Accountants should be aware that under Alert Level 4, they are allowed to operate their practices and should do so from home offices as far as possible. Each firm will have to implement a Covid-19 workplace risk plan detailing how you will protect your staff from infection. Travel is allowed should it be necessary to perform work for clients that are themselves allowed to operate. A special permit is required to travel that should be issued by the practice owner.
Accountants that implement payroll systems can still register as an essential service insofar as they are necessary to implement the payroll system for a client performing an essential service such as health or food.
You can access more detail from the SA Institute of Business Accountants (Saiba) guides and resources page, which provides clarity under what conditions accountants can continue to operate.
It is also essential that accountants understand the conditions applicable under Alert Level 4 to business in general, and their clients in particular. Government has published the Occupational Health and Safety (OHS) regulations and requirements applicable to employers who may commence operations under Level 4 lockdown on 1 May, 2020. The National Employers Association of SA (Neasa) has issued the following guide.
There may be insufficient time available for employers to prepare for the resumption of operations on 1 May. This is a list of minimum requirements that employers will have to comply with as a basis for the proposed measures likely to be effected by government.
Normal occupational health and safety requirements still apply, in addition to the following specific requirements relating to Alert Level 4:
Personal hygiene policy
- all employees should regularly wash their hands with soap and water for a minimum of 20 seconds;
- no handshakes or other physical contact is allowed between employees or employees and visitors/clients;
- employees should sanitise their hands regularly with alcohol-based hand sanitiser, with an alcohol content of at least 70%, after contact with any person or after contact with frequently touched surfaces;
- employees must cough into the fold of their elbow or in a tissue which must be discarded in a waste bin afterwards, and then wash their hands immediately afterwards as set out above; and
- employees must avoid touching their eyes, nose, and mouth.
Personal protective equipment (PPE)
The employer will be compelled to introduce a COVID-19 PPE policy in respect of all employees and visitors to the workplace and to provide PPE, as to be determined by the regulations. We propose, in preparation, to introduce the following PPE measures in the workplace:
- the issuing of masks to all employees and all employees must wear these masks;
- the employer may not allow any visitor to enter the workplace without the proper PPE as per the regulations and/or the employers’ policy;
- the employer should inform all visitors that they are to provide their own PPE in order to enter the workplace, alternatively, issue all visitors with the required PPE;
- the employer should train employees on the correct use, necessary hygiene practices and proper disposal of PPE in order to avoid cross-contamination from PPE to the user’s hands or clothes;
- supervisors should monitor and enforce wearing, sanitising and disposal of the appropriate PPE; and
- the employer should perform non-invasive temperature testing of all employees and visitors upon entering the premises.
Social distancing measures
It is widely expected that the regulations will enforce social distancing measures in the workplace, as social distancing is one of the main strategies in preventing the spread of the virus.
Employers will likely be expected to implement the following measures:
- employees must practice social distancing of at least 1.5 meters away from any other person in all circumstances;
- the employer should introduce staggered tea and lunch breaks to avoid a gathering of people and should also enforce social distancing protocols during these breaks;
- the employer should adopt and enforce a policy to avoid face to face meetings and, where possible, conduct meetings via electronic platforms (such as Skype, Zoom or Microsoft Teams);
- the employer should, where possible, adopt a work from home policy, particularly in respect of vulnerable employees;
- the use of paper towels on door handles, handrails and other commonly touched surfaces should be enforced;
- the employer should implement measures for the regular cleaning of the office and commonly touched areas; and
- the employer should introduce rules confining employees to their workstation, as far as practically possible.
The employer must enforce a strict ‘no travel for business purposes policy’, subject to the exceptions as per the regulations, i.e. cargo that may be moved across provincial borders.
Policies and procedures to be implemented in the event of a COVID-19 outbreak in the workplace:
- the employer must develop a policy and protocol which is to be implemented when a case of COVID-19 infection has been detected in the workplace. It is not yet clear what this protocol will contain as the Government has not yet provided guidance on this issue;
- the employer should train employees on their responsibilities and the relevant procedures in terms of the protocol;
- employers should utilise a checklist to ensure compliance with all the OHS requirements. A checklist will be provided as part of a toolkit that NEASA will circulate to members once the final regulations are available.
It is strongly advised that a dedicated manager should be identified to monitor and enforce compliance with all of the above.