Construction union Unite has sent an open letter to Mark Reynolds, the skills workstream lead of the Construction Leadership Council (CLC), warning that the organisation’s site operating procedures (SOP) are placing workers at risk.

Various versions

Since the COVID-19 pandemic began the various versions of the CLC’s operating procedures have acted as a template for safe site operation with the latest version of the SOP, (version 4) published last week. 

Unite is primarily concerned about the section which deals with Work Planning to Avoid Close Working which states: “If you are not able to work while maintaining a two metre distance, you should consider whether the activity should continue." It goes on to say "that management should minimise the frequency and time workers are within two metres of each other.”

Social distancing vital

Unite has called for site work to be planned in a way that allows social distancing to be maintained with appropriate protection for workers on the very rare occasions when this is not possible and working within two metres of each other cannot be avoided.

However, the SOP version four says: “Workplaces should not encourage the precautionary use of extra PPE to protect against Coronavirus (COVID-19).”  The union says that it will not support any guidance that could deny construction workers the appropriate PPE.  

PPE concerns

In the open letter (published in full below) to Mark Reynolds, Unite construction officer Jerry Swain states: “The SOP could and should be revised to explicitly state that the job should not be undertaken without appropriate PPE, which of course would include masks.”

 Unite also raises a similar concern about more than one person travelling together in a work vehicle and says that if two metre social distancing cannot be maintained then “workers should be supplied with an appropriate mask which must be worn”.

 CLC vital role

Commenting, Jerry Swain said: “Since the pandemic began, the CLC has become the go to place for construction sites trying to operate and keep workers safe.

 “It is essential that the information in the site operating procedures is clear, comprehensive and complete. As the procedures are currently written, the health of workers is placed at risk.

 “Unite has been constructive in the development of these procedures throughout and has fed its views into the CLC. It is imperative that the CLC ends the confusion and republishes revised procedures.

 “No one should be required to work within two metres of someone else on a construction site and on the extremely rare occasion when this is simply not possible then the full appropriate PPE must be issued. It is also essential  workers are fully trained in the safe usage of this equipment.

 "Our industry is under the spotlight; now is the time for the CLC to show leadership and do the right thing by workers. I truly hope, for the sake of our workers’ health and the battle against the spread of this virus that Unite receives a positive response from the CLC.”


Notes to editors:

 Open Letter

Dear Mr Reynolds

I am writing to you on behalf of Unite the union, in your capacity within the Construction Leadership Council (CLC), which is responsible for producing the Site Operating Procedure (SOP).

Unite have now had time to study the SOP version 4 that was recently published. In doing so we have sought observations from our well respected health and safety officer. Following this consideration please see below our comments, I will wherever possible use the SOP headings;


Whilst we of course accept that government guidance must at all times be followed, we would respectfully point out that they are not experts in construction and that the organisation responsible for workplace safety (HSE) do not appear to have had a great input into the advice issued by the government. It therefore follows that the CLC when issuing guidance have an obligation to ensure that it is complete and reflects ‘best practice’. It cannot be right for the industry Leadership Council to simply regurgitate minimum standards, surely the CLC’s role must be to lead.

We note in SOP introduction the following;

 “where the social distancing guidelines cannot be followed in full in relation to a particular activity, businesses should consider whether that activity needs to continue for the business to continue to operate, and, if so, take all the mitigating actions possible to reduce the risk of transmission between staff”.

This sentence is worth noting as it clearly identifies a risk exists where social distancing cannot be maintained and requires in such circumstances the employer to take “all mitigating actions possible”. Unite are of the view that this must be reflected throughout the SOP version 4, a failure to do so would be to compromise the safety of workers.

Travel to Work

We do not disagree with the advice and guidance given in this section

Driving at Work

Unite believes that the procedures in this section need to be updated to include:

“If more than one person is required to share a vehicle , then the vehicle must be large enough to allow for 2m social distancing. Failing this the workers should be supplied with an appropriate mask which must be worn”.

(Unite would very much like to see any evidence you may have that suggests wearing of masks will not assist in the prevention of the spread of the disease.)

Unite believes that it should be made clear that the procedures in this section includes the use of works vehicles at all times including when workers travel to and from work.

Site Access and Egress Points

We note in this section the SOP takes a common sense approach which if implemented should ensure that at this major ‘pinch point’ social distancing will be maintained and the additional point of ensuring workers wash their hands at this time is welcomed.

Without wishing to sound pedantic, we do have one concern; the SOP states; “Consider arrangements for monitoring compliance” Unite is of the view this should be a requirement.

Welfare facilities

We have used this generic to cover all non-working arears, Again we do not find ourselves at odds with the SOP guidance, it follows a good common sense approach recognising that  changes will need to be made and safe systems are required.

Work Planning to Avoid Close Working

It is at this point that Unite finds itself diametrically opposed to the SOP version 4. The SOP refers to the ‘Hierarchy of Controls’, which of course is the correct approach to any risk. At the bottom of the hierarchy is PPE, you will be aware when hazards cannot be controlled sufficiently in any other way PPE can be used as part of other collective measures to control risk.

In the SOP it recognises that people working within two metres of each other creates a risk. It then sets out to mitigate the risk, when all other options have failed to mitigate the risk, the SOP simply states “Coronavirus (COVID-19) needs to be managed through social distancing, hygiene and the hierarchy of control and not through the use of PPE”. What are workers to make of this statement, is it that the guidance is stating; that if you are unable to remove the risk you should put the worker at risk? If so that is completely unacceptable to Unite and its members?

The SOP could and should be revised to explicitly state that the job should not be undertaken without appropriate PPE, which of course would include masks.

The SOP also states “Workplaces should not encourage the precautionary use of extra PPE to protect against Coronavirus (COVID-19)”. This Unite finds somewhat concerning as most PPE is precautionary, so why is the risk of being infected with coronavirus different.

Unless you are able to satisfactorily answer Unite’s concerns we cannot support the SOP version 4 as it places workers lives at risk.

Unite looks forward to receiving your response. 

During the coronavirus crisis Unite is working to keep workers and the public safe, to defend jobs and to protect incomes.

For media enquiries ONLY please contact Unite senior communications officer Barckley Sumner on 07802 329235 or 0203 371 2067.

Email: b[email protected]

Unite is Britain and Ireland’s largest union with members working across all sectors of the economy. The general secretary is Len McCluskey.