CV1 - Assessing Risk of COVID-19 in Aquatic Facilities
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CV1 - Managing the Risk of COVID-19 in Aquatic Facilities

Issue Date Effective Date Version
20/10/2021 15/11/2021 2.0

Purpose

To provide aquatic facilities and swim schools guidance on assessing the risk of COVID-19 cross infection within their workplace

Scope

This guideline applies to aquatic facilities who are considering the impacts of aquatic activities or events which are being conducted under Australian Governments COVID -19 Social Distancing advisories www.health.gov.au/covid19-resources.

Additional guidance on how to conduct a risk assessment, the types of inclusions that should be contained within a risk assessment as well as the importance of an integrated approach to managing risk within the broader management system is contained in the Guidelines for Safe Pool Operations: Risk Management section available at: https://www.royallifesaving.com.au/subscribers/GSPO

About COVID-19

Coronavirus disease (COVID-19) is an infectious disease that is caused by a newly discovered form of coronavirus.

COVID-19 is a respiratory infection that was unknown before the outbreak that started in Hubei Province, China, in December 2019. Other known forms of coronaviruses include Middle East Respiratory Syndrome (MERS) and Severe Acute Respiratory Syndrome (SARS).

Legal Framework

State and Territory Work Health and Safety (WHS) laws require you to take care of the health, safety and welfare of your workers, including yourself and other staff, contractors and volunteers, and others (clients, customers, visitors) at your workplace.

This includes:

  • providing and maintaining a work environment that is without risk to health and safety
  • providing adequate and accessible facilities for the welfare of workers to carry out their work, and
  • monitoring the health of workers and the conditions of the workplace for the purpose of preventing illness or injury.

Owners and operators of Aquatic Facilities should refer to the state/territory workplace health and safety authorities for specific advice on their legal advice.

Commonwealth
Australian Capital Territory
New South Wales
Northern Territory
Queensland
South Australia
Tasmania
  • Tasmanian Government - Coronavirus disease (COVID-19) Resources (under the heading 'Current Directions')
Victoria
Western Australia

National COVID-19 Safe Workplace Principles

Recognising COVID-19 pandemic is a public health emergency, that all actions in respect of COVID-19 should be founded in expert health advice and that the following principles operate subject to the measures agreed and implemented by governments through the National Cabinet process

  1. All workers, regardless of their occupation or how they are engaged, have the right to a healthy and safe working environment.
  2. The COVID-19 pandemic requires a uniquely focused approach to work health and safety (WHS) as it applies to businesses, workers and others in the workplace.
  3. To keep our workplaces healthy and safe, businesses must, in consultation with workers, and their representatives, assess the way they work to identify, understand and quantify risks and to implement and review control measures to address those risks.
  4. As COVID-19 restrictions are gradually relaxed, businesses, workers and other duty holders must work together to adapt and promote safe work practices, consistent with advice from health authorities, to ensure their workplaces are ready for the social distancing and exemplary hygiene measures that will be an important part of the transition.
  5. Businesses and workers must actively control against the transmission of COVID-19 while at work, consistent with the latest advice from the Australian Health Protection Principal Committee (AHPPC), including considering the application of a hierarchy of appropriate controls where relevant.
  6. Businesses and workers must prepare for the possibility that there will be cases of COVID-19 in the workplace and be ready to respond immediately, appropriately, effectively and efficiently, and consistent with advice from health authorities.
  7. Existing State and Territory jurisdiction over WHS compliance and enforcement remains critical. While acknowledging that individual variations across WHS laws mean approaches in different parts of the country may vary, to ensure business and worker confidence, a commitment to a consistent national approach is key. This includes a commitment to communicating what constitutes best practice in prevention, mitigation and response to the risks presented by COVID-19.
  8. Safe Work Australia (SWA), will provide a central hub of WHS guidance and tools that Australian workplaces can use to successfully form the basis of their management of health and safety risks posed by COVID-19.
  9. States and Territories ultimately have the role of providing advice, education, compliance and enforcement of WHS and will leverage the use of the SWA central hub in fulfilling their statutory functions.
  10. The work of the National COVID-19 Coordination Commission will complement the work of SWA, jurisdictions and health authorities to support industries more broadly to respond to the COVID-19 pandemic appropriately, effectively and safely.

