The possibility of death is an ever-present risk
By DAVE IRESON – Squash Mad Correspondent
We have seen a lot in various media outlets about “how” squash might return as a sport, based on the guidance that has been issued so far in terms of return to work of various sectors in England (or in other countries where squash is now a permissible activity and how these organisations are approaching their return to business).
The question that many clubs will be faced with is “How do we interpret this confusing and vastly varying guidance?”
The guidance provided is often vague or not specific, but this is often necessary to reflect that what an extremely large municipal sports facility could reasonably do to manage certain risks is very different to what a member-run two-court club could implement.
Perhaps a route into unpicking this vague (current or future) guidance and how to apply it could be to provide an understanding around UK HSE legislative principles, where all employers, owners or committees of member clubs need to demonstrate compliance; this is based on the ALARP principle and ensuring that a suitable and sufficient risk assessment is completed on return to business (the cited HSE publication gives a good overview of the ALARP principles, and what is and isn’t tolerable).
“ALARP” is short for “as low as reasonably practicable and at its core is the concept of “reasonably practicable”; this involves weighing a risk against the trouble, time and money needed to control it.
Thus, ALARP describes the level to which the HSE expect to see workplace risks controlled to. E.g. to spend £1m to prevent five staff suffering bruised knees is obviously grossly disproportionate; but to spend £1m to prevent a major explosion capable of killing 150 people is obviously proportionate.
It provides a good frame of reference to understand what a club could, should and must consider, and do, to reopen their facilities. Completion of a suitable and sufficient risk assessment must be a priority for any club as and when returning to some sort of business is considered possible.
This assessment must document the risks and the control measures that are “reasonably practicable” to be put in place to ensure they do not fall foul of failing to meet their Health and Safety obligations in the UK. [Often legislation does not travel well across borders – UK legislation is very different from legislation in the US – it is often difficult to use one to support the other.]
In terms of documenting the risk: COVID-19 is different (but similar in nature) to seasonal influenza (note – I am not for a second suggesting COVID-19 is not more serious; but is similar in nature). Four months ago, almost every squash player in the country accepted the risk that when they stepped onto a squash court they could contract a cold, or flu, or other virus from their fellow participants or members.
The most severe outcome of this is that it could result in a fatality to one of the members of the club who contracts this (the worse credible consequence). There is a mortality rate associated with seasonal flu and many thousands die each year as a result of contracting this virus.
Clubs probably normally do nothing to manage this risk at your club – you rely on government campaigns to support the management of this: “Catch it, kill it, bin it”, or campaigns to get the seasonal flu jab, along with the assumption that people practice reasonable hygiene is sufficient.
The reason it is important to understand this, is that it may seem that a fatality is something that you would never want to endorse – rightly so – but a discussion around incremental risk from COVID-19 must have this recognition at its heart – this is an ever present risk we encounter on a day to day basis.
The question that needs to be addressed is: “What has changed compared with four months ago and introduction of COVID-19?”. [It is worth pointing out, most people aren’t experts in epidemiology but if you are a club committee or employer you will be required to complete a risk assessment without a degree in the relevant subject]. It seems the most obvious difference between the normal operating risk of your facility is that the mortality rate is higher if you compare COVID-19 with seasonal flu.
This statistic is most relevant to the worst credible consequence so it feels the right measure to use. This will vary dependent on a number of factors (testing capability, health care capacity and quality, population demographic etc), but as a broad-brush number, it is a good place to start.
The information that was found through a search of the internet suggests that COVID-19 mortality may be 3-4%, whereas seasonal flu may be 0.1-0.2% , (yes sources may be unverified – we need to start the conversation somewhere).
The next question is “What does this mean in terms of the risk assessment?”. The increase in mortality rate is roughly one order of magnitude (factor of 10) higher when comparing COVID-19 with seasonal flu.
The objective of the risk assessment should be to put in place control measures to reduce the risk back down by roughly one order of magnitude (to get back to where you started with seasonal flu – which is an “accepted” risk under normal operations).
Control measures that you choose to implement should be reasonably practicable (i.e. must be aligned to the perceived benefit, or must be affordable in the context of running a squash club to be implemented, and meet industry “good practice”).
Examples of reasonably practicable control measures could be as follows:
– If there are normally 100 people in the building, reduce the number to 10 (this is probably achievable via some sort of court management approach)
– Reduce your “playing bubble” from 20 to 2 (nominated players you are only allowed to play with)
– Remove club activities so groups of 20 become a group of 2 (i.e. 1v1 play only)
– Implement an enhanced cleaning regime to minimise transmission potential
– Awareness campaign via email and posters etc to improve member hygiene behaviours and social distancing as far as possible
Once these risk reduction measures are in place you can demonstrate (to your staff, members and HSE) how your club is moving into the “tolerable” and then “broadly acceptable” region of the ALARP triangle. There is then a responsibility on you to implement a Plan > Do > Check > Act cycle to ensure that the processes and measures you have put in place are effective.
The risk assessment and control measures form the basis of the “plan” – the “do” is the implementation of the measures at your club, however it doesn’t end there. You have a responsibility to check that the measures are being implemented appropriately – the “check” phase.
And then follow up and “act” to correct any issues, and most importantly learn and improve what you are doing all the time to push the risk as far down the ALARP triangle as possible, while continuing to adhere to changes in government guidance or industry good practice.
Examples of measures which may not be practicable:
– Solo practice only – sounds sensible?!? – but your business is competitive squash – do you ever sell a “solo only” membership? Probably not…. This might not be a sensible re-opening measure even if it complies with social distancing advice because it does not permit your business to operate properly. It would be like a restaurant re-opening but ask members of the same group to sit at different tables – it doesn’t make sense
– Thermal imaging cameras at the door – again sounds like a good idea – but is the cost of implementation disproportionate to the benefit? Some thermal temperature sensing cameras cost thousands of pounds, which for most clubs would be unaffordable.
The HSE have been quite clear that they expect that a suitable and sufficient risk assessment is completed prior to re-opening of any businesses and good practice is that this risk assessment is shared with staff (and for squash clubs ideally members too). This is a key activity that clubs should start thinking about and documenting so that a club specific conversation can be held and debated, and a list of sensible measures developed. Hopefully, the information shared in this article provides a structure that will allow clubs to consider how they could complete a risk assessment and also implement reasonably practicable measures.
The key messages are:
– In the UK the risk assessment needs to be specific – generic guidance won’t work in the UK and should be avoided. Every club needs to complete an assessment to determine the measures appropriate to them and their individual circumstances.
– The measures need to meet ALARP principles (based on good practice, risk reduction measures and principle of gross disproportion) to demonstrate ALARP tolerability. If this can’t be demonstrated, the club should remain shut.
– This risk is ever present (i.e. it is not a new problem –COVID-19 has however moved the goalposts significantly). We need to establish how we (the squash community) manage this changed risk profile on a club by club basis
Finally, clubs should familiarise them with RIDDOR reporting guidance. If clubs open it is probable at some point someone will contract COVID-19 within one or more of our facilities. There is a requirement to report certain COVID-19 cases under RIDDOR regulations .