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With many states making decisions on how to re-open businesses amid the coronavirus pandemic, there is much to be considered about creating a safe work environment. Each company is unique, and therefore, should take the time to analyze what will work best for its business. Unprecedented territory for all of us, each business will need to create new policies, standards, and controls to drive behaviors that help keep everyone safe. And, as a byproduct of their implementation, the policies will instill confidence in employees and customers and help bring them back to the business.
At a high level, businesses need to establish a preparedness and response plan that considers guidance from federal, state, local, tribal, and territorial health agencies. To create this plan, employers will want to evaluate where, how, and to what sources workers might be exposed and then determine the controls they can put in place to mitigate risk.
Some plans and policies will be newly documented approaches necessary due to the pandemic. Policies such as an exposure and response plan that includes identification and isolation of possible infectious individuals and contract tracing. Policies for reporting and communicating illness are necessary and are probably not currently in place. Other policies will likely be based on, but appropriately updated from, the current policies of the business.
In this type of situation, it is incumbent on the business to implement a “hierarchy of controls.” Identifying and mitigating exposures to hazards before work begins is the objective of such controls. The National Institute for Occupational Safety and Health (NIOSH) offers a basic outline through its interpretation of the Hierarchy of Controls.
The hierarchy starts with the controls perceived to be most effective and moves down to those considered the least effective. As defined by NIOSH, it flows as follows:
While elimination and substitution controls are much less possible as it relates to the pandemic, there is still quite a bit for businesses to consider around engineering controls, administrative controls, and PPE. As each company is different, the hierarchy of controls should take into account guidance from CDC recommendations as well as the needs of the specific business.
The following is a framework for thinking about the controls you implement.
Engineering controls
In workplaces where they are appropriate, engineering controls reduce exposure to hazards without relying on worker behavior and can be the most cost-effective solution to implement. Engineering controls for SARS-CoV-2 include:
Administrative controls
Administrative controls are changes made to policies and procedures that change the way people work. This will likely be the category where your business does the most work to support a pandemic response. Considerations include:
PPE
PPE programs are typically the last line of defense. They may be relatively inexpensive to establish but, over the long term, can be very costly to sustain. PPE can be uncomfortable to wear and potentially introduce other hazards such as breathing restrictions for some affected workers. Consider providing PPE, such as cloth masks and gloves.
Implementation
The work doesn’t stop with the development of these new policies and controls. Once your business has established its protocols for a pandemic response, they need to be rolled out systematically to the team. You’ll want to provide each team member with role-appropriate training, education, and informational material about changes to job functions, worker health and safety, workplace controls (including PPE), and medical care in the event of a COVID-19 outbreak.
You will need to consider complexities such as a dispersed employee population, procedures and policies that differ by geography and job function, and the need to train and communicate in languages other than English.
Preparedness and communication are the keys to success when behavior change is expected. Consider online training to drive adoption and reinforcement across the workforce and include an online certification training. Learners will be able to show that they have been through the training and understand the expectations. You may want to include knowledge checks or exams to determine employee understanding of high-risk topics. Education and creating a culture of accountability across the company ensure that everyone plays their part in pandemic response.
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Norman Ford is the VP of Compliance at Skillsoft.