DOC COVID 19 Risk Assessment Third Review 30 March 2022 DOC 6966080.pdf

COVID-19 risk assessment review: transmission in the workplace

Description:
HIGH INFLUENCE AND CONTROL
Date:                   30/03/2022

Unless stated the control

Harm the
Level of
Are the controls
measures are effective
Inherent likelihood that the harm
Comments
Hazard
hazard could
inherent risk  Control measures currently in place
eliminating or
and fit for purpose so far
would occur1
cause
(consequence)
minimising the risk?
as is reasonably
practicable:
DOC workers
DOC workers
All of the work activities identified under
High
Workers are encouraged and supported to
Eliminating

Currently,
95.1%
of
the
NZ
becoming infected
or other visitors  this heading in the initial risk
stay home if showing symptoms or unwell.

population are fully vaccinated which

or transmitting
contracting
assessment required very frequent

means  many  people  may  not  have
COVID-19 from
COVID-19
contact with others which ranged

any  symptoms,  we  have  herd
vaccinated workers
(which could
between very frequent short duration
Localised controls are available to staff to
Eliminating
immunity  and  Omicron  is  currently

by exposure to
result in
(e.g. customers at reception/ visitor
close premises as required
the  dominant  variant.  Omicron  has

airborne
serious illness
centres, working from home) to


broken  through  the  vaccination
transmission
or death) and
moderate duration (visiting multiple

barrier.
Localised controls are available to staff to
opportunities/ close
in turn
sites, working in close contact with

reduce capacity in meeting rooms as required.
Minimising

contacts via direct
transmitting to
workers, visiting outdoor areas on

contact between
others.
conservation land, meeting other


International  borders  will  begin  to
people (e.g., from
agencies) and very frequent prolonged


open  as  from  12  April  to  Australian
Workers and visitors aged 12.3 years+ are
other vaccinated
(e.g. indoor large events where DOC is
tourists and this introduces the risk of
required to hold a My Vaccine Pass
Minimising
My Vaccine Pass is
workers who are
in control such as Te Pukenga
them
bringing
new
COVID-19
(vaccination only) unless exempt.

currently no longer effective
often
Atawhai). Workplace offices and some
variants and other seasonal illnesses

in light of high vaccination
asymptomatic)
indoor events have aircon, some have

rate, high immunity from
such  as  the  flu  and  the  super  cold
the ability to open windows and doors.
Minimising
which
Australia
has
recently

Cleaning and disinfecting in accordance with
the Omicron outbreak and
reported.3
The inherent likelihood that harm would
guidance from Ministry of Health (MoH).

given the features of

occur in performing these work

Omicron.

See initial risk
activities in a Delta environment ranged
Frequently touched surfaces regularly
Minimising
The MoH also advises that protection
assessment for the
between Almost Certain (a regular
cleaned.

against  infection  with  either  Delta  or
work activities
occurrence) – Likely (occurs often).
Omicron  decreases  over  time.  A


Following the first and second reviews
booster  dose  at  4  months  after  the
Minimising
of the risk assessment, there was no
Physical distancing – workers and visitors at
end  of  the  first  dose  will  improve

change to the inherent likelihood of
least 1m apart from each other.
protection
against
Omicron

harm nor consequence and therefore

particularly  for  protection  against
no change to the overall inherent risk

severe
disease
such
as
Posters on hand washing are prominent in the
ratings referred to in the risk
hospitalisation  although  does  not
serviced huts and hand washing facilities are
Minimising
assessment. The residual risk ratings
result  in  as  many  people  being
available in the bathrooms.
with controls and vaccination were

hospitalised.
determined to remain at medium and


Omicron can still cause severe illness
for unvaccinated at high.
Masks to be worn inside premises (‘Mask
Minimising
and  even  death  especially  in  people

when moving’(, inside vehicles (as per DOC
who are at risk of severe outcomes.

policies and guidance)

