After months of disruption, organizations are eager to return to normal as part of the recovery lifecycle. For many, that means resuming operations in work facilities vacated due to local, state, and national lockdown orders.
Of course, bringing staff and operations back on premise in the midst of a pandemic isn’t without risk. What are those risks? And how do PCBUs (Persons Conducting a Business or Undertaking) mitigate them to ensure a safe return to work?
Proactive planning – like for any other potential business interruption – helps. And for this planning effort, in particular, Legal and/or Compliance representation is key. After all, businesses will be operating under the rules and regulations set out by jurisdictions and relevant health authorities (local, state, and federal) as to when it is permissible to reopen work premises.
Those directives have changed often throughout the Covid-19 crisis. They are likely to continue to evolve, as the pandemic remains fluid and unpredictable.
More specifically, jurisdictions are likely to take a phased approach to easing up on stay-at-home orders, rather than eliminate them all at once. Once those restrictions no longer apply, though, a resurgence of Covid-19 cases might trigger new closures. PCBUs must monitor the situation as it evolves – as always, situational awareness will be critical for back-to-work planning.
What’s more, it’s likely that individual jurisdictions in which PCBUs operate will or have put out guidance – or, at least, sketched out a framework – laying out what constitutes safe reopening, e.g. screening and testing, social distancing, use of personal protective equipment (PPE), and protocols for addressing reports of exposure. Return to work plans must adhere to that guidance, as part of the PCBU’s broader duty of care obligation to provide a workplace free from recognized hazards likely to cause death or serious physical harm.
Getting Facilities Management (and potentially building management) on board is also essential. After all, most regulators are recommending enhanced cleaning and disinfection of work premises before staff returns to work.
The effort won’t be completed after workers return, either. Return to work plans should also account for the likelihood that on-premise workers will test positive for Covid-19. In that eventuality, employers should be ready to once again vacate the premises and allow for another round of deep cleaning – in fact, jurisdictions might even mandate these enhanced cleanings and disinfection measures after persons who have entered the facility are suspected of having or confirmed to have Covid-19.
Even before employees test positive, plans should provide for routine environmental cleaning and disinfection, in an effort to maintain a safe working environment for employees, per best-practice guidelines. Those guidelines are likely to entail:
- Regularly cleaning and disinfecting all frequently touched surfaces in the workplace, such as workstations, keyboards, telephones, handrails, and doorknobs.
- Cleaning dirty surfaces using detergent or soap and water prior to disinfection using products certified for use against Covid-19.
- Discouraging workers from using other workers’ phones, desks, offices, or other work tools and equipment, when possible. If necessary, cleaning and disinfecting before and after use.
- Providing disposable wipes to ensure commonly used surfaces remain clean.
Planners will also want to consider whether building ventilation could be improved, so that more outdoor air circulates through the system, cutting down the risk of Covid-19 transmission. What else? Focus on the human aspects, as well. Workers without sufficient leave may be tempted to continue working with mild symptoms, rather than call in sick. Have systems in place to keep reminding workers to be vigilant, monitor their status, remind them of symptoms to watch, practice good hygiene etc.
In addition to shutting down and cleaning, implement good response procedures like worker contact tracing, speedy communications to affected workers with good advice about what symptoms to be watching for. The ability to case manage ill workers will also provide evidence of duty of care by ensuring those workers are really well before coming back and risking further infection.
And that’s not even the half of it. Mitigating safety risk when bringing employees back on premise will take time, effort, and advanced planning. For tips on how to build a customized return-to-work protocols tailored to your business, download our back-to-work playbook.