CDC Issues Guidance for Employers in Office Buildings in Response to COVID-19 Pandemic  

May 29, 2020
On May 27, 2020, the U.S. Centers for Disease Control and Prevention (the “CDC”) issued guidance on the steps
“[o]ffice building employers, building owners and managers, and building operations specialists” can take to “create a safe and healthy workplace and protect workers and clients.”
 
The CDC’s step by step guidance advises employers to:  (1) review the CDC Interim Guidance for Businesses and Employers and create a COVID-19 workplace safety and health plan; (2) check the building to see if it’s ready for occupancy before resuming business operations; (3) identify where and how workers may be exposed to COVID-19 at work; (4) develop hazard controls using the hierarchy of controls to reduce transmission among workers; (5) educate employees and supervisors about actions they can take to protect themselves at work; and (6) take actions to maintain a healthy work environment for employees and clients.
 
The CDC guidance sets forth a range of suggestions for consideration by employers as they seek to create a safe and healthy workplace and protect employees and visitors from COVID-19.  Because all workplaces and workforces are different, employers should review the CDC’s guidance, as well as other federal, state and local guidance, to determine which guidance is applicable to their circumstances. 
 
Determine if Building Is Ready for Occupancy
Before resuming business operations, evaluate the building to ensure it is ready for occupancy. Steps employers might take to determine readiness include:
  • Ensuring that ventilation systems are operating properly, including following proper start-up guidance for building heating, ventilation, and air conditioning systems that have been shut down during the closure. 
  • Increasing circulation of outdoor air as much as possible by opening windows and doors, using fans, and other methods, subject to potential safety or health risks.
  • Evaluating the building’s mechanical and life safety systems and checking for hazards associated with prolonged shutdown including mold, rodents and other pests, or stagnant water systems, and taking appropriate remedial actions.
 
Identify Possible Worker Exposure to COVID-19
Employers should conduct a thorough hazard assessment to identify workplace hazards that could increase risks for COVID-19 transmission. Such an assessment might include identifying work and common areas where employees could have contact within 6 feet of others such as meeting rooms, break rooms, cafeterias, or entry/exit points. Employers should also include all employees in the workplace, regardless of level, in communication plans. If contractors are employed in the workplace, employers should develop plans to communicate with the contracting company about any modifications to work processes and requirements for the contractors to prevent transmission of COVID-19.
 
Develop Hazard Controls to Reduce Transmission of COVID-19
Employers should develop a combination of engineering and administrative hazard controls to reduce transmission of COVID-19 among workers. Engineering controls are designed to isolate workers from the hazard whereas administrative controls are designed to change the way people work.
  • Engineering controls may include:
    • Modifying seats, furniture, or workstations to maintain social distancing of 6 feet between employees.
      • If social distancing is not an option, employers should consider installing transparent shields or physical barriers.
      • Employers should also consider arranging reception or other communal seating area chairs by covering, spacing, or removing chairs to maintain social distancing.
    • Employing methods to physically separate employees in all areas of the workplace, including meeting rooms, break rooms, parking lots, entry and exit areas, and locker rooms.
      • Using methods such as signs or tape marks placed 6 feet apart to indicate to employees where to stand when physical barriers are not possible.
      • Replacing high-touch communal items, such as coffee pots and bulk snacks, with alternatives like pre-packaged items.
    • Taking steps to improve ventilation in the building.
      • Increasing the percentage of outdoor air and considering the use of natural ventilation when environmental conditions and building requirements allow.
      • Increasing total airflow supply to occupied spaces, if possible, and disabling demand-control ventilation controls that reduce air supply based on temperature or occupancy..
      • Improving central air filtration, and considering running the building ventilation system even during unoccupied times to maximize dilution ventilation.
      • Generating “clean-to-less-clean air movement,” by re-evaluating the positioning of air diffusers and ventilators, and having staff work in areas served by “clean” ventilation zones that do not include higher-risk areas such as visitor reception.
    • Considering use of portable high-efficiency particulate air (HEPA) fan/filtration systems to help enhance air cleaning.
    • Ensuring exhaust fans in restroom facilities are functional and operating at full capacity when the building is occupied.
    • Considering use of ultraviolet germicidal irradiation (UVGI) as a supplement to help inactivate the virus.
       
