

Note: for further examples of the type of information that should be provided within documents see

the Appendix 1: Examples of site specific application information

5.3. Reviewers will challenge ‘generic’ application material

It is important that the applicant has addressed each ‘’key risks area’ in relation to the site in question,

so reviewers should be careful to assess if the applicant has really done so or has just pasted together

a generic assessment using CLC published guidance or even worse un-COVID related risk assessment

/ method statement material. If so then the reviewer will challenge the applicant and address this

approach. Ensure there is an adequate site plan with the C19 site specific procedure plan and risk

assessment which shows thinking, the key risk areas, i.e. ingress/egress, toilets, hand washing, rest

areas, work / team zoning, etc.

5.4. Reviewers will challenge ‘optimistic’ or ‘simplistic’ thinking

Some applicants when preparing there C19 site specific procedure plan and risk assessment may be

tempted to be optimistic or simplistic about their site, for example how they are going to avoid close

working. If application documents use language like “all works will be carried out while observing 2m

safe distancing” without identifying where individual work tasks sit on the hierarchy of control

decision making (in respect of 2m distancing) then reviewers will challenge the applicant to see if they

have really considered the issues correctly. For example, does the applicant at any point recognise


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the need for work sequencing, or to provide PPE / RPE in certain cases, or to defer certain works (that

can’t be carried out with adequately with 2m social distancing)?

5.5. Reviewers will challenge a lack of detail

If the application fails to capture the nature of the work stage that the project is at (i.e. which stage

the application covers) or give sufficient details to understand their proposed mitigation controls, for

example the number of staff on site at one time, ingress / egress controls, demarcations and zoning

within the site, the number of toilets, rest areas, locations, how often will they be cleaned, then the

reviewer will challenge the applicant to provide this as required.

5.6. How the reviewer marks the application

For each relevant ‘key risk area’ the reviewer will use the ‘Application Results Sheet’ to record if the

submission is either a ‘Fail’, ‘Partial’, ‘Pass’ or ‘NA’ as set out in the below table.

Table: Application Results Sheet categories

➢ Fails to demonstrate sufficient understanding or to propose adequate controls, e.g. insufficient application material or use of a generic approach (cut and paste).

Fail

➢ Partially demonstrates understanding or proposes adequate controls e.g. correctly identified a risk but failed to identify an adequate mitigation, or procedure in the method statement.

Partial

➢ Fully demonstrates understanding and proposes adequate controls. Pass

➢ Not Applicable , If in the Reviewers assessment it is not relevant to the site in question, e.g. due to the type of work / site setup

NA

Further Reviewer Actions and Outcome!

What to do if a key risk area is assessed as a Fail:

The reviewer will contact the applicant and explain the particular requirement and ensure understanding. They will work through the application with them and talk through how the applicant is planning to keep all involved on site safe. When they do that it may become easier for the applicant to put into words what is required and re-submit the documents with a better understanding.

➢ IF IT CAN BE AMENDED then the relevant application material should be resubmitted directly to the reviewer (via email) and the Application Result Sheet will be updated.

➢ IF IT CAN’T BE AMENDED, i.e. there is a more fundamental constraint (e.g. a site or resources issue) then the outcome of the review will be to ‘Withhold’ the application. The reviewer will record their comments against the relevant key risk area on the Application Result Sheet.


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What to do IF a key risk area is assessed as a Partial:

The reviewer will contact the applicant and explain the particular requirement and ensure understanding. They will work through the application with them and see if the issue can be rectified and the application material amended by them. It may be that there is sufficient understanding of a risk but that only partial compliance is possible due to a particular site or resources issue.

➢ IF IT CAN BE AMENDED because the reviewer believes that an alternative mitigation is possible and reasonable (for example excluding a particular element of high risk work – for the time being) then the applicant will amended their application material accordingly and resubmit directly to the reviewer (via email) and the Application Result Sheet will be updated. The reviewer should record their comments against the relevant key risk area on the Application Result Sheet.

