Supporting Employees' Health and Safety: Workplace Measures and Policies

Businesses and employers are crucial in curbing and impeding the transmission of SARS-CoV-2 within the Workplace. Employers need to develop comprehensive plans encompassing preparedness, response, and control measures, considering various workplace factors. These factors include the feasibility of implementing social distancing measures, the ability to stagger employee shifts, the level of interaction employees have with the public in person, the possibility of telework arrangements, the geographical isolation of the Workplace, the presence of congregate housing for employees, the proportion of employees at higher risk for severe illness, sick leave policies, and the priority of maintaining uninterrupted operations. Moreover, employers should consider the overall level of COVID-19 disease transmission within their local communities.

Businesses and employers are encouraged to collaborate with state and local health officials to make informed decisions and respond appropriately, seeking up-to-date and accurate information. Such information will guide public health officials in determining community-level strategies based on local conditions.

As an employer, when resuming normal or phased activities following a business interruption, it presents an opportune moment to revise and update your COVID-19 preparedness, response, and control plans. It is essential for all employers to implement a customized plan specific to their Workplace. This pandemic essay plan should identify areas and job tasks with potential exposure to SARS-CoV-2 and incorporate control measures to eliminate or minimize these exposures. Open communication with employees regarding planned changes and soliciting their input is crucial. Effective dissemination of important COVID-19 information should involve collaboration with employees and unions.

For comprehensive guidelines on mitigating and preventing the spread of COVID-19 in the Workplace, refer to the OSHA Guidance on Mitigating and Preventing the Spread of COVID-19 in the Workplace. This resource provides information on protecting workers based on their exposure risk. It is important to note that employees can transmit COVID-19 even if they are asymptomatic.

All employers must consider the most effective measures to reduce the spread of SARS-CoV-2 and mitigate the impact within their workplaces. This entails activities to prevent and reduce transmission among employees, maintain healthy business operations, and foster a safe work environment. Stay updated on COVID-19 regulations, guidance, and recommendations from federal, state, and local public health authorities, and ensure that workers have access to this information. Regularly consult the CDC COVID-19 website for the latest updates.

Actively encourage sick employees to remain at home.

Employees displaying symptoms should inform their supervisor and stay home. The CDC recommends testing for individuals with any indications or signs of COVID-19 and for all close contacts of individuals with COVID-19.

Employees who are sick with COVID-19 should isolate themselves and adhere to the CDC's recommended steps. Similarly, employees who are asymptomatic or pre-symptomatic but have tested positive for SARS-CoV-2 infection should also isolate themselves and follow the CDC's recommended guidelines. Employees should only return to work after meeting the criteria to discontinue home isolation in consultation with healthcare professionals.

If employees are well but have a household member with COVID-19, they should inform their supervisor and follow the CDC's recommended precautions.

Employers are encouraged to implement flexible and supportive policies, including non-punitive paid sick leave, as part of a comprehensive approach to prevent and reduce transmission among employees. Certain employees may be eligible for leave under the Family Medical Leave Act (FMLA) or the Families First Coronavirus Response Act.

Consider conducting daily health checks, either in-person or virtually, such as symptom and temperature screenings, before employees enter the premises. Follow the guidelines of state and local public health authorities and, if available, consult your occupational health services. It is important to note that screening and health checks are not substitutes for other protective measures like social distancing, mask-wearing (unless respirators or facemasks are required), and engineering controls, including proper ventilation. Symptom and temperature screenings cannot identify asymptomatic individuals or those who are pre-symptomatic.

For virtual health checks, encourage individuals to self-screen before arriving at the Workplace. An electronic monitoring system could be implemented where employees report their absence of fever and COVID-19 symptoms, no prior diagnosis of SARS-CoV-2 infection in the last ten days, no exposure to individuals with SARS-CoV-2 infection during the previous 14 days, and no ongoing evaluation for SARS-CoV-2 infection, such as pending viral tests.

When conducting in-person health checks, ensure they are performed safely and respectfully while maintaining social distancing among workers entering the screening area. Workers should not proceed past the screening area if any of the following apply:

• Symptoms of COVID-19
• Fever of 100.4 degrees Fahrenheit (oF) or higher or feeling feverish
• Undergoing evaluation for SARS-CoV-2 infection (such as pending viral test)
• Diagnosis of SARS-CoV-2 infection in the previous ten days
• Close contact with someone with SARS-CoV-2 infection in the last 14 days

Adhere to guidance from the Equal Employment Opportunity Commission regarding the confidentiality of medical records obtained during health checks. To prevent stigma and discrimination, ensure employee health screenings are as private as possible. Avoid making risk determinations based on race or country of origin, and maintain the confidentiality of each individual's medical status and history.