Risk Assessment

The owner or operator of an aquatic facility should develop, implement, monitor and continually improve a risk management framework that includes the potential of someone being exposed to the infection of COVID-19.

The risk assessment should:

  • Identify the level of risk present in the local community
  • The assessment of the level of risk present in the community may depend on:
    • The number of active cases in the community
    • The number of “mystery cases” - that is, cases where the source of infection has not been linked to an existing case, and which may indicate that there are chains of transmission in the community which have not yet been identified by public health authorities
    • The level of vaccination across the community
    • Whether additional variants of concern are present in Australia’s quarantine system
  • Identify local State / Territory regulations and Public Health Orders
  • Identify all of the activities or situations where people in the workplace may contract COVID-19 from each other (either by droplet transmission or from a surface)
  • Assess the level of risk that people in these activities, areas or situations may contract and spread COVID-19 in the aquatic facility
  • When assessing the level of risk, aquatic facility owners and/or operators should give consideration to:
    • the likelihood of the hazard or risk concerned eventuating;
    • the degree of harm that would result if the hazard or risk eventuated;
    • what the person concerned knows, or ought reasonably to know, about the hazard or risk and any ways of eliminating or reducing the hazard or risk;
    • the availability and suitability of ways to eliminate or reduce the hazard or risk;
    • the cost of eliminating or reducing the hazard or risk.
  • Determine what control measures are reasonably practicable to eliminate or minimise the risk of exposure to COVID-19

The level of risk associated with exposure to COVID-19 may not be the same for all aquatic facilities and/or activities and/or zones within the facility. It will depend on a range of factors, including the community context, geographic location, business size, workforce demographics and characteristics (such as whether the business has any vulnerable workers), as well as:

  • the nature of the aquatic facility (for example, indoor or outdoor, noting that facilities which are predominantly outdoor will also have indoor spaces such as toilets and change rooms)
  • the work tasks and activities undertaken at the aquatic facility, for example is there significant interaction with customers, do any work tasks require workers to be in close proximity to be carried out safely
  • the working arrangements of the workers, such as roster bubbles and/or whether workers work across multiple workplaces
  • Whether the business engages with or provides services to persons who are vulnerable, in particular persons with disabilities, persons who are older, persons who are ineligible for COVID-19 vaccinations, persons with pre-existing medical conditions and Aboriginal and Torres Straight Islander people.

The risk management framework should be consistent with the AS/NZS ISO 31000:2018 Risk management- Principles and Guidelines, the Guidelines for Safe Pool Operations - Risk Management and any of their amendments.

Specific guidance on risk assessment as it pertains to COVID-19 can be found https://www.safeworkaustralia.gov.au/doc/key-considerations-undertaking-risk-assessment-covid-19

Specific Examples for a Risk Assessment is:
  • Checklist – Key considerations when undertaking a COVID-19 risk assessment
  • Template - Template and Example COVID-19 risk register
  • Workplace checklist - What can I do to keep my workers safe at the workplace and limit the spread of COVID19?
Non-aquatic Activity Risk Assessment

When identifying the activities or situations where people in the aquatic facility may contract COVID-19 from each other (either by droplet transmission or from a surface), the owner or operator of an aquatic facility should assess:

The aquatic activity risk assessment in relation to COVID-19 should consider at a minimum the following:

  • work tasks, workflows or processes carried out at the aquatic facility, such as using shared equipment
  • areas where workers may be in close proximity, such as in offices, behind the counter at a reception, café or retail store and/or shared areas such as break rooms or kitchens
  • interactions between workers, including when travelling to and from work (for example when carpooling) and when on a meal or rest break
  • interactions between workers and customers or other people who attend the aquatic facility, for example delivery drivers
  • interactions between visitors and customers at the workplace, for example people who are not part of the same household,
  • interactions of the kind referred to above which involve one or more of the 3Cs - confined spaces, crowded places, and close contact settings
  • high touch surfaces at the workplace which may become contaminated, such as door handles, drink fountains, taps or access control points such as turnstiles and fob swipe points

