Work health and safety laws require a medical practice to ensure, so far as is reasonably practicable, the health and safety of workers and others at the practice. The COVID pandemic has presented a range of new health and safety risks for medical practices to manage.

The usual process applies to health and safety risks arising from COVID ‑ identify the hazards, conduct a risk assessment, consult with workers, determine measures to minimise or eliminate the risks and implement those measures.

The challenging part for practices is undertaking a risk assessment with constantly changing advice and novel measures to manage the risks (for example, face coverings and COVID vaccination). Risk assessment and management must be an ongoing process including when public health directions are no longer in place.

A properly performed risk assessment is a critical tool to manage work health and safety risks, and other risks (such as the risk of a discrimination claim). This guide provides an overview of the risk assessment process for medical practices.

What is a risk assessment?

A risk assessment allows you to identify:

• The risk associated with COVID
• The measure that could be implemented to minimise or eliminate the risks
• The measure that should be implemented to minimise or eliminate the risks

Risk assessment is an ongoing process.

Resources
Risk assessment | Safe Work Australia

Does a risk assessment need to be writing?

Yes, it should be in writing.

This will assist in your thinking and communication with your workers. It may also be required in response to a request from a work health and safety inspector or to assist in defending a legal claim such as a discrimination complaint.

Resources
Template and example COVID risk register | Safe Work Australia

How do I undertake a risk assessment?

Safe Work Austrtalia has provided the following guidance:
Risk assessment | Safe Work Australia
covid19.swa.gov.au/media-centre/assessing-and-managing-risks [short video]
How to manage work health and safety risks

What should the practice consider as part of the risk assessment?

Safe Work Australia has provided the following guidance:
Key considerations for undertaking a risk assessment - COVID

Examples of the matters to consider include:

• Advice from state and federal health departments
• Advice from the Australian Health Protection Principal Committee (AHPPC)
• Advice from work health and safety bodies such as Safe Work Australia
• Advice from relevant authorities about COVID exposure in the practice
• Public health directions - a practice is still obliged to undertake a risk assessment even if there is no longer a public health direction
• Advice from your college or other professional body
• The rate of community transmission
• The risk of transmission in your practice, having regard to the nature of the work performed in your practice
• The nature of the services your practice provides
• The consequences of your practice refusing access to the medical service
• The type of people who attend your practice and whether there is a heightened risk they will suffer severe disease (for example, people over 60 or people with pre-existing health conditions)
• The time people generally stay inside the medical practice when receiving medical services
• Whether it is possible to socially distance in the practice
• Availability of personal protective equipment (PPE) and face coverings and COVID vaccinations
• COVID vaccination status of workers
• Whether workers interact with a large number of people
• The other control measures that your practice has in place
• Where the practice is located (for example, in private hospital grounds)
• The worker demographic (for example, whether a worker also works in a respiratory clinic or in a COVID ward)
• How workers travel to work

What are possible risks in a health care practice?

Risk to your practice will be determined by all the above considerations.
Examples could be:

• Covid infection worker to patient/visitor
• Covid infection worker to worker
• Covid infection patient to patient
• Covid infection patient to worker
• Adverse effect from wearing PPE
• Adverse effect from sanitiser and cleaning substances
• Worker shortages for isolation or illness
• Worker serious illness
• Aggressive patients
• Delayed or missed diagnosis
• Worker complaints and disputes
• Worker resignations
• Workers travelling to work on public transport
• Working from home
• Fatigued workers
• Working in more than one clinic
• Communal areas shared with respiratory clinic worker
• Managing pop up clinics
• Sharing equipment
• Mental health
• Patient privacy
• Leave management
• Availability of COVID control measures

Resources
How to determine what is reasonably practicable to meet a health and safety duty | Safe Work Australia

How do I consult with workers?

