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Risk Review

Managing Your WHS & Building Risks as Pandemic Restrictions Change

28 July 2020

The COVID-19 pandemic has had far-reaching impacts on people and businesses, creating a dynamic legislative environment that necessitates rapid change to processes and operational set ups. The recent transition to ‘COVIDSafe’ ways of working prescribes careful consideration of the health and safety risks presented by the pandemic, as well as long-term implications for business continuity and operations.

The current focus for many businesses and facility managers is to minimise the risk of COVID-19 transmission to workers and the public, and to ensure that workplaces and buildings can be safely reoccupied in states where restrictions are lifting, and to ensure appropriate ongoing COVIDSafe management of assets during continued periods of reduced occupancy.

Applying forethought and planning to your building’s operations prior to, during, and following a shutdown can go a long way in reducing issues that may be faced when normal operations recommence. Understanding what essential maintenance and other safety requirements (legislative and best practice) are required to be conducted within a building during a shutdown and upon reopening is key to ensuring that the building can be reoccupied safely and effectively as it is reopened. Facilitating this transition requires an understanding of what the risks are, what controls can be put in place, and what your obligations are.

This Risk Review aims to highlight several facets of WHS and Building risks related to reopening of workplaces after extended periods.


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Pandemic Plans

The primary consideration for safe building reoccupation, and resumption of business activities, is infection risk; whether controls are sufficient to prevent or limit virus transmission within a workplace in the event of an exposure. There is now a wealth of regulatory guidance and industry-specific information available to assist businesses when planning and implementing their return to normality.

This guidance centres on the development of Pandemic (or COVIDSafe) Plans which set out the necessary control measures for a business to resume their activities in a manner aligned with regulatory requirements on social distancing, workplace cleanliness, worker awareness and education, and contingency plans in the event of an exposure.


COVIDSafe Risk Assessments

To identify appropriate controls and implement a Pandemic Plan relevant to a workplace or business, it is critical to understand the specific risk profile of that workplace. For instance, shared use building areas such as lobbies, end-of-trip facilities and lifts may present an elevated risk due to their highly trafficked nature, and occupancy by individuals external to the operational control procedures of a business such as other tenants, visitors and contractors.

Activities that require person-to-person interaction or that take place within high occupancy areas may also present challenges due to an inability to maintain physical distancing between individuals. Cleaning and disinfection protocols need to be robust and aligned with the specific activities and occupancy rate of a workplace.

COVIDSafe Risk Assessments consider the specific risk-profile of a workplace and assets, reviewing the adequacy of existing control measures, and identifying any additional controls required, such as changes to cleaning and disinfection processes, occupancy rate management, access and egress routing, and physical distancing.

Bonus Resource: Download Greencap’s ‘COVID-19 Risk Management Framework Flowchart’


Cleaning & Disinfection

A key component of maintaining COVIDSafe operations is the implementation of a cleaning and disinfection regime that is appropriate for a building’s interior, furnishings, and mechanical ventilation systems. To ensure the building can be safely reoccupied after any shutdown, it is important to engage the correct cleaning contractors and verify that their cleaning methodology and anti-viral cleaning products used are adequate and in line with recommended guidelines and best practice.

Read: Disinfectants for use against COVID-19 in the ARTG for legal supply in Australia

The closure and reopening of a building would also require a more general assessment of the building’s cleaning requirements. Leaving a building to “sit” without an appropriate cleaning regime in place may create other health hazards. If a building is not adequately cleaned prior to and/or during a shutdown, there is an increased risk of hazards such as vermin/pest infestations from food waste, environmental hazards, chemical leaks, dirty and dusty tenancies, and unclean common areas.

Rectifying these types of problems can cost significant amounts of money and place a strain on already limited resources.

Bonus Resource: Download Greencap’s ‘Workplace Hygiene Checklist’


Emergency Management & Fire Engineering

Emergency Management Plans

It is important that the emergency management plans of a building are reviewed and updated to comply with regulations and a building’s Pandemic Plan.

