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Preparing for the New Normal: Vaccination Policy for Employers

As businesses prepare for the “The New Normal” (probably by the end of June) of vaccinated employees, regular workplace testing and continued social distancing – we have prepared guidance to help you implement a vaccination policy and templates on:

  • Vaccination policy for your business 
  • Covid-19 workplace risk checklist
  • Vaccine register for all staff    

The Bank of England (BoE) chief economist Andrew Haldane has commented that the UK economy is like a “coiled spring”, and that consumer confidence would surge back thanks to the vaccine programme.

Today, BoE Governor Andrew Bailey stated the UK economy will recover to its pre-Covid level by the end of this year, albeit with a cautionary note on the level of uncertainty still surrounding the virus. 

Employers Vaccination and Testing Policy Guidance

Over 50,000 English businesses have now registered their interest for Free rapid tests for all businesses for regular workplace testing. 

You can order free rapid lateral flow tests to test your employees twice a week in the workplace. We expect similar schemes to roll out in all UK regions shortly – but you must register on or before 31 March 2021.

The UK Covid-19 vaccines delivery plan was first published on the 11 January 2021.

The executive summary states: “Vaccines are a foundation of our way out of this pandemic and the best way to protect people from COVID-19, potentially saving thousands of lives.

Review and edit as appropriate and refer to the https://www.gov.uk/coronavirus website for further resources and please feel free to call us to discuss any specific issues you may have.  

Please note: these are examples only and should not be relied upon until you have confirmed contents with your advisors, solicitors and / or HR specialists or performed a check to make sure you are comfortable with sending employees a copy. Please review, edit and add your details as appropriate. This policy note should be read in conjunction with the detailed legislation or regulations. No responsibility for loss occasioned by any person acting or refraining from action as a result of the material contained in this programme can be accepted by the authors or TurnerWarran.

Vaccination Policy

Please note this is an example and should not be relied upon until you have confirmed contents with your solicitors and / or HR specialists or reviewed Government guidance to your own satisfaction. 

There are 14 industry specific “Working safely during coronavirus (COVID-19)” Government guides and you should have implemented workplace changes to reduce the risk of transmission already. If not see: https://www.gov.uk/guidance/working-safely-during-coronavirus-covid-19

Below is a template of suggested wording if you are going to introduce a vaccination policy in your business. 

COVID-19 Vaccination and Testing Policy for [Insert Business Name]

The UK Covid-19 vaccines delivery plan was published on the 11 January 2021. The executive summary states: “Vaccines are a foundation of our way out of this pandemic and the best way to protect people from COVID-19, potentially saving thousands of lives.”

Our policy on vaccinations

This policy statement allows [NAME OF BUSINESS] to outline its views on vaccinations and explains the role of and expectations on employees and ensures the workplace is as Covid secure as possible.

The business is aware of the Working safely during coronavirus guidelines published by HM Government and has undertaken a review dated [Date]. The actions taken to work more safely during Covid-19 can be seen here: [insert link to document]. The working safely guidelines are under regular review and we will update employees on workplace changes as appropriate.

COVID-19 is a reportable disease under the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (RIDDOR).

The Health and Safety at Work Act 1974 obliges [NAME OF BUSINESS] to take reasonable steps to reduce any workplace risks. This duty gives the justification for encouraging our employees to be vaccinated to protect themselves and everyone else at the workplace.

The policy of [NAME OF BUSINESS] is to encourage all employees to have the vaccine when offered.

[NAME OF BUSINESS] acknowledges some employees cannot have the vaccine on medical grounds and specific measures will be taken to ensure the safety of these employees and others in the workplace. Please notify us if this is your situation. With your consent, we will take appropriate steps with regards to reinforcing a secure working environment, facilitating remote working where possible, or considering a different role.

For employees who are hesitant to have the vaccine on religious, spiritual or other grounds we encourage you to understand one of our roles is to act as a “gatekeeper” for the health and safety of all employees and we will encourage you to discuss your concerns with management and we will consider each case individually. 

