COVID-19 Management Planning: Questions Employers Must Be Able to Answer Before Returning Employees to the Workplace

and   |   May 27, 2020

Across the U.S. states are beginning to lift restrictions that will allow businesses to reopen. While this brings hope, it also presents an enormous task and responsibility for employers. Employers will need to coordinate with multiple groups to prepare their workplace for re-occupancy and establish plans for how they will safely manage their workforce and continue to ensure a healthy environment throughout this pandemic.

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There are a great number of issues and details to address in order to develop an effective COVID-19 management plan. Here are some of the most critical questions employers must be able to answer before returning staff to the workplace.
 

Have you established a strong leadership team to manage the challenges associated with the COVID-19 crisis?

A qualified leadership team will need to be assembled whose purpose is to anticipate, evaluate and develop plans to control SARS-CoV-2 risks to employees, the community and to your organization throughout the pandemic. To establish transparency and trust this team should train staff on COVID-19 prevention procedures and provide regular communications with staff to communicate:

  • Measures that are being undertaken to create a healthy workplace and to prevent transmission of disease.
  • Any confirmed COVID-19 cases in the workplace and steps taken by your organization to manage the risks.
  • Reminders to staff to continue practicing infection prevention behaviors such as hand washing, staying home when sick, and practicing social distancing.

Your team should include membership from the following groups:

  • Environmental Health & Safety
  • Human Resources
  • Employee Health Services
  • Facilities
  • Communications
  • Critical Business Functions

Specialized consultants or service providers may also be needed to address issues such as collection and evaluation of employee medical information, environmental health, building science and janitorial services. Specific roles and lines of responsibility should be established and communicated.

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Have you assessed whether your building’s water systems are at risk for Legionella growth?

For several weeks now most buildings have been empty or had low occupancy due to the pandemic. Stagnant water has been sitting in building pipes, creating ideal conditions for Legionella bacteria growth. Legionella bacteria causes Legionnaires’ disease, a serious pneumonia that often results in hospitalization and in the same vulnerable populations as COVID-19. The CDC recommends “flushing” of outlets until all water is “replaced” within the building and until the hot water reaches the maximum temperature at every outlet in the building. This should be in combination with implementation of an effective Water Management Plan which should include targeted testing. Achieving these recommendations will require a significant amount of personnel time and building owners and managers may need to enlist additional assistance to address these specialized issues in a timely manner.

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What proactive measures will be undertaken by facilities management to ensure a healthy workplace?

Many employees will be reluctant to return to the workplace due to fears of exposure to the coronavirus. It will be imperative that your leadership can assure employees that the workplace is safe.

A pressing question for facilities management is whether they need to disinfect their HVAC system before re-opening. The answer to that requires an understanding of how viruses survive in the environment and will depend upon whether your facility has special circumstances such as being located in a high humidity region as well as the type of mechanical system you have in your building. For more on this issue read this blog post Do I Need to Disinfect My HVAC System for the Coronavirus Before Re-Occupancy?

Aggressive disinfection efforts can introduce unwanted chemicals into the indoor environment, which could be irritating to individuals upon re-occupancy. Understanding proper dilution and application of disinfectants is essential and should be monitored during required treatments. Now is the time to verify HVAC performance and the quality of your indoor environment through a targeted inspection and testing program to ensure a “clean bill of health” prior to re-occupancy. This will ensure that workspaces meet or exceed code requirements of cities and towns. Your HVAC performance criteria must be clear and consistent with best industry practices in the event regulators pay an unexpected visit to address complaints.
 

If you are a tenant, have you communicated with your building owner or property management company to coordinate plans?

If you lease your facility, you will need to communicate with Property/Office Building Management regarding what measures they are taking to provide:

  • Additional cleaning for the general building space (e.g. entry ways, common break rooms/kitchens, restrooms, stairwells, elevators, etc.). Dated logs should be maintained that describe the scope of work conducted.
  • Communication and specific steps they will be taking if a COVID-19 positive case is identified in the building or in someone having visited the building (another tenant, service providers, etc.).
  • Additional security and building systems adjustments needed if the building occupancy lowers significantly due to tenant’s shifting to working remotely.
  • Increased general ventilation if feasible.
  • Contact information for Property/Office Building Management in case of an emergency.

Your responsibilities as a tenant may include plans for:

  • If your office or facility only requires access using a key fob or security card during off hours, consider restricting access throughout the day to ensure the office is secure if you have shifted to an in office work rotation schedule, or a work from home policy.
  • Notification to vendors to suspend deliveries and/or adjust maintenance schedules for services provided (e.g., vending/coffee machines, recycling services, perishable food deliveries).
  • Arranging for additional cleaning and disinfections services in your area if the Property/Office Building Management services do not meet your needs.

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Have you identified appropriate infection prevention practices to prevent transmission of COVID-19?

