Does your business comply with Level 2 regulations?


Businesses and services need to meet public health requirements under the COVID-19 Public Health Response (Alert Level 2) Order 2020 which has been brought in by the Government to set out what you need to do to prevent the spread of COVID-19, WorkSafe reports

Moving to Alert Level 2 brings many more PCBUs (persons conducting a business or undertaking – businesses, not-for-profits and other organisations) back to work.

Those PCBUs resuming work for the first time need to think about how to work differently to minimise the risk of COVID-19 transmission.

For those PCBUs who are already operating, now is a good time to revisit the approach you already have in place.

The Ministry of Health sets the requirements for managing the risk of COVID-19 transmission. It’s identified the controls you need to use to minimise the risk for your workers, volunteers, and other people affected by the work, like customers.

The key controls for work and workplaces are to:

  • keep people with COVID-19 symptoms off the premises
  • maintain physical distancing
  • enable good hygiene practices
  • keep track of people who enter the premises.

As you’re thinking about what working at Alert Level 2 means for how you operate, you need to consider how you’ll implement these infection controls. Remember that you must continue to meet HSWA requirements as well as COVID-19 public health requirements.

More information about the controls is available on the Ministry of Health website.

What should I be thinking about?

We’ve identified seven key areas all PCBUs should think about when planning their approach to Alert Level 2. They’re based on the same seven questions we asked PCBUs to think about when moving to Alert Level 3. At Alert Level 2 there are fewer restrictions on operations so the risks of COVID-19 transmission need to be reviewed.

We also have guidance for specific industries in our COVID-19 section.

Your industry may have prepared guidance to help you operate safely under COVID-19 restrictions – check with your industry organisation. Some industry guidance is available on our endorsed industry guidance page.

It’s important that you discuss your approach to operating safely at Alert Level 2 with your workers and their representatives. We recommend you talk with workers about which controls you’ll use at this level and how this may differ from what you did at Alert Level 3. This means your workers will understand how you intend to manage work safely and what they need to do to help. Think about what processes you might put in place to update and implement suggestions from workers and their representatives.

We also recommend you document your Alert Level 2 approach so it can be shared with others, including customers or clients. This will also make it easier to regularly review and update your approach. You may like to use our temple to document your thinking.

Note: the questions and prompts are general and apply for all businesses. You may also need to consider other things depending on your circumstances and the nature of your business.

How will you manage the risks of restarting part or all of your operations at Alert Level 2?

The extent to which PCBUs resumed normal operations at Alert Level 3 will have varied greatly depending on the nature of the work. Whatever your circumstances, moving to Alert Level 2 means you need to think about the risks of operating in new ways. This may include having some or all of your workers back at the premises, or travelling between sites, or working with equipment and machinery that’s not been used for weeks.

Key things to consider include:

  • Will you have the right people with the right skills to operate safely? This could be affected by having some workers unavailable to work or needing to use different team rostering arrangements.
  • Will you need to clean or ensure appropriate hygiene arrangements before occupying work spaces?
  • Will there be maintenance required for machinery and tools that haven’t been used for weeks? For example, vehicles’ warrants of fitness may have expired, or equipment may require a new compliance certificate or servicing.
  • When did you last have your ventilation system or air-conditioning checked? Are you confident that it is working efficiently? Now is a good time to schedule cleaning and maintenance.
  • What else needs to be done at work before you can safely restart all or part of your operations?

You might not identify anything that needs to be addressed, but it’s important your workers can see that you’ve thought this through. Talk about it with them – they may think of something you’ve overlooked.

How will you ensure all workers are able to keep themselves safe from exposure to COVID-19?

You need to make sure your workers (including volunteers) have access to the right information about keeping themselves well during Alert Level 2. This will mean they’re able to maintain good work and hygiene practices. Don’t assume your workers will just know how to do this. Make sure they have, or know where to get, official information.

Provide your workers with guidance on keeping well while travelling between home and work. Some PCBUs may choose to make travel arrangements to support their workers to stay well.

You may also like to consider:

  • providing information sheets and posters
  • discussing physical distancing and hygiene in team meetings (keeping in mind the need to continue physical distancing)
  • using virtual meeting technology
  • reviewing WorkSafe and Ministry of Health guidance regularly and updating your internal advice as needed
  • refreshing information regularly to keep safe practices front of mind.