For employees who ultimately refuse the vaccine, or refuse to disclose whether they have had the vaccine, we will consider your reasons and discuss together ways to implement alternative solutions such as continued working from home, social distancing within the workplace, screens and the use of PPE. We may also be willing to consider changing your work responsibilities or role if this could enable you to work remotely or in a safer working environment.

It is the policy of [NAME OF BUSINESS] to maintain a register of employees who have been vaccinated. This is a voluntary procedure for employees, and we are encouraging you to confidentially share your vaccination details with us so we can judge the level of Covid-19 testing required at our workplace and other Covid-19 risk reduction measures. The information provided to us will be treated as securely as your payroll details and will not be released to anyone or anywhere without your express written consent.   

Testing policy

Around 1 in 3 people with coronavirus don’t have symptoms, which means they could be spreading the virus in workplaces without knowing. Rapid testing detects cases quickly – in under 30 minutes – meaning positive cases can isolate immediately, breaking chains of transmission.   

Our policy is to perform Workplace testing for Covid-19 regularly on employees (whether or not they have been vaccinated) and (if appropriate) visitors to the workplace per the government guidance.

[NOTE: Decide on whether all employees to be tested or those not vaccinated]  

Regular testing could be the difference between a workplace being able to stay open and operational, or needing to close due to a COVID-19 outbreak. It forms a crucial part of the government’s plan to ease restrictions gradually and safely as we get back to a more normal life.

[NAME OF BUSINESS] has registered with the Government to receive rapid workplace testing and we will be implementing the procedures as outlined above.   

At all times we will refer to our duties in the Health and Safety at Work Act 1974 which requires the employer to take all reasonably practicable steps to reduce workplace risks to their lowest practicable level. 

If you have any concerns over the policies outlined above please contact us to discuss matters confidentially.  

[Name 

Position

Date] 

COVID-19 Vaccination and Testing Risk Assessment Checklist

The checklist below is designed to enhance your existing risk assessment and guide you to the resources to assist you in redesigning procedures to accommodate regular testing and vaccinated employees and visitors.

  1. Register your interest by 31 March for free rapid tests for all businesses – https://www.gov.uk/get-workplace-coronavirus-tests
  2. Review the working safely during coronavirus sector specific industry guide(s) – see link above.
  3. If you have not done so previously, perform an initial assessment of workplace safety.
  4. Use interactive HSE tools – https://www.hse.gov.uk/simple-health-safety/risk/index.htm
  5. Outline the further actions you need to take to make the workplace secure. These may include social distancing, partitions, PPE, one-way systems, rotating employees in any given area / time frame, deep cleaning and sanitization stations, visitor areas.  
  6. Document your risk assessment and procedures.
  7. Confirm your internal workplace procedures are up to date and appropriate to help reduce transmission and maintain employee safety.
  8. Update procedures if necessary and document your revised risk assessment.
  9. Implement a testing policy for employees and visitors – a sample, all, non-vaccinated or combination? Note your reasons for the policy and document. 
  10. If employees have been working from home discuss the return to the workplace with them in advance to address their concerns and expectations.
  11. Send vaccination and testing policy statement to all employees.
  12. Note questions and discuss with employees individually any concerns.
  13. Obtain employee consent for their information to go on internal register. 
  14. Note any non-consenting employees for additional covid-19 safety procedures e.g. regular testing (if applicable). 
  15. Consider new procedures for employee safety for those who cannot or will not have the vaccine.  
  16. Document all conversations regarding the policy on personnel records.    
  17. Consult your HR specialist to check your actions are compliant with employment law or best practice until any new case law or legislation comes into force.

Template vaccine and testing register

The Excel register allows you to record the date and type of vaccinations and employee consent to you maintaining their records. It also allows you to note the date of testing for Covid-19 through the Government’s free lateral flow coronavirus tests.

You can record this manually or use the excel spreadsheet template above. The spreadsheet template has been prepopulated with room for four Covid-19 test dates and results. 

Your business may need more for “at risk” individuals or where your business cannot socially distance and needs to rely on more testing.

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