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:
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.
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.
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