Your workers will be able to suggest effective ways to share information with them. This is particularly important if you have workers for whom English isn’t their first language.

How will you gather information on your workers’ wellness to ensure they are safe and well to work?

At Alert Level 2 you still need to be vigilant about the possibility of COVID-19 transmission at work. You continue to need to ensure workers who are unwell or suffering symptoms consistent with COVID-19 don’t come into contact with other workers or customers/clients. If workers have COVID-like symptoms, they shouldn’t come back to work until they have either recovered or have been tested and cleared from having COVID-19 and are no longer symptomatic.

The symptoms are:

  • a new or worsening cough
  • a high temperature (at least 38°C)
  • shortness of breath
  • sore throat
  • sneezing and runny nose
  • temporary loss of smell.

Workers who have been diagnosed with COVID-19 are able to return to work, without risk to others, when they’ve been cleared from isolation. The criteria for being released from isolation depends on the circumstances, such as whether the person’s been hospitalised. In all cases a health professional or health team assesses whether someone can be released from isolation, and so return to work safely.

There are a range of reasons why workers may come to work despite being told they should stay home if unwell. This won’t necessarily be wilful behaviour. It’s important to have open communication with workers to understand why they want to be at work.

Check in regularly with workers to ensure they’re well. You could supplement this with a system that provides a self-symptom check for workers and other people before they enter the workplace. Your system needs to ensure that other people who don’t routinely work there are also screened.

The frequency of checking will vary depending upon the nature of your work, and what you and your worker representatives decide will be most effective. We recommend daily checks where possible. It is essential you involve workers and their representatives in deciding your system. Some PCBUs may choose to do more extensive checking, in agreement with their workers. Privacy requirements will apply to these records.

You may also like to consider:

  • setting up flexible leave arrangements to ensure workers stay at home and are not financially pressured to come to work when they have a respiratory infection
  • how you’ll follow up to ensure workers only return if they have recovered or they have been tested and cleared of COVID-19.

How will you operate your business in a way that keeps workers and other people safe from exposure to COVID-19?

At Alert Level 2 PCBUs should continue to manage the risks of COVID-19 transmission at work by:

  • keeping people with COVID-19 symptoms off the premises
  • maintaining physical distancing
  • enabling good hygiene practices
  • keeping track of people who enter the premises.

If you are using hand sanitisers as part of your good hygiene practices make sure you read and adhere to the safety information on the labels. It’s best to use soap and water when possible.

The government is encouraging all PCBUs to use alternative ways of working if possible. Premises can open for workers, clients and customers. Services can also be provided on customers’ premises (e.g. in homes). For many people this will mean going back to work at their workplace.

In most work situations personal protective equipment (PPE) isn’t recommended, other than what’s routinely required for the work. If workers are worried about working without PPE, it is important you engage with them and their representatives about the underlying reasons for their concerns. Discuss which controls you’ve chosen and why.

At Alert Level 2 the government is encouraging people if alternative ways of working. You must continue to ensure that workers who are working remotely can do so safely.

You may also like to consider:

  • how you will maintain appropriate separation between workers, and between workers and customers or groups of customers. The separation distance needed will depend on the nature of your work, and the control you have over hygiene and cleaning controls, and the ability to keep contact records. See our guidance on physical distancing for details
  • what processes you’ll implement to ensure public health requirements on hygiene and cleaning are followed
  • how you’ll inform and, if needed, train your workers on new processes
  • when, if at all, PPE will be used and why. If PPE is to be used, consider how workers will be trained to use it correctly
  • how you’ll make sure you have ongoing supplies of essential cleaning and hygiene products
  • how you’ll work with other PCBUs to make sure appropriate practices are followed by both your workers and theirs. (This helps you meet HSWA overlapping duties.)
  • whether you’ll implement revolving breaks or common protocols to ensure 1 metre physical distance in the office, at team meetings, and at other shared facilities
  • how you’ll collaborate with other PCBUs in your building on managing shared spaces like stairwells, lifts, and foyers
  • whether you’ll make transport arrangements for workers travelling to and from work, to make their commute easier, to reduce the risk of exposure to COVID-19, and to respond to any limited capacity on public transport due to physical distancing requirements.

It’ll take time for people to get used to the new processes, so don’t expect to meet pre-COVID-19 delivery targets immediately.

