Return-to-Work Guidance in the Wake of COVID-19
Posted on May 5, 2020
Before we begin, VelocityEHS would like to acknowledge the health care providers, first responders, grocery store workers, truck drivers and transportation workers, and other essential workers who have been operating uninterrupted since the beginning of the COVID-19 outbreak. All of us owe you an immeasurable amount of gratitude for your service and tireless commitment. We hope that the following guidance will serve as a helpful supplement to your existing workplace protections, and that you will continue to stay safe during COVID-19.
As governments and public health officials examine the prospect of lifting stay-at-home orders, ending mandatory closures for non-essential businesses and getting the economy back to work, there is one thing that everyone needs to keep in mind — SARS-CoV-2 and COVID-19 is still a serious threat. That threat is perhaps even greater today than it was when the first case was recorded in the U.S. more than 90 days ago.
Returning to Work?
If your business is evaluating the process of re-opening over the coming days and weeks, you need to know that it’s not going to be as easy as switching on a light bulb. If you haven’t done so already, there are numerous policies, controls and other preventive measures that you must put in place prior to opening your doors in order to protect workers and the general public.
Numerous regulatory agencies and public health and safety organizations including U.S. federal and state OSHA, Health Canada, EU-OSHA, CDC, AIHA and others have published a wide array of guidance for returning to work in the midst of the COVID-19 pandemic. We’ve analyzed and compiled guidance across several of these sources to help provide you with reliable, actionable strategies you can use to help prepare your business and get up and running, while minimizing the risk of transmission and infection to the greatest extent possible.
Remember, without sufficient safeguards in place, you may unknowingly contribute to a resurgence of COVID-19 cases in your community, placing an unfair and unsustainable burden on health care providers and emergency responders who are already stretched to breaking point. If your business has the option to keep workers at home until COVID-19 is no longer a threat — we advise that you do so.
General Return-to-Work Guidance
The preventive measures you ultimately implement are largely dependent upon the unique exposure scenarios that may be encountered, and the overall level of exposure risk in your workplace. Yet, regardless of your industry and exposure risk level, there are things that all workplaces should do to achieve the greatest possible level of protection.
Developing a Return-to-Work Plan
Before you resume normal operations, you need to create a clearly defined plan of action for implementing necessary SARS-CoV-2 exposure safeguards, and procedures for identifying and responding to cases of COVID-19 in your workplace.
You should assign a qualified person or team of individuals who will be responsible for coordinating the development and implementation of your COVID-19 return-to-work plan. All workers in your facility should know how to contact plan coordinator(s) with any COVID-19 concerns, and affected workers should be included to the greatest extent possible in the plan development process. All individuals entering or working in your establishment (e.g., all facility workers, contractors, and others) should receive notice and training in your return-to-work plan, and it should be readily available to those individuals at all times.
When drafting a COVID-19 return-to-work plan, be sure to review relevant regulatory and public health agency guidelines. For example, OSHA’s “Guidance on Preparing Workplaces for COVID-19” includes recommendations and specific safety and health standards that can provide a solid basis for your plan.
COVID-19 Return-to-Work Plan Elements
At a minimum, your COVID-19 return-to-work plan should include detailed descriptions of the following:
Communication of Return-to-Work Policies
Before bringing your workers back into the workplace, your employees need reassurance that you’ve thought the process through, and that you’re doing everything possible to protect them. They need to know details of your return-to-work plans including timing for return-to-work, exposure controls that have been put in place, and any other safeguards you’re implementing to minimize or eliminate potential workplace exposures to SARS-CoV-2 and COVID-19. Make use of your existing communications channels, and make every effort to keep workers informed and up-to-date, especially as policies and elements of your plan change.
Identification & Assessment of Exposure Risks
You’ll need to perform an exhaustive evaluation of where, how and when workers may be exposed to SARS-CoV-2 and COVID-19. Be sure to identify and address EVERY POTENTIAL SCENARIO. At a minimum, this should include:
- Workspaces where individuals are in close contact (<6 feet) with other workers during work shifts
- High-touch surfaces that are likely sources of potential contamination
- Areas where workers congregate (breakrooms, restrooms, corridors and passageways, etc.) and potential modes/pathways of virus transmission
- Workers’ individual risk factors (e.g., older age, pre-existing medical conditions, etc.)
- ANY AND ALL workspaces or workplace conditions deemed to be a potential source of exposure
Your assessment should also include, to the greatest possible degree, non-occupational exposure risks. Make sure you identify and account for any instances where workers have/may have had had unprotected exposures to people known to have, or suspected of having, COVID-19. Evaluating non-occupational exposure risks will require participation from workers to provide personal information to the employer, information that workers may be apprehensive to share. Maintain and emphasize the privacy of all information shared by employees regarding non-occupational exposure, and that it is solely for the purpose of assessing potential exposure to COVID-19.
