COVID-19 | Is your policy register current?

27 April 2020
Jonathon Hadley, Partner, Brisbane Siobhan Mulcahy, Partner, Melbourne

The highly infectious nature of COVID-19, the ability of the virus to kill, and the disastrous impact the virus has shown it can have on a national economy all lead to one certain point.  Once a vaccine for COVID-19 is available every employer will need to consider whether they are doing enough in their workplace to protect their workers from COVID-19 infection.

Unless vaccination against COVID-19 becomes compulsory (which is highly unlikely), all employers will need to ensure that their vaccination policy is robust enough to allow them to protect their workforce to the standard required by workplace health and safety obligations.

Matters to consider in the drafting of a vaccination policy include:

  • Conscientious objection
  • Contraindication
  • Proof of immunity – through vaccination or otherwise
  • Volunteers in or about the workplace
  • Employees on exchange
  • Test periods
  • Record keeping

At the same time, with a virus such as COVID-19 normal risk assessments will likely not be appropriate.  Importantly, with a coronavirus it is not only the risk from a particular work environment that must be considered by an employer, but the risk to each worker from each other worker in the workplace.

While COVID-19 has shone the light on vaccination or immunisation policies, it has also shown the importance of workplace policies more broadly. Policies that a number of employers have relied on over the last several weeks have included policies on each of:

  • Telecommuting (working from home)
  • Flexible working hours
  • Arrangements for vulnerable employees
  • Drugs & alcohol
  • Privacy
  • Document security

A strong and current policy bank is critical for timely and appropriate response in the workplace.  It is also critical in a number of instances for evidencing compliance with workplace health and safety obligations.

Gadens have a dedicated cell of policy specialists who are able to assist you with a review of your policy bank, and specialist advice on a vaccination policy for your workplace.


For details of all our COVID-19 tips and updates, visit the Gadens COVID-19 Hub.


Authored by:

Jonathon Hadley, Partner

This update does not constitute legal advice and should not be relied upon as such. It is intended only to provide a summary and general overview on matters of interest and it is not intended to be comprehensive. You should seek legal or other professional advice before acting or relying on any of the content.

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