Suggested steps to take include:

  • Evaluate the effectiveness of your Emergency Management Plan and the compliance level of your evacuation drills and Emergency Control Organisation (ECO) training with the current situation
  • Ensure a sufficient number of wardens are in place in your workplace and that they have been trained recently as a team to respond to an emergency
  • Ascertain if the wardens are trained to deal with multiple or simultaneous emergencies and, if so, whether these have been practised
  • Identify any gaps in your plan where emergency management practices must be revised to cater for COVID-19 restrictions and relaxations
  • Ensuring the facility systems are ready and that social distancing requirements are met for anyone working or visiting a workplace
  • Consider how the return to work can occur in stages and will be affected by the types of business undertaken at the site and the ability of staff to return with restrictions on public transport
  • Determine the most suitable method to continue Warden training (such as face to face or web-based) to maintain skills of all wardens and ensure that there are sufficient trained Wardens on site
  • Reviewing the effectiveness of the implementation program and making any necessary adjustments

Bonus Resource: Download Greencap’s ‘Return to Work Analysis Checklist’


Safe Access (Fire Stairs)

Given the difficulties in maintaining appropriate physical distancing within lifts, building managers may be tempted to consider the utilisation of fire isolated stairways as a means of facilitating the movement of occupants within a building. Whilst there are no laws prohibiting the use of fire stairs for general access, it must be recognised that fire stairs are not necessarily as safe as general access stairways, due to the numerous concessions in the design granted by the building codes.

The use of fire isolated stairways also introduces new risks to a building, such as the increased potential for fire doors to be held in the open position, thereby impairing the building’s smoke management systems and stairway pressurisation systems. Assessing the condition and feasibility of fire stairs as an additional mode of moving people on a day-to-day basis is essential to ensure that one risk is not being created in order to mitigate another.


Case Study: Fire Stairs as General Access

The facility manager for a six-storey educational building in the Sydney CDB approached Greencap with the following scenario:

  • The building was populated by occupants sharing numerous classrooms and other common areas, with class schedules resulting in regular turnover of occupants over the course of a day
  • The operator of the educational facility sought to address the issue of physical distancing within lifts by utilising the fire stair for access
  • The operator requested the site facility manager to allow the fire stair final discharge door at Ground Level (at the rear of the property) to be left open over the course of the day to allow students, teachers and visitors to utilise the stair for general access

Greencap’s advice to the facility manager was:

There is no statutory impediment in NSW to the utilisation of fire stairs for general building access, however:

  • The fire stair final discharge door may be a fire resistant doorset (depending on proximity to the site boundary) and may be required to remain in the normally closed position on this basis
  • The open door presented a clear security risk, as it provided access to all levels of the building from the stair
  • Whilst the stair was not provided with a pressurisation system, there remained the potential for the smoke logging of the stair and propagation of smoke through the building in a fire scenario via internal fire stair doors being (potentially) illegally wedged in the open position
  • The stairway met the minimum requirements of the building code for a fire stair rather than a general access stair, thus it lacked safety features such as balustrades with small openings, and handrails/colour-contrasting nosings/tactile ground surface indicators to support access by persons with visual impairment

It was recommended that prior to the use of the fire stair in this manner, a risk assessment should be carried out taking into consideration the aforementioned factors.


Heating, Ventilation & Air Conditioning (HVAC) and Indoor Environmental Quality

A primary concern in the maintenance for the indoor environmental conditions for a building is Heating, Ventilation and Air Conditioning (HVAC). Many HVAC systems run in a pre-set automatic mode that are generally designed to operate under normal building conditions such as having occupants within the building, operation of lights and electrical equipment, and vehicles using the buildings car park – all of which produce heat. When this “normal” state is altered, the building’s management system is not always smart enough to compensate for change which in turn can affect how the HVAC system conditions the indoor environment within the building.

Preparing and adjusting building HVAC settings will help minimise issues during a shutdown and as the building slowly reoccupies to normal levels.

The role of aerosol and respiratory droplet transmission of COVID-19 is now more accurately understood, and as such ventilation forms an important component in the appropriate management of COVID-19 risk for densely occupied buildings and workplaces. Maintaining social distancing and limiting building occupation is best augmented by increased ventilation, with higher fresh air provision and an increase in the number of air changes per hour. Understanding the air flow dynamics, mixing efficiency and workplace layout is critical to ensuring that any changes to your HVAC system are appropriate and effective in minimising the residence time of infectious particles in indoor air.