MoH  advice  is  that  getting  boosted

continues  to  be  one  of  the  most

1 NZ Vaccine data and statistics as at 30 March 2022: 96.3% of ages 12+ have had first doses, 95.1% of ages 12+ are fully vaccinated (3,972,660 people), 72.7% of ages 18+ have had a booster (2,578,129 people).  See https://www.health.govt.nz/news-media/news-items/15918-community-cases-817-
hospitalisations-24-icu-14-deaths
3 From 11:59pm 12 April 2022, vaccinated Australian citizens and permanent residents can enter NZ and self-test on arrival. From 11:59pm 1 May 2022, vaccinated people from countries who do not need a visa (visa waiver visitors) or visitors from other countries who already hold a valid visitor visa can enter
NZ and self-test on arrival. From July 2022, vaccinated travellers arriving under the Accredited Employer Work Visa categories can enter New Zealand and self-test on arrival. From October 2022, all visa categories will reopen including visitor and student visas.
COVID-19 Risk Assessment Review 3 – DOC 6966080
Page 1 of 8

Unless stated the control

Harm the
Are the controls
measures are effective
Inherent likelihood that the harm
Level of
Comments
Hazard
hazard could
Control measures currently in place
eliminating or
and fit for purpose so far
would occur1
inherent risk
cause
(consequence)
minimising the risk?
as is reasonably
practicable:
DOC vaccinated
DOC workers –
High
All DOC staff (unless exempt) in the
Eliminating/ Minimising
See above re My Vaccine

workers or visitors
in particular

workplace currently are vaccinated and

Pass.
becoming infected
vulnerable
required to hold a My Vaccine Pass

or transmitting
workers or

COVID-19 from
other



unvaccinated DOC
unvaccinated
Workers have been briefed on symptoms of

Eliminating

workers or
visitors
COVID-19 and have been told to stay home if
unvaccinated
contracting

they are showing symptoms or unwell.


visitors (by
COVID-19




exposure to
(which could
If workers are a close or household contact of
airborne
result in

a COVID-19 positive case, workers are
transmission
serious illness

Eliminating
required to stay home and isolate for 7 days.
opportunities/ close
or death) and


contacts via direct
in turn

contact between
transmitting to


Workers have been trained on appropriate
people (e.g., from
others.

measures to take
Minimising
others who are
infected)








Rapid Antigen Tests (RATs) will be supplied to
See initial risk
some staff that are working alone in a remote
assessment for the
Situations where staff are required to
Minimising
locations and access to RAT kits is difficult
work activities
undertake medical first aid and

providing direct physical assistance to
logistically.4
others also increases the risk of


infection and transmission (and harm).
If a worker becomes unwell at work, a process

is in place to isolate them and arrange for

them to be sent home to receive medical

attention. District teams have a completed
Business continuity planning which will
Minimising
provide direction on process to follow.



Workers don’t have contact with contractors5

or other DOC staff who undertake
Minimising
cleaning/servicing.



Where worker meetings are required, they are
held indoors / outdoors with 1m distancing and
masks are worn.
Minimising


Where possible, break times are staggered to

minimise the number of workers using break
Minimising
room at one time.



Other control measures as above for workers

(including masks, general cleaning, and
disinfecting).




4 http://intranet/about-DOC/covid-19-information-hub/rapid-antigen-tests-rats/
5 Contractors present a similar risk profile to that of DOC staff undertaking servicing or maintenance. Contractors are required to have an appropriate COVID-19 health and safety plan to manage the risks associated with COVID-19.
COVID-19 Risk Assessment Review 3 – DOC 6966080
Page 3 of 8

Description:
Requirements set by other organisations and authorities
Date:
30/03/2022

Harm the
Level of
Are the controls
Unless stated the control measures
Comments
Inherent likelihood that the harm
Hazard
hazard
inherent
Control measures currently in place
eliminating or
are effective and fit for purpose so
would occur
(See above)
could cause
risk
minimising the risk?
far as is reasonably practicable:
(consequence)
DOC
Workers or
Likelihood of infection occurring
T
his was
Masks
Eliminating

workers
other visitors
remains as Almost Certain given
previously

becoming
contracting
there is very high frequency of
assessed as
infected or
COVID-19
prolonged exposure and
extreme
Handwashing
Eliminating

transmitting
(which could
recirculated air whether people

COVID-19
result in
travel domestically (air, taxi, public
Hand sanitiser
by:
serious
transport) or travel internationally.

illness or

Exposure to

death) and in
Eliminating

airborne
Physical distancing – DOC workers
turn

transmission
and visitors at least 1m apart from each

transmitting
opportunities

other.
to others.

