Employers face a daunting task as they craft new and revised policies for the “new normal” as employees start to return to work onsite. Not only do they have to comply with a myriad of constantly changing federal and state laws and guidelines, but they have to earn the trust of their employees, vendors, and customers that the workplace is safe. It’s critical to have a clear plan that is well communicated, but flexible, as this is uncharted territory. Open communication and encouraging feedback will build confidence as safe and efficient processes evolve.
The details of each employer’s plan will look different. At a minimum, it must reflect compliance with federal and state laws and guidelines. Industry groups and associations provide helpful guidance and resources and OSHA has issued guidance for specific industries. The CDC guidelines for business can be found here.
The American College of Occupational and Environmental Medicine (ACOEM) has launched Getting America Safely Back to Work that describes how OEM physicians can help employers navigate through the myriad return-to-workplace issues as well as return-to-work/fitness for duty issues for injured employees.
Automotive-seating manufacturer Lear Corp. recently published the “Safe Work Playbook,” a guide for safe practices at work during the pandemic for organizations of all sizes. It includes steps for cleaning and disinfecting equipment, staggering shifts and lunch breaks, setting up a pandemic response team, establishing onsite health screening, and creating protocols for isolating employees who come to work sick.
Here are key issues to consider:
- Workplace safety: a COVID-19 Infection/Exposure Control Plan
- Administrative controls: staggered return to work, reducing number of workers onsite at one time, changing or alternating shifts minimizing or eliminating overlap, cross-training workers to accommodate more absenteeism, re-schedule lunch breaks, appointing a COVID-19 coordinator to oversee equipment disinfecting and social distancing
- Engineering controls: reconfiguring workspaces to promote physical distancing, increasing ventilation rates, high-efficiency air filters, installing physical barriers, one-way traffic patterns throughout workplace, monitors that beep when one worker gets within six feet of another, more handwashing stations, drive-through windows for customer service
- Pre-shift health screening: temperature checks and health/symptom questionnaires
- Decisions about personal protective equipment, respirators, face masks, and face coverings – will they be required, who will pay for them, etc.
- Detailed plans for enhanced disinfecting, including common touchpoints such as time clocks, doors, shared equipment, break room. Shift changes should allow the opportunity for optimal disinfection of the workplace
- Screening and minimizing interaction with all visitors and vendors
- Plan for safe meeting places with no more than 10 employees at any meeting
- Protocols for isolating employees who become ill at work, stay-at-home requirements, and exposure communication to affected staff
- Restrict access to confined or closed spaces
- Provide adequate handwashing facilities and/or hand sanitizer that contains at least 60% alcohol
- Define and limit travel to “essential”
- Recalling employees
- Larger employers are encouraged to use a phasing-in system to limit exposure and build employee confidence
- Know how to recall furloughed employees to qualify for loan forgiveness under the Paycheck Protection Program and how the new federal paid leave laws apply to employees returning from furlough
- Keep separate records for payroll period that workers were furloughed for workers’ compensation purposes
- If job responsibilities have changed, understand what needs to be done for compliance with FLSA and Workers’ Compensation
- Notify the state unemployment agency of employees recalled
- Determine how to handle employees who are unable or unwilling to return to work
- Determine if light duty will be offered to injured workers to return to work and what will happen if they refuse to do so because of fear of exposure
- Evaluate the need for extra protections for “high-risk” employees
- Review any benefit and compensation changes that have been made
- Have a remote pre-return training for managers and supervisors
- On the first day of facility reopening, have staggered staff training in an area that adheres to social distancing protocol
- Consider requiring employees to sign and acknowledge the organizations’ policies on preventing the spread of the coronavirus
- The COVID-19 exposure control plan or response plan should provide a detailed description of everything the employer is doing to address the hazard, including an assessment of potential changes to personal protective equipment, administrative controls, workspace separation, and staggered work shifts
- Keep adequate records of good-faith efforts to comply with standards that require annual or recurring audits, reviews, training, or assessments
- Understand the reporting requirements for COVID-19 cases
- Follow guidance issued for your industry
- Do not retaliate against employees who file complaints
- Work from home
- When possible, continue remoting working and flexible hours
- Review policies to determine if they need to be strengthened or updated
- Communicate which jobs will be permitted to continue to telework and why
- Consider staggering work in office and at home among team members
- Assess IT infrastructure and staff
- Monitor productivity and be clear about expectations
Employers have learned valuable lessons regarding their resiliency over the past months. It’s important to prepare for a potential second wave in the fall as well as implement a business continuity plan, including infectious disease control, if a plan does not exist.
A time of crisis is what truly defines a reputation. Your response to your employees, customers, and vendors will be the key to survival and long-term prosperity.
Additional resources and a formal checklist can be found at the Duncan Financial Group COVID-19 Resource Center Online
For additional information and resources on Coronavirus, go to the Duncan Financial Group COVID-19 Resource Center Online
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