Take appropriate measures to protect personnel conducting in-person screenings from potential exposure to infectious individuals entering the facility. This can be achieved through social distancing, physical barriers, and mask-wearing. If social distancing or walls are not feasible during screening, personal protective equipment (PPE) can be used by screeners when they are within 6 feet of an employee. However, it is essential to note that relying solely on PPE is less effective and may be challenging due to shortages and training requirements. Ensure that screeners are adequately trained on the correct use and reading of thermometers according to manufacturer standards, as improper calibration and service can lead to inaccurate temperature readings.

Below are examples that can be integrated into the in-person screening process while maintaining the word count:

Social Distancing:

• Ask employees to self-measure their temperature either before arriving at the Workplace or upon arrival. Upon their arrival, maintain a distance of at least 6 feet from the employee and:
• Request the employee to confirm a temperature below 100.4o F (38.0oC).
• Conduct a visual assessment of the employee for signs of illness, such as flushed cheeks, inappropriate sweating for the ambient temperature, or difficulty performing regular tasks.
• Screening staff and employees being screened should wear masks. If a distance of 6 feet can be maintained, screening staff do not need to wear additional personal protective equipment (PPE).

Barrier/Partitional Controls:

• During the screening, the screener should stand behind a physical barrier, like a glass or plastic window or partition, that shields the face and mucous membranes from respiratory droplets. Upon arrival, the screener should wear a mask and wash hands with soap and water for at least 20 seconds. For each employee:
• Perform a visual inspection of the employee for signs of illness, including flushed cheeks, inappropriate sweating for the ambient temperature, or difficulty performing regular tasks.
• Conduct temperature and symptom screening.
• Put on disposable gloves.
• Check the employee's temperature while ensuring the screener's face remains behind the barrier.
• Clean and disinfect contact thermometers according to the manufacturer's instructions and facility policies. Non-contact thermometers should also be cleaned and disinfected per the manufacturer's instructions and facility policies.
• Remove and discard gloves, then wash hands with soap and water for at least 20 seconds between each employee. If soap and water are unavailable, use hand sanitizer with at least 60% alcohol.
• Change gloves if soiled or damaged; gloves should only be worn continuously for up to four hours.

PPE:

• Screeners should be trained in proper donning, doffing, and disposal of all PPE. Upon arrival, the screener should wash their hands with soap and water for at least 20 seconds or use hand sanitizer with at least 60% alcohol. They should wear a facemask or respirator, eye protection (goggles or disposable face shield), and a single pair of disposable gloves. Extended use of facemasks/respirators and eye protection may be considered. A gown may be necessary if extensive contact with an employee is anticipated.
• Perform a visual inspection of the employee for signs of illness, including flushed cheeks, inappropriate sweating for the ambient temperature, or difficulty performing regular tasks.
• Conduct temperature and symptom screening.
• If conducting temperature checks on multiple individuals, the screener should change gloves and wash hands or use hand sanitizer with at least 60% alcohol between each employee.
• Clean and disinfect contact thermometers according to the manufacturer's instructions and facility policies. Non-contact thermometers should also be cleaned and disinfected per the manufacturer's instructions and facility policies.
• If the screener does not have physical contact with the individual and disposable or non-contact thermometers are used, gloves should not be changed before the next check. Gloves should be worn continuously for up to four hours. After removing gloves, screeners should wash their hands with soap and water for at least 20 seconds or use hand sanitizer if soap and water are unavailable.
• Any PPE, including gloves, facemask, respirator, eye protection, and gown, should be removed and discarded if soiled or damaged.

Remember to follow proper procedures to ensure the safety and effectiveness of the screening process.

Consider integrating SARS-CoV-2 testing into workplace preparedness, response, and control plans.

When formulating an approach to testing, refer to the guidance applicable to select non-healthcare workplaces. This may involve conducting initial testing of all workers before entering the Workplace, implementing periodic testing at regular intervals, or focusing on testing new workers or those returning from extended absences such as medical leave or furlough. Alternatively, a combination of these approaches can be considered. Factors such as testing availability, previous test results, and the level of community transmission can help determine the appropriate interval for periodic testing.

Identify potential workplace exposures to individuals with COVID-19 and implement appropriate control measures.

As employers are responsible for providing a safe and healthy workplace, conduct a thorough hazard assessment to identify workplace hazards related to COVID-19. Employ a combination of control measures from the hierarchy of controls to mitigate the spread of COVID-19. These measures include engineering controls, workplace administrative policies, and personal protective equipment (PPE) to safeguard workers against identified hazards (see table below).

