Business owners who have had to suspend operations due to the COVID-19 shutdown are anxiously waiting to get back to business, but restarting operations will require several changes to both facilities and practices in the workplace to ensure safety for employees and compliance with regulations. Employers will want to establish their plans and policies for workplace safety before bringing their employees back to work.
Executive Director of CEOtoCEO and Washington State Representative Joe Schmick presented the questions companies should be asking to provide a safe work environment for employees and minimize the risk of infection hampering operations. These guidelines include practices for hygiene in the workplace, tailoring policies to the industry or job responsibilities, and communication to employees.
Joe noted that many companies have been creating business continuity or disaster plans for decades, but these plans predominantly focus on natural disasters or accidents such as flood, fire, tornado, earthquake, or power outage. Many companies even have plans for what they will do if key personnel are lost. Most companies do not have a plan for a pandemic or biohazard, but the COVID-19 outbreak has demonstrated the need for every company to establish a plan for how they will operate when transmission of illness in the workplace, or the government's response to a pandemic, becomes a disruptor of business.
Companies should consider what their immediate needs will be upon returning. What are the projects that need to be completed, and which employees are needed to complete them? A phased return may be appropriate if the workload is limited upon return, but is expected to increase as the businesses resumes operations. Employers should also consider options to reduce the density of people in their workplace and keep groups of employees separated. Creating distinct "teams" of employees that do not share physical space with employees from other teams can help minimize the chance of infection spreading throughout the entire company.
- Split Workforce
- Teams report to work on different days, and are not in the workplace at the same time
- Distributed Workforce
- Teams work in distinct locations which are separate from each other, and do not report to the work location of another team
Some companies may want to prohibit outside sales people from reporting to the office, and will need to establish procedures for submitting paperwork from clients. Thought should also be given to which employees can complete their job responsibilities from home, and which employees need to be in the office. Ideally, the employer can create as many separate work locations as possible to limit the risk of illness transmission between employees. While having every employee working from home would be ideal in this regard, it is not likely to be feasible for most employers.
The General Duty Clause of the Occupational Safety and Health Act (OSHA) requires employers to provide a workplace "free from any recognized hazards that are causing or are likely to cause the death or serious physical harm to employees."
According to OSHA, "This means an employer has an affirmative duty to protect employees from a pandemic virus."
Establishing a plan to protect employees is a good first step in fulfilling the duty to protect employees. It is expected that Washington State will require businesses to have one. A company risk management plan should reflect the latest State and Federal requirements, and changes to company policies should be added to the employee handbook as they are made.
The first measure necessary to provide a safe workplace in terms of COVID-19 is to screen anyone before they enter the workplace for signs of potential infection. This should be done in a location that offers both privacy and sufficient space to observe proper social distancing. One employee should be designated to conduct the screenings, record the results, and maintain the records, as the information gathered should be treated as private health information. Having one designated person with access to the screening records limits the risk of private health information being misplaced.
Health screenings can be conducted either onsite or online. Employees reporting for on-site work should be subject to a temperature screening in addition to being asked questions about their health status, activities, and travel to high-risk areas. Temperature screening should be done with a touch-free infrared thermometer, and employees with a temperature of over 100.4 degrees Fahrenheit (the temperature the CDC has set as indicative of a fever) should be sent home.
Health screening questions that have been recommended by the CDC are listed below. Employees should be asked to answer if they are experiencing any of the following symptoms, and their answer for each should be recorded every day they report to work:
- Sore throat
- Shortness of breath
- Loss of taste
- Loss of smell
- Bluish face or lips
- Abnormal muscle pain
Employees who display or confirm having any of these symptoms should be sent home and advised to contact their healthcare providers.
Employees should also be asked about any travel, social visits, or contact with people outside their households they have had since their last screening.
The records kept of these screenings will help companies demonstrate the fulfillment of their responsibilities under the General Duties Clause, but may also be helpful in identifying any employees who may have been working with an employee who tests positive for COVID-19 or another illness.