  • Administrative controls may include:
    • Encouraging employees who have symptoms of COVID-19 or who have a sick family member at home with COVID-19 to notify their supervisor and stay home.
      • Separating and sending home employees who appear to have symptoms upon arrival at work or who develop symptoms during the day.
      • Continuing to have sick employees remain at home until the criteria to discontinue home isolation are met, in consultation with a healthcare provider.
      • Performing enhanced cleaning and disinfection after anyone suspected or confirmed to have COVID-19 has been in the workplace.
    • Considering the use of daily in-person or virtual health checks (e.g., symptoms and/or temperature screening) of employees before they enter the work site.
      • Implementing a policy to prevent employees from congregating while awaiting screening.
    • Staggering shifts, start times, and break times, as feasible, to reduce the density of employees in common areas.
    • Considering posting signs in parking areas and entrances that ask guests and visitors to phone from their cars to inform the administration or security when they reach the facility, to wear cloth face coverings, and to not enter the building if sick, and providing directions for visitors to enter the building at staggered times.
    • Cleaning and disinfecting high-touch surfaces, such as workstations, keyboards, telephones, handrails, printers/copiers, drinking fountains, and doorknobs.
      • Following the Guidance for Cleaning and Disinfecting to develop, follow, and maintain a plan to perform regular cleanings.
      • Providing employees with disposable wipes and other cleaning materials so they can properly wipe down frequently touched surfaces before each use.
    • Reminding employees of good hygiene practices and providing employees adequate time to wash their hands and access to soap, clean water, and single use paper towels.
    • Establishing policies and practices for social distancing.
      • Reminding employees that people may be able to spread COVID-19 even if they do not show symptoms.
      • Prohibiting handshaking, hugs, and fist bumps.
      • Limiting use and occupancy of elevators to maintain social distancing of at least 6 feet.
      • Encouraging the use of outdoor seating areas and social distancing for any small group activities.
    • Considering offering incentives to employees who use public transportation to use forms of transportation that minimize close contact with others.
      • Offering reimbursement for parking for commuting to work alone or single-occupancy rides.
      • Staggering employees’ hours so they can commute at less busy times.
      • Asking employees to wash their hands as soon as possible after their commute.
    • Posting signs and reminders at entrances and in strategic places providing instruction on hand hygiene, COVID-19 symptoms, and cough and sneeze etiquette.
      • Posting signs for non-English speakers, as needed.
      • Using no-touch waste receptacles when possible.
      • Reminding employees to avoid touching their eyes, nose, and mouth.
    • Having employees wear a cloth face covering to cover their nose and mouth in all areas of the business.
      • Employees should not wear cloth face coverings at work if they have trouble breathing, any inability to tolerate wearing it, or if they are unable to remove it without assistance.
      • Remind employees and clients that CDC recommends wearing a cloth face covering in public settings where other social distancing measures are difficult to maintain, especially in areas of significant community-based transmission.
 
Educate Employees and Supervisors
Employers should make efforts to educate employees and supervisors about actions they can take to protect themselves at work, including signs and symptoms of infection, social distancing, personal protective equipment, good hygiene practices, and staying home when ill. All communication and training by employers should be accurate and timely, easy to understand, and available in the employee’s preferred language. Employers should also provide information and training on what actions employees should take when feeling ill including information about workplace leave policies, and guidance from local and state health departments. The CDC has free posters that are available for download.
 
Maintain a Healthy Work Environment
Employers should consult the CDC Interim Guidance for Businesses and Employers to learn about more recommendations for creating new sick leave policies, cleaning, and employee communication policies to help protect workers and clients. 
 
As the COVID-19 situation continues to develop, and federal, state, and local governments issue additional guidance, employers need to be cognizant of new guidance and requirements. For more information, please visit S&C’s page regarding Coronavirus updates.