Perform a comprehensive hazard assessment to determine the presence or likelihood of workplace hazards and identify specific job duties requiring controls or PPE. In cases where engineering and administrative controls cannot be implemented or are insufficiently protective, employers are obligated to:

• Assess the necessary PPE for specific job duties.
• Provide appropriate PPE to workers at no cost.
• Train workers on the correct use of PPE.

Ensure all employees adhere to mask-wearing guidelines outlined by the CDC, OSHA, and relevant state or local requirements. This applies even if the hazard assessment determines workers do not require PPE such as respirators or medical facemasks for protection.

CDC recommends wearing a mask that securely covers the nose and mouth, limiting the release of respiratory droplets and aiding in protecting co-workers and the general public. It is important to note that masks should not be placed on children under 2, individuals with breathing difficulties, or those who are unconscious, incapacitated, or unable to remove the cover without assistance.

While masks can help prevent unknowingly infected individuals from spreading the virus, they also offer some level of protection to the wearer. However, veneers do not provide the same level of protection as medical facemasks or respirators and should not serve as substitutes for required or recommended PPE in the Workplace.

Remind employees and customers to follow CDC recommendations by wearing masks in public settings and in proximity to individuals outside their household, especially when maintaining social distancing becomes challenging. It is important to emphasize that wearing masks does not replace the need for social distancing, and both measures should be practiced simultaneously.

Refer to the OSHA COVID-19 web page for comprehensive information on protecting workers from potential SARS-CoV-2 exposures, including employer guidance based on exposure risk.

Separate employees who are unwell.

If employees exhibit symptoms upon arrival at work or become sick during the day, promptly isolate them from other employees, customers, and visitors and send them home. Establish a procedure for safely transporting employees who fall ill while at work. They may require transport home or to a healthcare facility. Take appropriate action if an employee is suspected or confirmed to have COVID-19.

Adhere to the CDC's recommendations for cleaning and disinfection:

• Before disinfection, clean soiled surfaces using soap and water.
• Utilize products that meet EPA criteria for effectively combating SARS-CoV-2, the virus responsible for COVID-19, and are suitable for specific surfaces.
• Always wear suitable gloves and gowns under the chemicals used when cleaning and disinfecting.
• Ensure sufficient ventilation when using cleaning and disinfection products to prevent inhalation of toxic fumes.
• Additional personal protective equipment (PPE) may be necessary depending on the setting and disinfectant used. Consult the manufacturer's instructions for proper usage of each product.

Identify employees who may have been exposed to the virus and determine if they require additional precautions

Employers have a responsibility to manage the return-to-work process for potentially exposed workers in a manner that prioritizes their health and the health of their co-workers and the general public. Inform employees if they have had close contact (within 6 feet) with a confirmed or suspected case of SARS-CoV-2 infection in the Workplace while maintaining confidentiality as required by the Americans with Disabilities Act (ADA). Most workplaces should follow the Public Health Recommendations for Community-Related Exposure. The recommended approach is for exposed employees (close contacts) to quarantine for 14 days, telework if possible, and self-monitor for symptoms.

This approach minimizes the risk of post-quarantine transmission and aligns with the most extensive experience. While the CDC recommends a 14-day quarantine, alternatives are provided for shorter durations that may end after 7 or 10 days, depending on certain conditions. These options are outlined in the Options to Reduce Quarantine for Contacts of Persons with SARS-CoV-2 Infection Using Symptom Monitoring and Diagnostic Testing.

Shortening the quarantine period may enhance adherence to public health recommendations. However, it may be less effective in preventing COVID-19 transmission than the currently recommended 14-day quarantine. Workplaces can consider these alternative quarantine measures to address staffing shortages, but there are other options.

Employers should be aware that reducing the duration of quarantine carries additional transmission risk. It's essential to consider workplace characteristics when determining if the extra risk is acceptable, such as community transmission levels, the ability to maintain social distancing, the proportion of employees at higher risk for severe illness, and the priority of ensuring business continuity.

Employers should advise workers to monitor for symptoms and self-isolate immediately if any symptoms arise within the 14 days of exposure. Consistent adherence to all recommended mitigation strategies (e.g., mask-wearing, social distancing, hand hygiene, cleaning and disinfection, and proper ventilation) is crucial.

