Authored by: Carol A. Sigmond
CDC developed draft guidance to assist employers in reopening while making reasonable and effective efforts to contain the coronavirus that spreads COVID-19. See infra While the draft guidelines are targeted to services that attract groups of people in close contact, there are some general principles that will help many commercial offices and businesses to reopen safely.
As you will see, there appear to be four principles underpinning these guidelines: communication and training, social distancing, disinfecting and contact tracing. The guidance varies based on the phase of gating criteria that has been achieved. See infra for the Gating Criteria
a) Social Distancing
The draft guidance encourages social distancing. The guidelines recommend people stay at least 6 feet apart. This applies in rest rooms, elevators, lobbies and hallways. Additionally, the guidelines recommend making changes to the work space to increase safety, such as setting up designated routes in common areas or installing sneeze guards or relocating staff. Common rooms such as break rooms should be closed or the use of these areas be scheduled.
The draft guidance recommends that everyone should wash their hands with soap and water, for 20 seconds, regularly. If soap and water are not available then workers should use hand sanitizer.
c) Wearing Masks
The draft guidance urges that everyone to wear masks. The guidelines recommend face coverings over the nose and mouth , unless face shields are required. Anyone unable to wear a mask should be encouraged to telecommute.
d) Signage and Communication
The draft guidelines recommend that signage be placed in the work place to show how to stop the spread of corona virus. These signs should encourage: the proper procedure for wearing and removing face masks; correct handwashing procedure; and other guidance on preventing the spread of the disease.
e) Proper Protection for Workers
The draft guidelines recommend making masks, gloves, hand sanitizer, disinfectant, including wipes, and no-touch trash cans available. The guidelines also recommend that work spaces hallways, lobbies, common areas, and restrooms be cleaned and disinfected regularly. There are two other aspects of worker protection being flagged by the CDC. First, ensuring that all domestic water systems are cleaned and free from Legionnaires disease, which lives in stagnant water. Second, all building HVAC systems must be cleaned and disinfected before reopening and periodically thereafter.
f) Sensible Schedules
The draft guidelines recommend scheduling that will allow for contact tracing if someone becomes infected with the corona virus. This includes: assigning shift schedules that have workers who are able to telecommute continue to do so at least in part and assigning workers to groups and maintain those groups to the extent possible and avoid allowing different groups from comingling.
g) Flexible Sick Leave and Telecommuting
The guidelines encourage having workers telecommute if they are feeling ill. The days of our powering through colds and seeming minor illnesses to go to work are over. The CDC is asking that we self-quarantine if we have any possible symptoms of COVID-19. In addition, vulnerable workers, including those over age 65, or suffering from certain underlying medical conditions, such as diabetes, chronic lung disease, moderate to severe asthma, severe high blood pressure or heart conditions, or chronic liver or kidney disease should be more cautious in returning to work. To the maximum extent possible, these employees should continue to telecommute until the virus is further contained.
h) Limits on Meetings, Travel, Sharing Tools or Equipment, or Sharing Spaces
The guidelines encourage limits on in person meetings, travel, sharing of tools, equipment or confined spaces. The reasons for these limitations appear to be two-fold, containing the spread of the virus and allowing for contact tracing should someone become ill with the virus.
The draft guidelines encourage training for everyone in the work place respecting containing coronavirus. The training should be targeted to specific conduct (wearing masks, handwashing, social distancing, etc. ) that will help avoid contracting or spreading the virus. Employers should consider video training and signage as well as distribution of handouts.