The operator should consider external issues when undertaking their risk assessment. These issues can include:

  • public health laws
  • rates of COVID-19 in the local community
  • how workers travel to and from work – where large numbers of workers have no other option but to use public transport businesses may need to:
    • clearly communicate ways they can minimise the risks associated with COVID-19 while on public transport and direct them to appropriate resources to help with this, or
    • put in place arrangements such as staggering start and finish times and/or session times to prevent large numbers of workers and/or patrons travelling at peak hour and arriving at the same time, causing congestion in common areas like foyers and changerooms
  • workers’ personal circumstances, such as whether they have been classified as a vulnerable worker, have caring responsibilities for a vulnerable person or there is a vulnerable person in their household
  • issues regarding access to childcare and schools in the community at the particular point in time and stage of restrictions currently active in the jurisdiction the business is located in – this may impact the business’s application of its working from home policy (if working from home is possible in the industry the business is operating in)
  • changes in customer expectations or behaviours
  • supply chain issues, including demand or availability of products/services, and
  • increased or decreased demand for products/services.

The owner or operator of an aquatic facility should consider internal elements of the aquatic facility’s operations as part of the risk assessment. These may include:

  • the size and nature of the workplace:
    • number and location of workplaces within the business
    • type of workplaces - for example whether they are an office, retail outlet, factory, warehouse, in-home servicer or other type of workplace
    • physical layout of the workplace in accommodating physical distancing measures (and in particular, the layout of shared facilities such as break rooms where workers who are otherwise able to physically distance may be required to come into close contact with other workers)
    • facilities available to manage the risks associated with COVID-19, such as adequate provision of handwashing facilities, and ventilation in confined spaces
  • the size and nature of the workforce, for example:
    • a high proportion of casual workers without access to paid leave
    • whether there are vulnerable workers who may be more likely to experience serious illness if they contract the virus
  • the nature and organisation of work tasks carried out at the workplace, for example:
    • whether the job roles involve significant interaction with other workers, customers/clients or other people
    • how work is organised for the duration of the pandemic including processes to manage any increased worker absences (due to sickness, self-isolation or quarantine requirements etc.) – where work tasks need to be performed by two or more workers to be done safely, consideration may need to be given to whether these tasks can be rescheduled if there is a reduced workforce due to circumstances related to the pandemic.
Aquatic Activity Risk Assessment

As part of an overall risk assessment the owner or operator of an aquatic facility should consider specific assessment for each of the activities that it does within its facilities. Owners and Operators of Aquatic Facilities should refer to the following GSPO SV4 Aquatic Activity Risk Assessment.

The aquatic activity risk assessment in relation to COVID-19 should consider at a minimum the following:

  • Physical distancing of parents to other parents/children/teacher/coach in the water
  • Physical distancing of children to other children/parents/teacher/coach in the water
  • Physical distancing of parents to other parents watching or teachers/coaches
  • Requirements to touch the child in order to assist them in their learning activities (i.e. assisting the child to float)
  • Safety requirements to physically support the student in their learning activities
  • Supervision requirements if student is unable to support themselves in the activities
  • Social practices of children in managing their own hygiene (i.e. wiping their nose in the water)
  • Physical distancing of other aquatic activities within the pool / area that may cause social distancing to be compromised
  • Sharing of teaching and pool equipment from one class to another or within the same class
  • Placement / Location of personal items and their vicinity to others (i.e. water bottles on the side of deck)
  • Additional supervision requirements in order to allow the social distancing to occur both in the water and out of the water
  • Air circulation and filtration in indoor spaces to determine the flow of air and to ensure appropriate management of air flows
  • Personal protective equipment

References