Meeting your Health and Safety obligations during COVID-19


Under the Health and Safety at Work Act 2015 (HSWA) agencies (as PCBUs) are required to take all reasonable steps to provide a safe working environment for workers. This includes:

  • Eliminating and managing the risk of the spread of Covid-19 (and other infectious disease) so far as reasonably practicable.
  • Managing other health and safety risks, including those linked to or amplified by the Covid-19 environment.
  • Supporting the wellbeing of staff through this period of uncertainty and change.
  • Consulting and coordinating with other PCBUs as part of their response.
  • Engaging with workers and their unions/representatives about health and safety issues and working to achieve a mutually acceptable outcome.

Agencies also have a role in helping New Zealand’s Covid-19 Immunisation Programme succeed, by encouraging and supporting workers to get vaccinated(external link).

Stay Informed and Communicate Regularly

Visit official websites regularly to keep up to date with current information, guidance and public health requirements. These can change at short notice as the situation changes, or with new information or scientific knowledge about Covid-19.

Ensure you also, keep managers and workers informed by maintaining up to date information and guidance on your own agency internal websites and through regular communications.

Prepare for change

Agencies should remain prepared and have documented plans in place for different scenarios that may occur, particularly those that are likely to result in changes to NZ’s alert levels noting these could be applied at a town, city, territorial local authority, regional or national level. 

The Covid-19 Public Health Response Order 2021(external link) sets the public health requirements for managing the risk of Covid-19 transmission. It identifies the controls needed to minimise the risk for your workers, volunteers, and other people affected by the work, including customers. 

Your agency may need to implement additional controls to keep workers safe, depending on the nature of the work they do and the environment they work in. Also consider the controls needed to manage any potential secondary risks created by Covid-19. 

Some Considerations

  • Are you regularly engaging with different groups of workers and their unions/representatives when planning for each scenario?
  • Are you considering how each scenario will impact your agency’s risk profile for other H&S risks (see “review other risks” section below)?
  • Do you know, and have you documented, what controls your agency will implement at each alert level (for covid-19 and other associated risks)?
  • Are you regularly engaging with contractors, suppliers and other relevant PCBUs?
  • Does your planning include how you will manage an exposure or suspected exposure to Covid-19, including a system to collect information to support contact tracing?
  • Are you communicating regularly with workers, volunteers and other people affected, including customers?
  • Are line managers trained, competent and prepared to give advice and support at each alert level and throughout transition?
  • Is your training for Health and Safety Representatives readily available and up to date?

Managing Transition Between Alert Levels

Agencies should ensure they manage the transition between alert levels, considering the impact this change will have on people, any (physical) changes that need to be made within your workplace, and any policy or procedural changes that may be required.  Te Kawa Mataaho, The Public Service Commission provides workforce guidelines to assist State services agencies to comply with public health and social measures being taken. 

In applying these guidelines, it is important that State services agencies take a consistent approach and model what is expected for the rest of New Zealand. 

Some Considerations

  • Ensure you are engaging with different groups of workers and their representatives when considering the impacts of each transition.
  • Consider how your people will be impacted by the changing alert levels and how you will support them through the transition period. Staff wellbeing should remain a priority alongside resuming or maintaining operations and agencies should support individuals who may require more time to adjust and feel safe with new requirements.
  • Provide clear communication and guidance to managers and workers. Ensure adequate training or induction is provided to support people to adjust to new ways of working and/or to ensure correct use of equipment or PPE.
  • Consider how each workspace is used and what physical changes to the workplace will be required to ensure physical distancing or other controls are able to be managed.
  • Update existing health and safety risks, policies, and procedures (including incident response, incident reporting and emergency management) to reflect changes.

Monitor, Check and Provide Assurance

Agencies should ensure they have processes in place to monitor and check controls during all alert levels. 

Some considerations

  • What controls do you have in place and how do you know that these are working?
  • Where may new areas of risk arise?
  • How you monitoring incidents and events and are you comfortable with how these are being reported and managed?
  • What assurance (reporting, data, evidence) are you able to provide to your executive teams to demonstrate that what they believe is happening is actually happening?
  • Are you meeting regularly with workers and their representatives to allow them to raise concerns and to provide feedback directly?

Review other Risks

The impacts of Covid-19 may impact your agency’s risk profile. As well as managing the risk of exposure to Covid-19, consider the potential secondary impacts of covid-19 and if the way you currently manage these risks may need to change.  Examples could include impacts on mental health, working from home, fatigue, and potentially increased aggressive behaviour towards frontline staff.