As Michigan gets back to work, it is crucial to maintain a safe work environment for employees and for any members of the public that you and your client companies may encounter. Business owners are also required to have a written preparedness and response plan, per EO 2020-59.
“Developing a COVID-19 preparedness and response plan, consistent with recommendations in Guidance on Preparing Workplaces for COVID-19, developed by the Occupational Health and Safety Administration and available at https://www.osha.gov/Publications/OSHA3990.pdf. Such plan must be available at company headquarters or the worksite.”
This SBAM web page (https://www.sbam.org/Resources/COVID-19-Resources/Get-Back-to-Work-Safely-Tips-and-Resources?fbclid=IwAR0T83E-myfZakDpcZnn6M3LfwiuFMVJ4_hPIXT3kOfwwICfuz4Tk_sXN8Q
) should serve as a guide and checklist to help guide you through the creation of a preparedness plan and getting back to work safely. Please check it regularly as it will be updated it with new guidance from the State of Michigan and CDC.
General Guidance on Reopening
Under the provisions of the Occupational Safety and Health Act of 1970 (OSH Act), employers must provide a workplace free from recognized hazards that are causing, or are likely to cause, death or serious physical harm to employees regardless of the size of business. Employers with more than ten employees and whose establishments are not classified as a partially exempt industry must record work-related injuries and illnesses using OSHA Forms 300, 300A and 301.
Reinforce key messages
, such as:
Make sure that your federal Labor Law posters are on display in the workplace.
- Encouraging your employees to stay home if they feel sick
- Using cough and sneeze etiquette
- Practicing hand hygiene
The DOL issued a new poster that is to be displayed beginning April 1, 2020. You may have provided an electronic version to employees that were working remotely at the time, but you also need to have it on display at your workplace. Click here for a PDF of the poster.
Additionally, the U.S. Department of Labor's Occupational Safety and Health Administration (OSHA) has issued a new poster listing steps all workplaces can take to reduce the risk of exposure to coronavirus. The poster highlights 10 infection prevention measures every employer can implement to protect workers' safety and health during the coronavirus pandemic. Safety measures include
May an employer administer a COVID-19 test (a test to detect the presence of the COVID-19 virus) before permitting employees to enter the workplace?
- Encouraging sick workers to stay home;
- Establishing flexible worksites and staggered work shifts;
- Discouraging workers from using other workers' phones, desks and other work equipment; and
- Using Environmental Protection Agency-approved cleaning chemicals with label claims against the coronavirus.
The ADA requires that any mandatory medical test of employees be "job related and consistent with business necessity." Applying this standard to the current circumstances of the COVID-19 pandemic, employers may take steps to determine if employees entering the workplace have COVID-19 because an individual with the virus will pose a direct threat to the health of others. Therefore an employer may choose to administer COVID-19 testing to employees before they enter the workplace to determine if they have the virus.
Consistent with the ADA standard, employers should ensure that the tests are accurate and reliable. For example, employers may review guidance from the U.S. Food and Drug Administration about what may or may not be considered safe and accurate testing, as well as guidance from CDC or other public health authorities, and check for updates. Employers may wish to consider the incidence of false-positives or false-negatives associated with a particular test. Finally, note that accurate testing only reveals if the virus is currently present; a negative test does not mean the employee will not acquire the virus later.
Based on guidance from medical and public health authorities, employers should still require - to the greatest extent possible - that employees observe infection control practices (such as social distancing, regular handwashing, and other measures) in the workplace to prevent transmission of COVID-19.
Personal Protective Equipment (PPE) Guidance
Provide protection supplies where appropriate including:
Health Screening Guidance
- Hand sanitizer – consider putting this in various areas of your office or facility
- Sanitizer for surfaces such as door handles, elevator buttons, computer keyboards, tools and other surfaces that are commonly touched by multiple people
- Provide soap and water, tissues, and no-touch disposal receptacles for use by employees.
- Provide cloth face coverings or surgical style masks and face shields where appropriate
- Provide gloves and gowns where appropriate
- Touchless thermometers for taking employee temperatures
As public health experts and doctors learn more about COVID-19, the list of associated systems may grow or change. Employers should rely on the CDC and reputable medical sources for guidance on emerging COVID-19 symptoms. These sources may guide employers when choosing questions to ask employees to determine whether they would pose a direct threat to health in the workplace. For example, additional symptoms beyond fever or cough may include new loss of smell or taste as well as gastrointestinal problems, such as nausea, diarrhea, and vomiting.
Check with your County Health Department to determine if they have issued an emergency order or other guidance to control the spread of COVID-19. Consider asking employees to answer questions like those posed in this example from the Ingham County Department of Health before they are permitted to enter your workplace.
Workplace Checklist: (http://www.hd.ingham.org/Portals/HD/Home/Documents/cd/coronavirus/ICHDWorkHealthChecklist2.pdf
Workplace Screening: (http://www.hd.ingham.org/Portals/HD/Home/Documents/cd/coronavirus/ICHDWorkHealthScreening2.pdf
The COVID-19 Employee Health Screening Form from the Society of Human Resources Management is another resource.
Pay attention to your employees. Separate employees who appear to have acute respiratory illness symptoms from other employees and send them home immediately. Restrict their access to the business until they have recovered.
Workplace Cleaning Guidance
Frequently perform enhanced cleaning of commonly touched surfaces, such as workstations, countertops, railings, door handles, and doorknobs. Use the cleaning agents that are usually used in these areas and follow the directions on the label. Provide disposable wipes so that commonly used surfaces can be wiped down by employees before each use.
See this CDC guide for tips on cleaning and disinfecting your workplace. (https://www.cdc.gov/coronavirus/2019-ncov/community/disinfecting-building-facility.html
See this CDC guide for tips on keeping the workplace safe. (https://www.cdc.gov/coronavirus/2019-ncov/community/stay-safe.html
Cashless Payment Transactions
If your business is in retail, food service, or other industries that require a product or service charge, you might want to think about how you can accept completely cashless payments.
Distancing/Queueing In Your Workplace
- Apple Pay
- Paying online
- Paperless receipts
- Ability to have customers swipe/insert their own card
Look around your facility. Can you limit the number of employees using your breakroom, restroom, common areas and other places within your environment where employees gather?
- Mark off six-feet of space
- Use rope and stanchions to set up a queue, similar to what you would experience in an airport TSA line
- Create a system for one-way pedestrian traffic patterns