/

Close
Minimising

contacts via
Masks to be worn inside facilities.

direct

contact

Requirements when travelling per DOC
between
procedures
Minimising

people (e.g.,
from others

who are

infected)

See initial

risk
assessment

for the work

activities

COVID-19 Risk Assessment Review 3 – DOC 6966080
Page 5 of 8

Description:
Low influence and control: Non-DOC worksites and/or interactions with the public
Date:
30/03/2022

Are the controls
Unless stated the control
Comments
Harm the
Level of
Inherent likelihood that the harm
eliminating or
measures are effective and fit
Hazard
hazard could
inherent risk
Control measures currently in place
would occur
minimising the
for purpose so far as is
cause
(consequence)
risk?
reasonably practicable:
DOC workers
Workers or

Workers are encouraged and supported to
Eliminating

becoming
other visitors
stay home if showing symptoms.



infected or
contracting

transmitting
COVID-19

COVID-19 by:
(which could
Localised controls are available to staff to
Eliminating/
See above re My Vaccine Pass
result in serious
close premises as required
Exposure to
Minimising
illness or death)

airborne


and in turn
transmission
Localised controls are available to staff to

transmitting to

opportunities/
reduce capacity in meeting rooms as
others.

Close

required.

contacts via


direct contact
Minimising
between
Workers and visitors aged 12.3 years+ are


required to hold a My Vaccine Pass
people (e.g.,

(vaccination only) unless exempt.

from others
who are

Minimising
infected)

Cleaning and disinfecting in accordance with

guidance from Ministry of Health (MoH).6

See initial risk

Minimising
assessment
Frequently touched surfaces regularly

for the work
cleaned.
activities



Physical distancing – workers and visitors at
least 1m apart from each other. Localised

risk assessments are undertaken as

appropriate.

6 https://www.health.govt.nz/covid-19-novel-coronavirus/covid-19-health-advice-public/covid-19-general-cleaning-and-disinfection-advice last accessed 29 March 2022
COVID-19 Risk Assessment Review 3 – DOC 6966080
Page 6 of 8

Description:
Conclusions and Recommendations – draft not completed
Date:
30/03/2022

