Environment Health and Safety Practice Area Leader and Principal
Since the beginning of the COVID-19 outbreak, Golder has been assisting clients with the identification of business risk and continuity planning options. As a global company, with offices on six continents, we have seen the impact that this unprecedented event is having on our people, clients and communities. Because we have been working through this crisis since the first appearance of COVID-19 in mainland China, we have gained hard-won experience concerning how to navigate during a pandemic.
There are simple and strategic steps that organizations must take when responding to the changing conditions that this outbreak presents. Below you’ll find 10 things business leaders should consider as they plan for what’s happening now and what comes next:
1. Be prepared to assess, manage and document your risk
As businesses continue to operate and employees’ exposures outside the workplace cannot be controlled, risk must be recognized and managed. Public health agencies will often provide guidance.
For example, in the United States, the Centers for Disease Control and Prevention (CDC) and the Occupational Safety and Health Administration (OSHA) have recommended that businesses identify an employee’s risk of contracting COVID-19 against their daily work activities. Recognizing exposures within the workplace could help mitigate the risk by implementing modified work practices and policies within the organization.
Document what you do now, even during times when guidance and recommendations are constantly being updated with new information. These records will be important down the road when questions regarding due diligence and compliance will likely come up.
2. Understand your need for a medical surveillance program
Given the fact that COVID-19 can affect all industries regardless of activities conducted, companies will need to assess and determine the applicability of and need for a medical surveillance program. Therefore, employers must thoroughly understand the occupational laws and standards that may trigger the need for medical surveillance, including the need to verify that workers are medically fit to use personal protective equipment that may now be required to do their job.
3. Determine the best way to protect your employees
To continue with their duties, many employees require additional protection. As an employer, you must not only take the proper steps to protect your employees, but you need to do so in accordance with current laws and regulations, especially with regard to respiratory protection. Selecting proper respiratory protection based on the employee’s job duties and exposure, and ensuring proper fit, are key.
4. Develop or update your work-from-home policies
Many governmental authorities are implementing and enforcing shelter-in-place or stay-at-home practices. To continue doing business, companies must develop or update their work-from-home policies to ensure compliance with applicable occupational laws and reducing injury and illness claims down the road. Because some researchers indicate the need to practice some level of social distancing intermittently for the foreseeable future, relevant policies and procedures need to be clarified now.
5. Develop or update return-to-work policies
As employees recover from time off as a result of a suspected or confirmed COVID-19 illness, protocols should be in place to receive the employee back into the workplace while also confirming that the individual does not present symptoms and has been cleared either by a medical professional or by local authorities. Employee screening for temperature and requiring the use of masks may become a normal way of life, at least initially. Make sure you have site and job specific questionnaires to help document site re-entry procedures. You may also need to determine at-work isolation protocols for a period, immediately after the employee is reintegrated to the workplace.
6. Implement industrial hygiene best practices for personal protective equipment
As the demand for personal protective equipment (PPE) continues, employers facing shortages may be instructed by regulatory agencies to reuse PPE or use expired PPE. If this becomes the case, it is imperative that you establish and document disinfection protocols and PPE reuse criteria. These disinfection and reuse protocols should be analyzed carefully in conjunction with an employee’s job specific exposure. Lack of strategic planning and training in the use of PPE could result in unprotected employees.
7. Confirm your buildings are suitable for re-occupancy
Enhanced cleaning and disinfection of your workplace will be necessary following a confirmed or suspected case of COVID-19. Employers will need to develop or review site-specific cleanup and disinfection protocols to ensure they are consistent with current best practice guidance, and conduct cleanup and disinfection procedures at the workplace. It will also be important to conduct on-site visual inspections and testing to determine cleanliness prior to re-occupancy.
8. Devise a plan to keep empty buildings safe
Enhanced cleaning and disinfection protocols are important, but re-occupying buildings after mandatory shut-down orders requires continuous, minimum maintenance and operations of critical building systems in order to avoid moisture problems and mold growth, as well as the amplification of waterborne pathogens such as Legionella in cooling towers and potable water distribution systems. It is important your building engineers and facility staff review current operations of heating ventilation and air-conditioning (HVAC) and water distributions systems to ensure Indoor Environmental Quality (IEQ) within the building is properly maintained while temporarily shut down. This may also include conducting pre-occupancy risk assessments, including testing the IEQ and water systems.
9. Rethink building design post COVID-19
This outbreak is showing us that buildings can play an important role in minimizing the risks presented by different modes of disease transmission. In fact, what was once considered acceptable IEQ, may no longer be satisfactory, requiring new approaches to design and best practices as a way to improve IEQ. With that in mind, we may see building designs begin to incorporate more touchless sensors and even artificial intelligence (AI) technology to reduce the transmission of disease.
Building design may also begin to reflect the fact that IT improvements have advanced working remotely. As companies look to minimize real estate costs with design trends like hot desking and open-floor-plan offices, building designers could look to incorporate anti-microbial coating and materials from healthcare in everyday spaces. Because the benefits of a healthy building show up in terms of improved productivity, employee retention, employee recruitment, and fewer sick days, heightened awareness of a building’s design and its ability to impact health may increase demand for better-performing, better-designed workspaces.
10. Weigh your options from a point of strength
When it comes to protecting employees’ safety, it is imperative to get protocols right. Since the outbreak started, businesses are being bombarded with offers of quick fixes for urgent needs. Often, these quick fixes are not the best fit. Our clients are finding that careful evaluation by licensed professionals can deliver solutions that work within their current framework. As we have worked to help our clients navigate this global pandemic, our EHS team has been working alongside our Digital Solutions team to leverage our clients’ current technology — or help them choose the right tool — to manage critical data, processes, and other relevant information.
Golder’s team of Industrial Hygienists, Toxicologists, Safety Professionals, EHS, and EMIS software professionals can support you in developing and implementing programs and protocols that can help you protect your employees and your business as you navigate the effects and aftereffects of COVID-19.
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