Changing work practices can bring new risks and impacts on existing risks at a time when your workers may already be stressed due to the restrictions of COVID-19 requirements on them and their families. You must engage with workers and worker representatives to minimise new risks created by the changes you implement.

How will you check to see if your work processes and risk controls are effective?

Continuing or resuming operations under Alert Level 2 will still require different ways of working, and things may not always go to plan. You and your workers will need to be prepared to learn and adapt to find the best ways to maintain physical distancing, and good hygiene and cleaning practices.

To make sure you can learn and adapt quickly, engage with your workers to find ways for them to let you know about what’s working, what’s not, and how things could be improved. You need to have good processes in place, which encourage workers to engage in work health and safety matters. Ask your workers – don’t just assume they will tell you.

Many PCBUs will already have effective incident reporting approaches that can be adapted to assess how well their COVID-19 controls are working. If you don’t have an incident reporting approach, or your usual practices aren’t right for these circumstances, you’ll need a way to find out if your approach is working.

You might like to consider:

  • the best way to engage with workers and their representatives – ask them how they would like to engage on decisions and provide feedback, and remember it may not be possible for them to complete forms or attend meetings outside of work
  • scheduling regular times to review your COVID-19 controls and their effectiveness
  • how you’ll communicate changes to processes and make sure all workers know about the changes and are trained to implement them
  • how you might use health and safety representatives to evaluate the COVID-19 controls’ implementation.

How do any changes impact on the risks of the work you do?

Changes to work procedures or practices may affect the way you’ve routinely managed the risks that arise from your work. For example, you may have controlled the risk of lifting heavy items by having two people involved, and now only one person is available to do the task.

It’s also possible the new procedures you put in place bring new risks or challenges you’ve not had to think about before. For example, if you are planning to introduce shift rotations, you’ll need to work out how to manage the associated risks.

How will you manage an exposure or suspected exposure to COVID-19?

Despite all your best efforts, it’s possible a worker or other person at work may start to show symptoms consistent with COVID-19. This could happen either while they are at work or after they interacted with you or your workers.

There will be a time delay between symptoms developing, testing, and getting test results. In most cases the person will not have COVID-19. Unless advised otherwise you can continue to operate. Follow advice from Healthline or the worker’s GP about when it’s safe for them to return to work.

You need to make sure that:

  • workers who are unwell with respiratory symptoms immediately go home, and call Healthline or their GP
  • workers with respiratory symptoms who have tested negative for COVID-19 are able to stay home until they’ve been symptom-free for 48 hours
  • if a worker has tested positive, and you are contacted by a public health unit, you can provide clear information regarding the worker’s contacts at work. Wait for public health to contact you. They will provide advice about any further actions you are required to take. Consider who at your workplace is best to liaise with the public health unit if they call
  • the work area of the unwell worker is disinfected in accordance with the cleaning procedures that you have implemented, in line with public health requirements.
  • you have information about who was in contact with the worker from when the worker is suspected to have contracted COVID-19, because this will assist with contact tracing
  • you have a system for keeping in contact with unwell workers and tracking their progress.

You need a process to identify people at work who have been in close proximity to someone suspected or confirmed as having COVID-19. The best way to do this is to keep a register of people entering or leaving the premises or work space.

The minimum information you’ll need is:

  • full name (not nickname)
  • contact telephone number
  • physical address.

You’ll need to make sure you keep this personal information safe.

You may also like to think about:

  • how you’ll make sure the register is being used and maintained correctly
  • how you’ll prevent customers from touching common surfaces, or using common equipment, in order to enter details
  • where the register will be located and who is best to enter the contact details
  • whether you divide your work space into zones and limit movement between the zones
  • how you’ll avoid people sharing office products like pens and paper whenever possible
  • how you’ll make sure workers are able to wash their hands regularly
  • whether you’ll supervise visitors who aren’t at your site regularly.


COVID-19 is primarily a public health matter. The Ministry of Health sets the requirements for preventing the disease’s spread. Businesses and organisations are expected to implement and maintain the infectious disease control measures it’s identified.

While COVID-19 is top of mind at the moment, businesses and organisations must continue to meet their obligations under HSWA.

WorkSafe will be actively checking that businesses and organisations are doing what is expected of them.