Workplace Requirements for Stopping the Spread of COVID-19
The last few months have been extraordinary as employers were forced to make hard decisions with the onset of COVID-19 and stay-at-home orders. You may have moved your teams to work remotely. You may have furloughed or laid-off employees. All of these steps were following the local and national health officials’ requirements to stop the spread of COVID-19.
County health departments have begun to allow low-risk businesses to reopen this week. The next step will be to allow higher risk employers to bring back workers. The final phase will be an end to shelter-in-place orders. As we move through these phases you will need to keep appraised of changes, learn how your company is defined within your county health department's directives, and determine when to bring your employees back to the physical workplace. Each county has stringent requirements that employers must implement for assuring employee safety from the COVID-19. Below is information to help guide you through this process.
OSHA requires that employers provide a work environment that is safe, secure, and free from known health hazards. Following the protocols outlined below will help to establish that as an employer, you have taken the proper steps to provide a safe work environment by implementing procedures to help stop the spread of COVID-19.
Generally, employers will need to review, prepare, and implement a work-site specific COVID-19 exposure and prevention plan for each location. Though there are many industry-specific nuances to this plan, this plan will include four primary components: individual control measures and screening protocols, cleaning and disinfecting protocols, and physical distancing guidelines for employees and members of the public that may enter your business.
Initial considerations under the exposure and prevention plan include performing a comprehensive risk assessment of all work areas, identifying at-risk employees and measures to take to prevent unnecessary exposure, designating an individual or team to create and implement the overall plan, and ensure periodic review and updates to the plan.
As a reminder, employers are required to provide employees with any time spent on compliance with any of the requisite protocol and additional discretionary policies implemented, must be on the clock time.
Individual Control Measures & Screening Protocols The first assessment is to identify if employees can continue to carry out their duties remotely. If employees must return to work on-site, a decision needs to be made if symptom screenings will be conducted for workers. If so, it should be at the beginning of their shift or upon entering the building. This would include all vendors, contractors, or other visitors entering the business. You may choose to have employees self-screen at home. You’ll need to provide guidance and supplies for employees to do so. Be sure to encourage workers who are sick or have been exposed to someone who has tested positive to stay home.
Evaluate the health department’s directives on the requirements for individual offices and open workspaces to determine the need for face coverings. If the use of face coverings or other personal protective equipment (PPE) is warranted, the employer is required to provide it and enforce employees' use of it. Finally, ensure that employees have access to hand sanitizer and soap and encourage frequent use. Employees should never share PPE.
Cleaning and Disinfecting Protocols Set a schedule for thorough cleaning and disinfecting high traffic areas and shared workspaces. Frequently disinfect commonly used surfaces and instruct employees to frequently wipe down their spaces and equipment, especially if shared with others. Other considerations include providing sufficient supplies to sanitize, providing time during the shift for employees to implement cleaning practices, and ensuring sanitary facilities stay operational and stocked with appropriate supplies.
Physical/Social Distancing Guidelines Each plan needs to be specific to the unique layout of your company’s workspace and a thorough assessment of the space is needed to determine the steps to implement. The primary goal is to implement measures to create at least 6 feet of distance between people, whether employees, customers, or visitors.
Other best practices include, but are not limited to: decrease capacity in meeting rooms, limit the number of customers in the store, alternate employee schedules to decrease the number of employees on-site at one time, close or restrict the use of common areas such as breakrooms, stagger employee breaks and close self-serve beverage and snack areas.
The worksite specific plan imposes additional compliance requirements onto the employer.
Notification: provide all employees with a copy of the plan and maintain documentation showing delivery. Provide employees with information to report deficiencies with compliance with the plan.
Training: Employers must provide training, to cover the full plan and all protocols, to all employees. The training may have to be provided multiple times, depending on specific circumstances of the position or tasks. The training must include the proper use and care of the PPE.
Recordkeeping: employers must maintain training records, proof of dissemination of the plan, and document exposure incidents.
Compliance: employers are responsible for regularly evaluating the workplace for compliance with the plan and document and correct any deficiencies.
Policy and Procedure Review Employers should also review already existing policies and procedures to align them with revised requirements from OSHA. Your Injury and Illness Prevention Plan should be updated to reflect keys aspects of the exposure prevention plan to include prevention of the spread of the COVID-19. A separate policy should be in place to include the requirements of the FFCRA (Families First Response to Coronavirus Act) that expand paid sick leave and emergency FMLA. If applicable, review job descriptions if duties have been shifted due to limitations from stay at home orders.
Karen Mathews Radau, CEO and Sr. Consultant Small Business HR Services®, Chapter 113
Karen Mathews Radau has been in business for 12 years doing organizational effectiveness, career coaching and human resources. She is passionate about helping her clients be successful, manage their risk as an employer and develop a culture of compliance.
Karen is certified as an HR Professional, has an M.A. in Organizational Psychology from JFKU and a B.S. in Business Management from UOP. She has additional training and certifications, most notably as a Certified Coach and NLP (Neuro-Linguistic Programming) Master Practitioner. See more at www.Smallbizhrservices.com.