As part of physical distancing measures, many businesses are reconfiguring office layouts for a reduced occupancy rate, inclusive of moving or reorientating workspaces. Consideration of impacts to worker thermal comfort and indoor environmental quality should be made when planning changes to workplace layouts. For instance, the location and number of ventilation supply diffusers may require revision to accommodate changes to desk locations and office configurations.

One mechanism to address the potential risk of airborne COVID-19 transmission within workplaces is to conduct Indoor Environmental Quality (IEQ) and Indoor Air Quality (IAQ) assessments. These can be used to assess the adequacy of ventilation in the context of COVID-19, or address worker thermal comfort complaints where the ventilation configuration is no longer appropriate for amended workplace layout, for example following implementation of physical distancing controls.


Legionella Risk & Water Systems

Another significant risk during a building shutdown and reoccupation is the increased risk of Legionella growth in water systems such as cooling towers, fountains, and water features. The growth of the Legionella bacteria significantly increases in stagnant water as the residual biocide levels and chlorines will dissipate over time.

Maintenance of these water systems is paramount in a building to reduce the potential unsafe exposure for tenants and the public to Legionella during any form of limited building occupation, and as these systems are cycled back to full use.

Regular maintenance and inspections of these systems, plus additional chemical dosing and works may be required to manage these systems and reduce the risk of Legionella growth during periods of low use.


Case Study: Legionella in Building Cooling Water Systems

Greencap was asked to independently investigate a high Legionella count incurred in multiple cooling water systems (CWS) for a client in response to a notice received by NSW Health. The objective of this investigation was to understand and identify all contributing factors which may have led to Legionella counts at a level greater than allowable limits stated in the NSW Public Health Regulation 2012.


A root cause analysis indicated systemic issues arising from dosing equipment malfunction and chemical fluctuations throughout the review period. Chemical treatment of waters varied greatly and was, at times, inadequate for the review period. Additionally, all actions and improvement notices for the review period were deemed reactive rather than proactive, and actions relating to issues raised in previous Risk Management Plans (RMP) were found to be incomplete.

These factors, along with Sydney’s weather conditions during that period which may have brought in large amounts of ash and dust into the system, may have increased the burden on the CWS operation, resulting in escalated levels of Legionella. High organic load in combination with inadequate primary oxidising biocide dosage would have overwhelmed the secondary biocide and reduced the effectiveness of the water treatment program.

A remote monitoring system was not installed at the time of the review to provide real-time information regarding possible issues with microbial control program or faults.

Greencap’s recommendations included:

  • Maintain the CWS on a regular basis, even during shutdown periods
  • A continuous review and monitoring program can mitigate the risk of Legionella counts within a CWS
  • Install remote monitoring to provide real-time information regarding possible issues with microbial control programs which can be used to actively monitor and track chemical treatment of systems
  • Data relayed by the remote monitoring system should be monitored and actioned where required
  • Any trends observed through the collected data is actively investigated to mitigate further risks
  • Ensure actions arising from Risk Management Plan Assessments are reviewed in a timely manner and corrective actions are implemented and closed satisfactorily


Further Guidance

This Risk Review is illustrative of just some of the key elements of risk relating to building shutdowns, changes in occupancy levels, and other forced variations in the normal ongoing operations. The planned management of these elements is essential in maintaining the integrity of assets and complying with mandatory requirements for the provision of a safe workplace and the protection of the public and environment. Failure to do so can result in significant health & safety, commercial and reputational damage.

A document produced by the American Industrial Hygiene Association (AIHA) titled ‘Recovering from COVID-19 Building Closures – Guidance Document’ is a clear guide on some of the potential impacts that may need to be addressed when closing or reopening a building. While this is a document produced by an American organisation, the risks do not vary between countries and the guidance material is as applicable in Australia as it is in the United States of America.


