Creating A Safe Work Environment For A Return To Business During Pandemic Response
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:
- Elimination – Completely eliminate the hazard. This is the most effective control that can be implemented, but it is also one of the most challenging.
- Substitution – Replace the hazard with a non-hazardous object, device, or substance.
- Engineering controls – Change equipment to isolate people from the hazard.
- Administrative controls – Make process and policy changes that impact the way people work to cut down on exposure to the hazard.
- PPE – Use Personal Protective Equipment to protect the worker from the hazard.
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.
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:
- Upgrading technology for seamless, reliable remote work and encouraging its use to minimize meetings and travel
- Adding high-efficiency air filters or otherwise increasing ventilation rates in the work environment.
- Installing barriers, partitions, or ropes to separate employees from public or building occupants. Plexiglass screens, sneeze guards, theater ropes and stanchions, and hazard warning tape are all examples that may apply.
- Replacing frequently-touched equipment with hands-free versions, such as hands-free trash receptacles. Add sensors and no-touch technology for hands-free operation of doors, lighting, elevators, security systems, audio/visual equipment, height-adjustable tables, and task lights to cut down on the spread of germs.
- Installing mechanisms that support contactless pickup and delivery of products to customers.
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:
- Instituting a remote work policy to eliminate the opportunity for exposure in the workplace. A policy like this may currently exist but require updating and should include specifics on the type of work that can be done remotely and the official procedure for requesting remote work.
- Implementing new workplace flexibilities and protections that make employees more willing to comply with efforts to eliminate exposure to others. Updating sick and absence policies can help to ensure sick employees to stay home. Flexible sick leave policies, consistent with public health guidance, and policies that permit employees to stay home to care for ill family members are helpful. Eliminate the need for a healthcare provider’s note for employees who may beinfected with an acute respiratory illness.
- Implementing shift and schedule changes, such as staggered work shifts and breaks, eliminating the use of time clocks and timecards, and rotating weeks between home and office to cut down on interaction between people. Downsizing operations to have fewer people physically in the space and support social distancing guidelines is also a consideration.
- Adjusting employees’ work areas by eliminating desk and equipment sharing, requiring cleaning, or moving workstations to increase separation distance between workers.
- Establishing basic infection prevention measures for hygiene (hand washing, respiratory etiquette), updating the frequency of housekeeping practices, and use EPA-Registered Disinfectants from List N can also help mitigate the risk of infection. All employees should have training in disinfection procedures for specific operations, facilities, and work areas.
- Instituting new customer interaction guidelines like directing customer traffic through the workplace with one-way traffic patterns or limiting the number of customers in any area at one time.
- Establishing new meeting protocols that include no handshake greetings, remaining six feet apart or using video or telephone conferencing instead of in-person client meetings
- Retooling travel policies to start with essential travel only and defining what that is. Discontinue non-essential travel to locations with ongoing COVID-19 outbreaks. Regularly check CDC travel warning levels at www.cdc.gov/coronavirus/2019-n... workers with up-to-date education and training on COVID-19 risk factors and protective behaviors (e.g., cough etiquette and care of PPE).
- Installing signage to communicate social distancing, cough and sneeze etiquette, proper hand hygiene and control, and other critical procedures.
- Implementing employee screening procedures, such as taking temperatures, verbal and visual screening for symptoms, measuring potential exposure to COVID-19 or administering a COVID-19 test to detect the presence of the virus, before permitting employees to enter the workplace. (The EEOC also reminds employers they must take steps to ensure the tests are accurate and reliable and should refer to federal guidance outlining safe and effective methods.)
- Implementing screening procedures with customers and the public with the intent to minimize exposure to the public, e.g., a hair salon may perform health and travel screening with the customer by phone first, and reconfirm at the time of appointment, and require the customer to wear a mask.
- Instituting PPE policies and training workers who need to use protecting clothing and equipment on how to put it on, use and wear it, and remove it correctly in their current and potential duties. Training material should be easy to understand and available in the appropriate language and literacy level for all workers.
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.
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.