➢ IF IT CAN’T BE AMENDED, i.e. there is a more fundamental constraint (e.g. a site or resources issue) then the outcome of the review will be to ‘Withhold’ the application. The reviewer will record their comments against the relevant key risk area on the Application Result Sheet.

Review Outcome: Just one key risk assessment FAIL or PARTIAL (without reasonable mitigation) is sufficient to WITHHOLD the application.

5.7. Withheld applications

The reviewer will inform the applicant of the outcome of the review and the reasons.

5.8. Appeals and escalation

If the applicant wishes to appeal a review outcome then the reviewer will request that the application

documents and original application result sheet are issued to a second reviewer for re-evaluation and

the process repeated. That outcome will be final under the current social distancing and hygiene risks

and requirements.

5.9. Permit revision applications

Significant changes in construction method, scope or phasing will not be covered by a permit and

subject to a further permit (variation) application (via gov.je).

Such applications will be managed using the same reviewer as the original application where possible,

who is familiar with the site. The application emailed to the reviewer will include the reference

number of the original application and the new application number.


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Appendix 1: Examples of site specific application information

➢ Site layout plan

Must be specific to the phases of work to be included under the permit.

➢ Car / bike parking arrangements to ensure social distancing (e.g. such as vehicles facing in the same direction) with relevant direction signs.

➢ Secure site boundaries and controlled points of ingress and egress.

➢ Ingress and egress arrangements (ideally two separate points, or with controls to manage social distancing, such as demarked 2m queue spacing and entry management controls (sites may need to stagger start and finish times).

➢ Rules regarding worker movement around site, such as one-way flow systems, waiting / passing points, one doorway in / out, separate staircases for going up and down, etc?

➢ Construction areas, building plots, with worker / teams zoning

➢ Toilets (minimum 1 for every 5 persons, minimum separation to ensure 2 metre minimum social distancing) with hand washing facilities (ideally using hot running water and soap).

➢ Handwashing / hygiene points (e.g. clearly marked at site entrances, access work zones / building plots, toilets, rest areas, induction / meeting points, material stores, site offices, first aid, etc.).

➢ Rest areas (enough to ensure minimum 2 metre social distancing, may require staff to stagger breaks, demarked as required).

➢ Induction / meeting points

➢ Material stores

➢ Site offices

➢ First aid points

➢ Plant locations / use (e.g. dumper / fork lift / telehandler / excavator, etc.)

➢ Deliveries and laying down areas marked out to ensure 2 metre minimum social distancing.

➢ Emergency access


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➢ Procedure plan (this may include adapted method statements if relevant)

➢ SEE SECTION 4: KEY RISK GUIDANCE

➢ Risk assessment (this may be included in any wider risk assessment document)

➢ Should identify where tasks will sit on the hierarchy of control decision making (in respect of distancing). For example do they recognise the need for work sequencing, or to provide PPE / RPE in certain cases, or to defer certain works (that can’t be carried out with adequate social distancing)? If not then it advisable to challenge the applicant to see if they have really considered the issues correctly.


Ensure all workers (incl. contractors, delivery staff) are appropriately inducted, where possible before attending site, so that they understand:-

➢ When / if to turn up to site, i.e. when to self-isolate?

➢ Shifts times, parking and site ingress / egress arrangements.

➢ Signing in/out rules, etc.

➢ Rules regarding 2m social distancing and increased hand washing / hygiene while on site.

➢ Rules regarding worker movement around site, such as one-way flow systems, waiting / passing points, one doorway in / out, separate staircases for going up and down, etc?

➢ What to do should workers fall ill (i.e. who to inform, where to wait, ideally knowing in advance who from their household to contact to collect them, if anyone, etc.).

➢ Procedures for reporting concerns about unsafe activity / behaviour.

Ensure that there are information posters at entrances to work zones / building plots, at hand washing points, toilets, rest areas, meeting points, material stores, site offices, etc. (in relevant languages?) with COVID 19 site requirements.

➢ Site monitoring documentation template (LARGER SITES ONLY)

➢ Who will monitor (i.e. COVID Appointed Person?), how often, documentation, feedback to management and further action to improve safety (e.g. toolbox talks, discipline).