How Greencap Can Assist

Indoor Environmental Quality (IEQ) Assessments

Using specialised instrumentation, Greencap’s indoor environmental professionals evaluate a broad range of air quality parameters in the building environment, including:

  • Indoor air quality, including assessment of common gases such as O2, CO2 and CO as well as trace/specific gases based on the use of a specific building
  • Assessment of ventilation provisions (considering air change rates and fresh air provisions in the context of COVID-19)
  • Consideration of thermal comfort of occupants
  • Task-specific lighting adequacy checks
  • Ambient noise and acoustics
  • Ergonomic assessments


COVIDSafe Risk Assessments & Assurance Plans

Greencap has worked closely with clients throughout the pandemic to assess the adequacy of COVIDSafe Plans and assurance framework controls being implemented and provide specialist advice in clear and concise language.

Services include:

  • Independent onsite and/or desktop reviews and gap analyses of COVIDSafe assurance frameworks and controls
  • Review of cleaning and disinfection methodologies and products
  • Verification of physical distancing and isolation measures and controls
  • Consideration of ventilation provisions and occupancy rates
  • Review of worker awareness communications, posters and signage
  • Assessment of personal hygiene provisions onsite
  • Gap analysis and auditing of response protocols in the instance of a confirmed case in the workplace
  • Urgent responses to assess and rectify workplace COVIDSafe provisions following confirmed cases or exposures


Contractor Management

Greencap provides Contractor Management services to ensure consistent frameworks are in place for Procurement, pre-qualification, onboarding and monitoring and review of contractors. In the context of COVID-19, this has been particularly invaluable for Greencap clients when assessing cleaning contractors. Greencap’s services include:


Water Systems

Greencap has a team of water risk management consultants with qualifications and certifications, ensuring our clients receive tailored advice and solutions including:

  • Development of tailored Risk Assessments and Risk Management Plans (RMP)
  • Cooling Water System RMP Independent Audits
  • Risk assessments to ensure compliance in water delivery systems
  • Microbiological testing and corrosion monitoring program management
  • Root cause analysis following adverse results or system failure


Pandemic Plan Development

A Pandemic Safety Plan is a document which sets out the processes and procedures implemented by a business to effectively control risks, including infectious diseases such as COVID-19 to an acceptable level and ensure the provision of a healthy and safe work environment for employees and other persons such as visitors and customers.

Greencap can assist with development of your Pandemic Safety Plan, and provide guidance, gap analysis and reviews of existing systems and processes in the context of COVID-19, particularly with regards to returning to, and maintaining, business operations in a pandemic environment.


Review of Cleaning and Disinfection Methodology

Appropriate cleaning and disinfection protocols form a critical part of robust COVIDSafe site management, particularly for high-touch and high-use areas within buildings (such as lobbies, end-of-trip facilities, kitchens, bathrooms and lifts).

Greencap’s team of infection control professionals and occupational hygienists are able to provide:

  • Detailed and site-specific reviews of proposed cleaning and disinfection methodologies and procedures, both as part of pre-qualification of third-party cleaning contractors, and to confirm the adequacy of in-house cleaning protocols
  • Onsite verification and observation of the implementation of cleaning and disinfection processes
  • Verification of the level of compliance of cleaning and disinfection activities against approved methodologies and with any relevant DHHS requirements
  • Rapid site response in the event of confirmed COVID cases, to provide guidance around extent, scope and methodology for ‘deep clean’ activities


Emergency Management Plans & Procedures

There are several considerations for a business to ensure their compliance with AS3745:2010 in light of alternative and adapted working and staffing arrangements that have become essential since the onset of the pandemic.

Greencap’s specialised Emergency Management  division, TrimEVAC, have provided clients with the development and implementation of emergency management plans, procedures, evacuation diagrams and training since 1987.


Warden Training

AS3745:2010 states Emergency Control Organisation (ECO) members, including nominated deputies, shall attend a skills retention activity at intervals not greater than 6 months, to remain compliant.

TrimEVAC has been working with clients to ensure that compliance and warden training re maintained during the pandemic, via web-based training for ECO members delivered live by an Emergency Management Consultant.



Greencap acknowledges the Traditional Owners of Country throughout Australia and recognises their continuing connection to land, waters and culture.  We pay our respects to their Elders past, present and emerging.