Implementation of Workplace Exposure Controls
Once you have identified all potential exposure risks, you must implement the controls necessary to minimize or eliminate them. The controls necessary to address the full spectrum of workplace exposure risks are too numerous to list here. However, there are some general controls that public health officials and regulators point to as basic best practices for prevention:
- Daily pre-screening of workers for potential COVID-19 symptoms or exposure through use of temperature monitoring, questionnaires, etc., and restricting building access in cases of potential exposure. This should include temporary workers and contractors at your work site. Communicate with contractor providers and staffing agencies about their own return-to-work plans, including screening and removal policies.
- Mandatory use of personal protective equipment (PPE) including N95 face-fitting respirators (FFRs) or other approved respiratory protection, gloves, eye protection, etc.) Ensure systems are in place for managing supply, fit, maintenance and storage of worker PPE.
- Establish and enforce guidelines for personal hygiene, including shielding coughs and sneezes, and frequent handwashing
- Social distancing (i.e. maintaining at least 6 feet of separation between workers) or alternative practices when physical distancing is not possible
- Limiting/eliminating in-person meetings and work-related travel, and making use of available video conferencing and webchat technologies for remotely managing projects, tasks and workers – even post-lockdown
- Requiring people who are infected or suspected of being infected to stay at home
- Re-configuring the work environment (workstations, common areas, etc.) with social distancing in mind and implement rules, designs, processes and technologies to maintain appropriate social distancing
- Requiring workforce training in COVID-19 exposure control measures and practices, as well as relevant regulatory safety standards (i.e. OSHA Bloodborne Pathogens
- Frequent and regular disinfection of work spaces with approved disinfectant chemicals
- Install/modify HVAC system controls to meet or exceed ANSI/ASHRAE performance standards
Verification of Workplace Exposure Controls
Worksite assessments to evaluate effectiveness of COVID-19 prevention strategies should be performed frequently. As part of these assessments, facilities should consider ongoing testing and workplace contact tracing (identifying specific person-to-person transmission) for COVID-19 as a key indicator of control effectiveness. Perform preliminary workplace assessments, control verification and compliance audits prior to bringing workers back into your facilities.
Establishing Policies and Procedures for Prompt Identification and Isolation of Infected Individuals
If daily pre-screening reveals potential exposures, workers should be sent home immediately. Ensure that you have a system in place to easily document worker responses and screening results, not only to minimize the time required for screening, but also for future reference and contact tracing purposes. Establish isolation and removal procedures for workers who may exhibit symptoms during the work shift after they have entered your establishment, with the goal of minimizing or eliminating contact with potentially infected workers.
Developing Contingency Plans and Policies
Even with robust controls and prevention policies in place, the risk of exposure to SARS-CoV-2 and COVID-19 is still high. Proceed from the assumption that workers are likely to become infected, either in the workplace or outside of it, and develop plans to manage:
- Recording and reporting of work-related exposures to SARS-CoV-2 and COVID-19
- Increased rates of worker absenteeism
- Complaints from workers regarding lack of workplace COVID-19 safeguards
- The need to implement more aggressive exposure controls such as downsizing operations, delivering services remotely, or conducting essential operations with a reduced workforce
- The need to cross-train workers in different job tasks in order to continue operations or deliver essential services
- Interrupted supply chains and other operational disruptions
- Citations, penalties and stop-work orders issued by occupational health and safety regulators (e.g. OSHA) for failure to provide adequate workplace protections
Establish an Emergency Communications Plan
Identify the key personnel (including backup/reserve roles), chain of communications (including suppliers and customers), and processes necessary to quickly react in the event that a large number of employees exhibit COVID-19 symptoms — potentially indicating a workplace outbreak. You will need to determine at what point you should cease work, remove all workers from the workplace and begin implementing contingency plans for handling disruptions to operations, decontaminating the workplace, and other impacts of an outbreak.
It should be noted that the return-to-work plan elements we’ve discussed here are not comprehensive, but are more general in nature. The specific plan elements you develop for your workplace should reflect the unique exposure risks and operational attributes of your business, and your workforce.
Also, beware the mindset that we are somehow “out of the woods” when it comes to the risk of infection from SARS-CoV-2 and COVID-19. As we see in the data provided earlier, the rate of new cases confirmed each day is as high as it has been, and that trend may still be on the rise. There is an incredible amount of uncertainty surrounding the risks of returning to work at this time, so if you must return to work, the best approach is to not underestimate those risks and take every precaution possible. The lives of your workers and the fate of your business quite literally depend upon it.
For more COVID-19 return-to-work resources, as well as free tools to help you protect your workplace, visit the VelocityEHS COVID-19 Resource Site. While you’re there, check out some of our additional return-to-work resources, including:
- Consider the Physical Condition of Workers When Restarting Work
- Tips for Reducing Physical Stress on Workers When Restarting Work
- Restarting Work After COVID-19: 7 Tips to Help Employees Prepare
From all of us at VelocityEHS, remember to stay safe and follow the guidance coming from health and safety experts. With some common sense and a cautious approach, we’ll all get through this together.