Companies will need to decide if visitors will be allowed into the workplace. If visitors are allowed, they should be subject to the same health screening as employees, and the records should be kept as they are for employees. Visitors can be a potential source of exposure, and should be treated the same as employees in order to reduce risk in the work environment. It may be necessary to limit the access visitors have to certain areas of the workplace, and businesses will have to balance safety and requirements of their business. If possible, visitors should be restricted from accessing the immediate work areas of employees.
Some businesses may want to require visitors to wear masks. They can require visitors to wear masks even if their employees are not required to wear them, but it is advisable that a supply of masks is kept on hand for visitors in case they do not have their own.
Joe recommended that employers begin the process of evaluating their facilities by using their cell phones to record a video tour of their facilities. Review all of the items, devices, handles, and buttons that employees will touch throughout the day. This video can help determine the "touch points" that should be cleaned frequently to help minimize the risk of illnesses being transmitted.
Employers will also want to check the spacing of the office to ensure that employees will be able to observe proper social distancing as they perform their jobs. Signs and floor markings (either pre-printed durable floor stickers or durable colored tape) can be used to indicate proper distancing in both work and common areas. These visual cues will help reinforce social distancing habits in employees, as well as visitors to the workplace.
Signage indicating proper safety procedures should be placed throughout the workplace. The reception or entry area should have signage indicating to visitors that they should wait to be screened before entering. If visitors are required to sign in when entering, pens should be changed between visitors.
Sufficient hand sanitizing stations should be placed throughout the workplace. Touch-free dispensers are ideal, as they don't require people to touch a shared container, but currently supplies of refills for these certain dispensers can be limited supplies, so businesses may have to proactively locate suppliers and purchase from multiple sources.
Meetings may have to be eliminated, conducted online, or modified to comply with social distancing guidelines. Companies may want to establish meeting protocols, and may even need to establish specific protocols for different meeting rooms due to different spaces and furniture configurations. Each meeting room should have a sign posted stating the maximum capacity of people allowed for safety. Most meeting rooms may need to have every other chair in the room removed to allow sufficient space on each side of every participant. Floor marking tape can be placed to indicate where chairs should be positioned. Some companies may choose to require masks when people meet, even if they are observing proper social distancing.
Similarly, the break room or cafeteria should be set up to ensure proper social distancing. This may require the removal chairs, and may require the removal of some tables. Floor marking tape should be placed to indicate where chairs should be positioned, and signage should be placed at eye level reminding employees to observe social distancing when in the break room. Depending on the number of employees, it may also be necessary to have staggered breaks and separate lunch shifts to reduce the number of people using the break room at any one time.
Work spaces must be evaluated to conform to social distancing, and sharing of work spaces should be avoided if possible. "Shared" workspaces with no separation, or low-wall cubicles, will have to be modified, and some form of partition will need to be added. Reception areas or areas requiring visibility and separation should use some form of clear plastic partition ("sneeze guards") to reduce exposure.
It is also important that a regular schedule and procedure for cleaning and sanitizing workspaces is established. Certain "touch points" (as mentioned above) should be sanitized multiple times a day, while some employees will want to clean shared equipment such as copiers between every use. Businesses should have an adequate supply of disinfecting wipes so employees can conveniently disinfect surfaces throughout the day.
Establishing restrictions on access will be important, and these should be communicated to employees both verbally and through signage and floor markings. Controlling spaces employees can access in the workplace will help prevent them from congregating too closely or accessing areas of the office that are not necessary for their work.
Safety training can be conducted online, and initiating training before employees return to work is ideal, as it makes their return to the workplace that much more well-informed and prepared to operate safely. Training should be documented so companies can demonstrate compliance if necessary. Employers should assign certain personnel to ensure that training reflects the most current information and that company safety policies conform to the latest local and federal regulations.
Training on proper social distancing and hygiene should be conducted frequently to reinforce healthy habits in employees, as well as to offer an opportunity to review company policies, or any changes to those policies. Frequent training also provides opportunities to ask employees for feedback on how they feel regarding the company's safety measures, and anything the company could be doing to improve their confidence in them.
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