Based on guidance and directives from CDC, OSHA and state agencies you’ll need to establish plans that include appropriate infection prevention practices to prevent transmission of COVID-19 in your workplace. These include practices such as handwashing, social distancing, wearing masks, having employees clean and disinfect their individual workspace daily. The employer will need to provide handwashing facilities, supplies such as disinfectants and face coverings and organize the workspace so that staff can be properly spaced out or protected when working, using break or lunch rooms and moving about the facility. It is the duty of the employer to educate employees on the COVID-19 infection prevention practices and management plan and document that the training was completed.
 

Face masks are recommended and, in some states, required. How will you supply these and what are the protocols for use?

Face masks are recommended to reduce the release of respiratory droplets into the immediate environment, and in some states, may actually be required. For many organizations, the first hurdle may be obtaining an adequate supply of masks.

You’ll need to establish protocols that specify in what locations and situations employees are required to wear masks and communicate this to all staff. Staff will also need to be provided with instruction on the proper use and cleaning, or disposal, of masks.

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How will you manage your workplace to accommodate recommended precautions?

To minimize the potential for transmission of respiratory droplets, it is recommended by the CDC to physically space employees in the workplace to maintain a distance of six feet between individuals. Consider how will this be achieved in your workplace, taking into account different types of spaces such as open work areas, conference rooms, corridors and cafeterias. The nature of your operations will be a major factor in identifying the best approach.

For those with open concept offices that use flexible seating or “hoteling”, these practices may need to be suspended or, specific cleaning regimens will need to be employed on the “hoteling” spaces. Many times, it may be simpler to assign employees to a designated space for a period of time. Higher partitions may also need to be installed to better isolate individuals if the six-foot separations cannot be maintained. To achieve the six-foot distance, you may need to maintain a partial remote workforce (particularly for vulnerable populations) or stagger work shifts.
 

Have you identified proper protocols and methods of cleaning and disinfection?

Throughout the COVID-19 pandemic, it is advisable to perform additional cleaning procedures throughout your workplace. Frequently touched items such as drinking fountains, faucets, cabinet handles, door hardware, light switches and elevator buttons should be wiped down and disinfected regularly.

Enhanced or deep cleaning may be necessary in the event it is determined that a person with COVID-19 was in the workplace for an extended period of time, or an employee is identified as a close contact of a person who was confirmed or presumed to be positive for COVID-19.

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A close contact (as defined by the CDC) is someone who meets any of the following criteria:

  • Being within 6 feet of a COVID-19 case for a prolonged time period (10-15 minutes or more) including 2 days (48 hours) prior to the person developing symptoms
  • Caring for, living with, visiting, or sharing a healthcare waiting area or room with a COVID-19 case
  • Having direct contact with infectious secretions of a COVID-19 case (for example, being coughed on)

 

What steps will you take to respond to a positive case of COVID-19 in your workplace, or an employee who has been in close contact with a person who is COVID-19 positive?

A positive case of COVID-19 in your workplace will need to be managed effectively and treated with sensitivity. Key components of this process will be:

  • Virtual interview with the infected employee
  • Contact tracing
  • Notification of close contacts
  • Enhanced cleaning and disinfection plan
  • Corporate communication notifying employees of the confirmed case and steps taken by the organization to manage the risks
  • Criteria for when it will be acceptable for the employee and close contacts to return to work

Information is being updated frequently regarding recovery from COVID-19 and recommendations for returning to work; therefore, organizations should check CDC Guidelines regularly and revise plans accordingly.
 

Have you reviewed your human resource policies to make necessary adjustments to ensure they are in alignment with public health recommendations and state and federal laws related to COVID-19?

Human resource policies and practices will need to be reviewed to be sure they are consistent with public health recommendations and existing state and federal workplace laws related to COVID-19.

Communicate to employees what policies, workplace and leave flexibilities, and pay and benefits will be available. In particular, be sure sick pay and FMLA policies meet the new guidelines established by the Families First Coronavirus Response Act (FFCRA).

Review your current benefits programs to see what services can be provided virtually, such as via Telehealth, by phone, etc. Also review your benefits to see what other services may be available that will be useful in a crisis, such as an Employee Assistance Program (EAP).

It will require strong leadership and involvement from multiple groups to assure employees that appropriate measures are being taken to maintain a safe environment and prevent the transmission of the coronavirus in your workplace. Having written policies and procedures and documenting water management and indoor air quality measures will be valuable in the event an issue does arise. While federal and state agencies are providing guidance, accurate interpretation of that guidance and how to implement recommendations can be challenging. Organizations should enlist qualified experts to provide specialized support to their leadership team in areas such as occupational health, industrial hygiene and environmental health to assist with interpretation of guidelines and evaluating the effectiveness of their management plan.

If you need guidance on appropriate measures and best practices for reopening your workplace, contact us today to talk with an expert.