Safe Work Australia has provided the following guidance:

Practical steps include:

• Have a practice meeting to discuss the risk assessment and what it means for worker
• Invite the team to review the risk assessment and give input about their concerns and possible alternatives
• Invite the team to speak to you about their concerns and individual circumstances
• Document the consultation process (for example, minutes of meeting, email to worker)
• Ensure that you consult with workers who work part time, work offsite or are on paid or unpaid leave.

Resources
How to determine what is reasonably practicable to meet a health and safety duty | Safe Work Australia

How should the practice document the measures it will adopt?

We recommend that practices update their COVID-Safe Plan as new measures are implemented to manage the risks associated with COVID, rather than having separate policies dealing with each issue.

Resources
National COVID Commission Advisory Borad - My Business's COVID Safe Plan
RACGP - COVID Safe Plan template

What measures should the practice implement to manage COVID risks?

This is a decision for you and your team.

Examples of things you may wish to consider as part of your risk assessment could include:

• Ensuring adequate room ventilation
• HEPA air filtration
• Personal protective equipment such as N95 masks
• Physical distancing
• Good hygiene
• Increased cleaning
• Additional training
• Perspex screens
• Removing items such as toys and magazines from waiting rooms
• Telehealth and video consultations
• Seeing patients in the car park or another area outside the practice
• Requirement for lunch breaks outside the practice
• Mandatory face masks for workers and patients
• Mandatory isolation for workers who are COVID positive
• Mandatory COVID vaccination for workers and patients
• Mandatory COVID testing for workers and patients
• Working from home
• Educate patients about health and safety measures
• Possible alternative measures for workers and patients who cannot comply due to disability
• Patients entering via a back entrance or being placed in an isolation room
• Disposable or single use pens and pencils
• A designated isolation area for suspected COVID positive patients
• Availability of hand sanitiser
• Remove pamphlets from waiting rooms
• Ongoing training and education for workers
• Allocated responsibility for COVID safety issues
• Minimising the number of people in the practice (for example, consider the need for support people to attend an appointment)
• Remove shared food items + single use plates and cutlery
• Triage patients when they arrive at the practice
• Appropriate signage to direct patients
• Ensure you have current contact details to communicate with workers out of hours
• Managing equipment that multiple people touch (for example, EFTPOS machine)
• COVID safety issues on each meeting agenda
• Access to EAP for workers.

Resources
How to Determine what is Reasonably Practicable to meet a Health and Safety Duty | Safe Work Australia

What should you do if a patient is unable or unwilling to comply with a health and safety requirement?

When performing the risk assessment, you should consider whether there are alternate measures that the practice could implement so a patient’s care is not compromised. Examples include:

• Patients entering via a back entrance
• An isolation room for patients who cannot comply with control measures
• Setting consultation times at the end of the day for a high-risk patient so the practice can prepare and clean
• Consulting with the patient in full PPE (including N95 or P2 masks)
• Referring to a partner practice or other facility
• Patients waiting outside for their appointments
• Offer a telehealth consultation.

What should you do if a worker is unable or unwilling to comply with a health and safety requirement?

When performing the risk assessment, you should consider whether there are alternate measures that the practice could implement if a worker cannot or will not comply with a measure. You should have regard to any medical reports the worker

Examples include:

• Alternate duties
• Working from home
• Wearing full PPE at work (including N95 or P2 masks)
• Taking leave
• Telehealth appointments

Disclaimer

IMPORTANT: This publication is not comprehensive and does not constitute legal or medical advice. You should seek legal or other professional advice before relying on any content, and practise proper clinical decision making with regard to the individual circumstances. Persons implementing any recommendations contained in this publication must exercise their own independent skill or judgement or seek appropriate professional advice relevant to their own particular practice. Compliance with any recommendations will not in any way guarantee discharge of the duty of care owed to patients and others coming into contact with the health professional or practice. Avant is not responsible to you or anyone else for any loss suffered in connection with the use of this information. Information is only current at the date initially published. © Avant Mutual Group Limited 2022 fact-142b 10/22 (DT-2808).