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When planning for the new Traffic Light System feels a lot like planning a family Christmas…



Current as at 25 November 2021

The new traffic light system feels a lot like planning a family Christmas event. No one quite knows how to approach it. Everyone wants to avoid difficult discussions with their loved ones but overall, we want to keep ourselves and our families safe.


We’ve broken down the key things we think you should consider when planning for the new traffic light system, when to start, and what your next steps should be.


What is the new system?


The COVID-19 Protection Framework (traffic light system) introduces a new 3-level approach to managing COVID-19 in the community:

  • Green – used when there’s limited COVID-19 in the community, hospitalisations are at a manageable level, and the health system is ready to respond.

  • Orange – used when there’s increasing community transmission of COVID-19, the whole health system has focused its resources but can manage the outbreak, and there is an increasing risk to the public.

  • Red – used when action is needed to protect the health system and to protect at-risk populations.

The good news is that the new traffic light system is more flexible than the previous Alert Level system. You can find more information on the new system here.


Will the new rules impact your business?


Just like family Christmas, sometimes you can’t plan for all scenarios. However, if you are in business in any shape or form, you’re likely to be impacted in some way. You may not have employees, or employees directly impacted, but you may be a supplier to a business that requests your COVID-19 response policy or a customer to a business that requests that information prior to entry. It is best to be prepared for these scenarios rather than wait to see what the next steps are.


Let's be future-ready, today:


You don’t want to be caught in Christmas Eve panic shopping for the last Pavlova in the Supermarket. By planning early, you will not only determine if your business is impacted but what your next steps should be. We recommend the following actions to be taken.


1. Perform the recommended risk assessment


The new legislation is likely to include a health and safety risk assessment for employers to determine whether they require certain roles within their business to be performed by someone who is vaccinated. WorkSafe NZ currently has a risk assessment guide that can be used before the legislation is enacted, you can find it here.


The risk assessment focuses on the employee role – what is the work being done and does the role require a vaccinated employee to complete it.


When completing the risk assessment, follow the guidance but apply it to your scenario, if it helps, sit with your employee and work through it with them. This may help you formulate your answer while also keeping the communication channels open with your team.


Although the vaccination assessment tool is still in development, the government has released that it is also likely to include the following four factors:


- Work is done indoors, in a space smaller than 100m2

- Work is done less than 1 meter apart from other people

- Work is done in proximity to other people for more than 15 minutes

- Work involves providing services to people who are vulnerable to covid-19


If three of the four above circumstances are met, then it will be reasonable to require vaccination for that work.


Scenario 1: If you are in hospitality, events, gatherings, close contact business, or gyms then you will be required to use “My Vaccine Passes” to operate. Employees must have their first vaccination by 2nd December 2021 and be fully vaccinated by 17th January 2022.


Scenario 2: If you aren’t required to operate under the “My vaccine passes” mandate, your risk assessment might still find that you have certain roles in your business that should be performed by someone who is vaccinated. If you have an unvaccinated employee in a role that you believe will require them to be vaccinated there are options for the employee to remain in the business. This can be either in another role that does not require vaccination or for their role to operate in a way that would reduce the risk (ie change in location or hours of work). We encourage you to have those conversations early and follow the guidance here.


Scenario 3: If your risk assessment results have determined that you are not a mandated business and you have no roles in your business that are required to be performed by a vaccinated employee, then you should follow the guidance in the traffic light system around what processes to follow. For example, when to require face coverings, when working from home is encouraged, and when to socially distance.


If you can prove you have completed the risk assessment and engaged with your employees, then you are 95% there in meeting the new requirements. It is now a matter of reconfirming your risk assessment when the new law comes in to make sure no updates will require you to revisit your decisions.


2. Appoint a covid response internal champion that can be your sole source of truth and manage the change

Appoint your own key Christmas party planner. Who is responsible for communicating changes to the team, who will keep on top of the guidance coming out, and who will perform your risk assessment for your organisation.

3. Connect with your suppliers or customers to discuss potential changes to your business as a result of the rule changes

Don’t be afraid to pick up the phone and call your suppliers and customers early, you don’t have to have all the answers, but if you are clear on what it means for your business, you can open the communication channel and keep it open.

4. Encourage your employees to download their vaccination certificates.

Its relatively simple, but for those that aren’t as tech-savvy, it can be daunting to know where to start.


Tools you may need for your business:

  • How will you keep your employee’s information safe? How will you store their vaccination status?

  • The Ministry of Health has released an app to scan and verify customers’ “My Vaccine pass”. You may need to consider having a roaming cell phone or tablet to be able to scan the documents on entry of customers.

  • If you are in retail or hospitality, do you have a mechanism for ensuring you are socially distancing and able to count how many customers are on-site?

  • Do you have documented processes and procedures around your own COVID-19 response?

Key dates to note

  • 17 November – My Vaccine Pass is made available to the public.

  • 29 November – Cabinet will confirm the decision to move Auckland and the rest of New Zealand into the new traffic light system.

  • 2 December – At 11.59 pm, all of New Zealand will move to the traffic light system. Auckland will move to red. Settings for the rest of New Zealand are yet to be decided.

  • 15 December – People traveling out of Auckland will need to be fully vaccinated, or have a negative test 72 hours prior to departure, to leave Auckland and visit other parts of the country. This requirement will remain in place during the core summer period, until 17 January 2022.

  • 24 December – Time to panic if you haven’t completed your Christmas shopping

  • 25 December – Time to sit back, relax, and breathe a sigh of relief that all the hard work and planning has come through. Enjoy!

Helpful resources

Most industry bodies are putting out communications also, keep an eye out for your industry associating guidelines such as:

How can we help?

Like during the first Covid-19 response, we are reviewing and updating our information as soon as it comes out. If you have any questions on the above, please reach out.

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