Implementing testing strategies can complement efforts to reduce transmission in the Workplace. Serial testing conducted over time may detect infections among workers with exposures more effectively than one-time testing. Critical infrastructure workplaces should adhere to COVID-19 Critical Infrastructure Sector Response Planning and guidance on Testing Strategy for Coronavirus (COVID-19) in High-Density Critical Infrastructure Workplaces after a COVID-19 Case is Identified.

Educate employees on protective measures at work and home.

Encourage employees to adhere to any new policies or procedures related to illness, cleaning and disinfection, work meetings, and travel. Instruct employees to:

• Stay home if they are unwell, except for seeking medical care, and familiarize themselves with appropriate actions when feeling sick.
• Inform their supervisor if a household member is sick with COVID-19 and learn the necessary steps.
• Wear a mask in public settings and when in the presence of non-household members, particularly when maintaining social distancing, is challenging. Note that veneers should not be used for children under 2, individuals with breathing difficulties, or those who are unconscious, incapacitated, or unable to remove the mask without assistance.
• Frequently wash their hands with soap and water for at least 20 seconds, or utilize hand sanitizer containing at least 60% alcohol if soap and water are not available. Emphasize that soap and water should be used instead of hand sanitizer if hands are visibly dirty. Critical moments for hand hygiene include:

• • Before and after work shifts
  • Before and after work breaks
  • After blowing their nose, coughing, or sneezing
  • After using the restroom
  • Before eating or handling food
  • After touching or adjusting cloth face coverings
• Avoid touching their eyes, nose, and mouth with unwashed hands.
• Cover their mouth and nose with a tissue when coughing or sneezing, or use the inside of their elbow. Discard used tissues in touch-free trash cans and immediately wash hands with soap and water for at least 20 seconds. If soap and water are unavailable, use a hand sanitizer containing at least 60% alcohol. Refer to the CDC website for further guidance on coughing and sneezing etiquette.
• Practice regular cleaning and disinfection of frequently touched surfaces and objects, such as workstations, keyboards, phones, handrails, and doorknobs. Before disinfection, clean dirty surfaces with soap and water. For disinfection, utilize products that meet EPA criteria for effectiveness against SARS-CoV-2, the virus-causing COVID-19, and are suitable for specific characters.
• Avoid using other employees' phones, desks, offices, or work tools and equipment whenever possible. If usage is necessary, clean and disinfect them before and after use.
• Practice social distancing by avoiding large gatherings and maintaining a distance of at least 6 feet from others whenever feasible. Provide support for employees who use public transportation or ride-sharing for their commute:
• Consider offering incentives for employees to use transportation methods that minimize close contact with others (e.g., biking, walking, driving alone, or with household members). Encourage employees to follow CDC guidance on protecting themselves while using transportation. Allow flexible scheduling for employees to commute during less crowded times. Remind employees to clean their hands as soon as possible after their trip.
• Maintain healthy business operations:
• Appoint a workplace coordinator responsible for handling COVID-19 matters and their impact on the Workplace. Implement flexible and supportive sick leave policies:
• Ensure sick leave policies are flexible, non-punitive, and aligned with public health guidelines, and communicate these policies effectively to employees. Maintain flexibility for employees to stay home and care for sick family members or children due to school and childcare closures. Consider options such as advances on future sick leave and sick leave donation programs. Take into account the eligibility of employees for leave under the Family Medical Leave Act (FMLA) or the Families First Coronavirus Response Act.

Employers with fewer than 500 employees can claim 100% tax credits for COVID-19 paid leave provided under the Families First Coronavirus Response Act until March 31, 2021, up to specified limits. Consider implementing non-punitive "emergency sick leave" policies for employers without existing sick leave provisions. Do not require a COVID-19 test result or a healthcare provider's note for employees who are suffering to validate their illness, qualify for sick leave, or return to work. While the Americans with Disabilities Act allows employers to request a doctor's note to verify an employee's fitness to return to work, be mindful that healthcare facilities may be overwhelmed and unable to provide documentation promptly.

Most individuals with mild COVID-19 can recover at home following CDC recommendations for discontinuing home isolation and returning to work. Refer to the S. Equal Employment Opportunity Commission (EEOC) guidance on Pandemic Preparedness in the Workplace and the Americans with Disabilities Act to ensure compliance and take appropriate measures to protect workers based on CDC guidance. Review human resources policies to ensure alignment with public health recommendations and existing state and federal workplace laws. For further information on employer responsibilities, consult the Department of Labor's and the Equal Employment Opportunity Commission's websites.

Connect employees to available Employee Assistance Program (EAP) resources and community services as needed. Additional support may be required to help employees manage stress and cope with various challenges.