The Scottish Government published guidance for the college sector on 29 June 2020, which takes immediate effect.
It will be for each institution to work with its trade unions, staff and students to determine specific actions to apply the guidance in their own particular circumstances. At the present time Scotland remains in Phase 2 of its progression through the Scottish Government's Route Map out of the coronavirus crisis.
The guidance sets out a number of key principles which colleges are expected to consider when implementing the guidance. These include: the health, safety and wellbeing of students, staff, visitors, contractors and the wider community; ensuring there is the required flexibility in place to deliver a high quality experience which allows learning to take place safely; regularly reviewing the welfare and mental health needs of students and staff; introducing measures specifically designed to protect staff and students in specialised training facilities; engaging with staff and students, including trade unions and student associations.
Health and safety
The new guidance does not supersede existing health and safety legislation and universities should continue to abide by these obligations, including the legal duty on employers to conduct risk assessments and engage with health and safety committees. Where HSE identifies employers who are not complying with guidance to control public health risks, they will consider taking a range of actions to improve control of workplace risks including enforcement.
Risk assessments will underpin general protocols describing how people can access and use a college building. These will address questions regarding safely entering the building, moving around within it and using facilities such as offices, networked printers, canteens, toilets, etc. These will apply to everyone on the site and be drawn up by college management in consultation with relevant interested parties.
Public health measures
Physical distancing duties are set out in regulation 4(1) of the Health Protection (Coronavirus) (Restrictions) (Scotland) Regulations 2020. Colleges must take all reasonable measures to implement physical distancing (currently 2 metres) in all relevant areas. Colleges will take a risk-based approach and put in place measures to manage brief interactions within 2 metres which cannot reasonably be avoided, such as limited numbers of people passing each other in corridors. Where physical distancing cannot be followed in full in relation to a particular activity, colleges should consider whether that activity needs to continue, and, if so, take all the mitigating actions possible to reduce the risk of transmission. Possible mitigation actions include: the use of clear, appropriate signage across campuses; physical adjustments such as the use of perspex shields at reception points; one-way systems or other special controls on access to constrained spaces; shifts of employees being adjusted to minimise the numbers of staff on campus and in specific buildings at any one time. On-campus activity should be undertaken only when deemed safe to do so through appropriate risk assessment and when safety measures are in place.
Staff and students should practice hand and respiratory hygiene as summarised in COVID-19 guidance for non-healthcare settings. Commonly touched objects should be cleaned regularly, which means at least twice daily.
The guidance states that PPE should be used consistently with local policies and in line with measures justified by risk assessment. The guidance highlights the difference between face masks and face coverings – while face masks are not recommended outside healthcare settings, face coverings may be necessary in line with 'Coronavirus (COVID-19) Phase 2: staying safe and protecting others (physical distancing)' guidance.
Workforce planning and student support
The guidance highlights that communication with staff and students is crucial including clear and effective communication of the arrangements and policies in place, reminders of the symptoms to look for and clear advice on how to respond should symptoms become apparent while on college premises. Colleges should also make clear the channels of communication through which staff, students and trade unions can raise concerns about the implementation of safety measures in individual settings.
Colleges should support remote working, where possible and appropriate, and staff will begin to return to campus where government guidance allows for it and roles require it. Colleges must consider the guidance on transport and other guidance both in planning for staff and student travel to campuses and as transport providers themselves. Colleges should communicate public health guidance to staff and students on keeping public transport safe. This includes that wearing of face coverings on public transport is now mandatory.
College vehicles should be driven by the same person where possible in order to minimise the risk of infection. Where this is not possible – and subject to specific risk assessment - the vehicle should be disinfected after use.
All colleges should follow the latest guidance for students and staff who are shielding or who live with individuals who are shielding.
Colleges should support the Test and Protect strategy by following the guidance aimed at employers in helping staff who self-isolate. People must stay at home and self-isolate if they have symptoms, are waiting for a coronavirus test result, tested positive for coronavirus, or live with someone who has symptoms/ are waiting for a test result or has tested positive.
Consideration should be given as to whether any particular measures or adjustments are required to fulfil duties under the Equality Act 2010.
Progressing through the phases
Planning and preparation will require work to be carried out prior to any restart e.g. implementation of one-way systems and hygiene stations.
The guidance highlights that risk assessment and adoption of mitigation measures should not be a one-off exercise, rather part of a regular and ongoing consultation and feedback loop between employers and trade unions to identify what measures are working, where refinements are possible and any gaps remaining.
During Phase 2 of the Route Map, colleges may prepare for the new academic year. This can include preparing buildings and student accommodation. Based on risk assessments, a small number of people are able to access facilities to collect materials to allow them to continue to work from home. They will also be able to go onsite to prepare teaching materials, including digital content. Colleges may also wish to open some on-campus services such as small retail units and outdoor sports facilities. If they choose to re-open these services, universities will want to consider specific guidance for that sector.
In Phase 3, wider campus services such as training restaurants and eating areas, gym and sports facilities, hairdressers and beauty salons can open. Childcare services and indoor office spaces can also reopen. In doing so it will be necessary to consult and apply any updated guidance. Colleges should also consider how to ensure the safe resumption of face-to-face student support services.
For the commencement of teaching in the new academic year, colleges will need to consider current public health guidance and identify the appropriate blend of delivery, reflecting on what will maximise learning as well as supporting more vulnerable learners and teachers, and enabling management of risk.
In Phase 4, while remote and flexible working will remain, it is anticipated that college campuses will be fully open with any necessary precautions.