Returning to Work During COVID-19

As states begin to lift “shelter in place” orders it is critical for businesses to have a plan in place to re-start operations.   OSHA’s guidance and recommendations for “essential” businesses, is a good resource for developing a plan. Identifying risk levels in the workplace and implementing control procedures such as social distancing, symptom checking, proper hygiene and sanitizing efforts are key.  Below are some measures you can include in your plan to help protect your employees.

Recommended Measures for Protecting Employees

• Require anyone with COVID-19 symptoms to stay home.
• Employees with family members at home with COVID-19 symptoms or tested positive should inform management.
• If an employee becomes sick during the day, send them home immediately. Clean and disinfect their workspace according to CDC recommendations – CDC Implementing Safety Practices.
• If an employee becomes sick during work or reports they are COVID-19 confirmed positive, organizations should make a list of all people the employee came into contact with during the time of symptoms and 2 days prior. The employee should be sent home immediately for a 14-day quarantine. Anyone with close contact the employee during this time would be considered exposed.
• Create a central entry point to the facility and maintain a daily attendance log of all workers and guests. Be sure to have a documented screening process in place.
• Practice social distancing by maintaining a minimum 6-foot distance from others.
• Prohibit gatherings of any size.
• Provide PPE such as gloves, goggles, face shields and face masks as appropriate for the activity being performed and as required to meet the assigned risk exposure level as recommended by OSHA guidance.
• Designate a site-specific supervisor to enforce COVID-19 guidance.
• Minimize interactions when picking up or delivering equipment or materials; ensure minimum 6-foot separation.
• Stagger starting times to reduce the number of people around and to ensure 6 feet of separation is possible.
• Discourage workers from using or sharing others’ work tools and equipment. Require that all tools and equipment be cleaned and disinfected before and after each shift.
• Post, in areas visible to all workers, required hygienic practices such as not touching faces with unwashed hands or with gloves; washing hands often with soap and water for at least 20 seconds; using hand sanitizer with at least 60% alcohol, cleaning AND disinfecting frequently-touched objects and surfaces such as workstations, keyboards, telephones, handrails, etc., covering the mouth and nose when coughing or sneezing; and other hygienic recommendations by the CDC.
• Place wash stations or hand sanitizers in multiple locations to encourage hand hygiene.
• Avoid shaking hands or making other unnecessary direct contact with others.
• Hold daily pre-shift meetings and employee orientations at staggered schedules.
• Suggest virtual or outdoor meetings whenever possible.
• Remind employees of HR contacts and that HR-related content and materials remain readily accessible and available.

OSHA

As a reminder, OSHA recently issued interim guidance regarding Coronavirus recordkeeping requirements and while there has been some loosening of regulations, employers must still provide a safe work environment for their employees. Pursuant to the OSHA recordkeeping requirements and as codified at 29 CFR Part 1904, employers with 10 or more employees must record certain work-related injuries and illnesses on their OSHA 300 Log. Any work-related exposure resulting in a COVID-19 diagnosis is required to be recorded on your OSHA 300 Log and your local Health Department should notified. The OSHA 300 Log COVID-19 recording requirement is prompted if the following conditions are present:

1. The situation involves a confirmed case of COVID-19;

2. There is objective evidence that the case is work-related, as defined by 29 CFR 1904.5; and

3. The case involves one or more of the general recording criteria laid out in 29 CFR 1904.7 (e.g., days away from work or medical treatment beyond first aid).

Visit https://www.osha.gov/Publications/OSHA3990.pdf for more information and recommendations on preparing your workplace for COVID-19.