It is important to keep up to date with the pandemic and to adapt and as rules change.
The initial COVID-19 health and safety risk assessment for DOC workers (staff and volunteers) and workers was undertaken in a Delta environment at a time when many of the population were unvaccinated. Our initial focus and the then MoH
advice was on transmission of Delta which is highly transmissible and carries a risk of harm (severe disease such as hospitalisation, severe illness, and death).  The initial health and safety risk assessment was based on multiple layered control
measures which included following MoH guidelines, sanitising or washing hands regularly, where practical wearing a mask and physically distancing around others and staying home if unwell.  Relying on advice from MoH, the risk assessment
determined that vaccination against Delta also presented a higher level of protection as a control measure and significantly moved the profile of risk down in terms of likelihood of transmission and severity of consequence. Consequently, DOC’s
COVID-19 Vaccination Policy which came into effect on 16 December 2021 required all DOC workers (unless exempt) to be fully vaccinated and have proof of their vaccination status by way of the My Vaccine Pass. The control measures we
implemented have been effective and fit for purpose.
This review notes (as set out in the first and second reviews we have conducted) that since the risk assessment was conducted, Delta has been overtaken by the Omicron BA.2 sublineage in New Zealand and it is increasingly widespread in
New Zealand with the Omicron peak in Auckland recently with smaller waves expected. This means the COVID-19 risk profile has moved. Experts are advising that the emergence of Omicron, an even more highly transmissible COVID-19
variant means that a threat exists for both vaccinated and unvaccinated people; the MoH advises that people who are fully vaccinated have less protection against transmission of Omicron than for Delta, but that vaccination still offers some
protection. The MoH also advises that protection against infection with either Delta or Omicron decreases over time. A booster dose at 4 months after the end of the first dose will improve protection against Omicron particularly for protection
against severe disease such as hospitalisation although does not result in as many people being hospitalised. Omicron can still cause severe illness and even death especially in people who are at risk of severe outcomes. MoH advice is that
getting boosted continues to be one of the most important ways people can protect themselves from Omicron and severe illness. There is a much lower risk of being hospitalised if up to date with vaccinations which for Omicron includes a third
of booster dose if eligible. As community transmission of Omicron increases, it is less likely there will be a greater risk of COVID-19 in DOC visitor accommodation than there is in the community.
Some specialist medical and scientific experts including the MoH advise that New Zealanders need to plan for and expect further variants as the COVID-19 virus will continue to adapt to survive, and they warn us that Omicron is not to be
underestimated as the impact on the body or the impact of long COVID-19 is not fully understood.
Border controls have recently changed, and the Government no longer requires incoming vaccinated New Zealanders and other vaccinated travellers to self-isolate on entry to New Zealand. Australian tourists who are vaccinated will be able to
travel to New Zealand from 12 April 2022. These changes introduce an increased level of risk to New Zealanders as these people may be asymptomatic, but they bring with them the risk of seasonal illnesses including the super cold some
Australians are experiencing.
Changes have also been made to the way close and household contacts are managed by MoH under Omicron Phase 3 Red which increases the likelihood of an infectious people being in the community, and hence increasing transmission in
the community but significantly this also increases population or herd immunity.
The Government has recently announced that CVCs7 will no longer be a requirement at any traffic light setting after 4 April 2022 at 11:59pm. This is irrespective of what traffic light setting is in place past this date. The technology for My Vaccine
Passes will remain available (and is being updated to include boosters) but there will be no mandate requiring its use. The rationale for this change is that we have moved past the point where CVCs are most effective. This approach is being
taken by the Government in light of the high vaccination rate (currently 95.1% of eligible New Zealanders are vaccinated which means many people may not have symptoms at all but still be able to pass on the virus to others), there are high
levels of acquired immunity from the Omicron outbreak and given the features of Omicron. Omicron BA.2 breaks through the vaccination barrier. However, MoH advise that vaccination (including boosters) continues to be strongly recommended
as one of the key public health measures and it provides significant benefits. The Government has indicated that My Vaccine Passes could become mandatory again in the future if there are different variants or circumstances change.
DOC is still able to close its workplaces where there is a high risk that is not easily mitigated and is required to work with iwi, communities, and campsite managers to assess risk for specific sites and support them regarding restrictions or
closures needed for public safety.
We cannot predict the future with any certainty as to how the pandemic will unfold. We act on best, most up to date official information available, remain vigilant, keep the health and safety risk assessment under review and ourselves briefed on
most up to date health advice from the MoH.
Considering the matters referred to above and bearing in mind we are entering the winter season which usually means fewer people in our accommodation (some of which will be seasonally closed), this review supports retention of all existing
control measures in DOC accommodation that is open to the public and/or our workers except for the requirement to provide proof of vaccination status for entry. The rapidly changing nature of COVID-19 means we should retain the ability to
require My Vaccine Passes in the future.
Recommendations:
(1)  Unvaccinated workers and contractors to DOC workplaces no longer be required to provide proof of vaccination status with a My Vaccine Pass.
(2)  Retention of the current Vaccination Policy and the ability to use CVCs as part of health and safety. To this end, it is recommended that the Vaccination Policy be suspended as of 4 April 2022 at 11:59pm to coincide with the
Government’s rol  back of My Vaccine Passes.
(3)  Use of alternative controls, additional controls transitioning unvaccinated staff (and vaccinated who have been working off-site) into the workforce
(4)  Localised risk assessments re control measures relevant to each workplace
(5)  Continue to monitor official health advice and observe current health risk levels in the community.
(6)  Undertake the formal review of the risk assessment referred to in the Vaccination Policy as scheduled on 31 May 2022 (unless there is a need to undertake this sooner).
(7)

7 CVC means a COVID-19 vaccination certificate issued under clause 8 or 9 of the COVID-19 Public Health Response (COVID-19 Vaccination Certificate) Order 2021.
COVID-19 Risk Assessment Review 3 – DOC 6966080
Page 7 of 8

APPENDIX

COVID-19 Risk Assessment Review 3 – DOC 6966080
Page 8 of 8