At some point in the very near future, whether in two weeks or two months, companies are going to have to manage building access very differently than ever before. Considerations will include the obvious, as well as some that are not-so-obvious. This blog addresses the mechanics of returning your workforce to your facilities.
White House Guidance
The White House recently issued generic guidelines for “Opening Up America Again” that cover the basics of what each state will address when issuing their own guidance. The proposal indicates there will be three phases involved. Key points for companies include:
- Phase 1
- Continue to encourage telework
- Have your employees return to work in phases
- Close common areas, or enforce strict social distancing protocols
- Strongly consider special accommodations for your “vulnerable population” employees
- Phase 2
- Only removes the “return to work in phases” guidance
- Phase 3
- Resume unrestricted staffing of worksites
Although this seems fairly straightforward, it doesn’t give specific guidance on how to implement a safety plan to re-open our worksites. Below is an outline of some things to consider as you develop a plan that works for your organization.
Who are you going to let in? Will you have half of your staff work onsite half of the time with the other half on site for the rest of the week? There is good reason to organize your staff into teams and have each team come to the office at their respective times. Each team should include a cross-section from various departments and functions. In the event someone tests positive, that team will most likely need to self-quarantine and this setup ensures you don’t lose an entire department to illness.
What about clients, vendors, and contractors? Alan Murray at Fortune Magazine indicated in his CEO Daily newsletter on April 22, 2020, indicated that many companies would be establishing “interoperability agreements,” which he states are protocols for sales and service people whose jobs depend on paying visits to clients and customers in other companies. You are definitely going to want to make sure that others who enter your building are following similar safety protocols. You will want similar assurances for your employees who visit other companies.
If you don’t already have someone, you may need to hire staff to control entry. Don’t forget that every entry point will need to be managed or you will need to designate one point of entry, with all other doors being for emergency exit only.
Are you going to screen people for illness? Non-contact thermometers are in high demand right now, so you might want to place your order now. What about masks? Are you going to provide masks when someone shows up without one, or are you going to deny entry? You may also want to ask people to use hand sanitizer at the door.
How are you going to handle deliveries and mail? Are you going to spray everything with a disinfectant before it leaves a staging area? Unfortunately, there is no clear guidance as to the level of risk with packages.
You will need to establish a policy that leaves as little room as possible for interpretation. You may even want to appoint a Chief COVID Officer who would be responsible for ensuring that all public safety guidelines and company policies are implemented and followed as well as to handle requests for exceptions. And don’t kid yourself, there will be plenty of requests for exceptions!
Everyone can quickly identify the obvious common areas: conference rooms, small meeting rooms, restrooms, kitchens, and break rooms. Don’t forget the areas around shared equipment such as copiers/printers/postage meters as well as the little areas set aside for coffee and water. You also have doorknobs, light switches, elevator buttons, and access keypads to consider.
You could consider sticking to virtual meetings even if everyone is in the building, provided your employees are equipped to do so. If not, you may want to mark specific seating zones on the conference room tables and remove the extra chairs from the room. You will also need to clean the room after every meeting.
Restrooms are tricky. It is very difficult to manage how many people are in a restroom that usually accommodates more than one person at a time. Also, you can’t really clean them after every use.
You will most likely need to declare that kitchens and break rooms are closed for the time being. Keep in mind some labor laws and union contracts require that you make break rooms available for certain employees. Union contracts will likely need to be modified. For lunch, you should go “old school” and advise people to bring their lunch in a small cooler and eat at their desks.
The only thing I can see working for shared copiers, printers, and postage meters is to provide hand sanitizer at each location, with directions to sanitize your hands after each use.
The trickiest issue of all, and the one most likely to incite a riot, is coffee! You may be OK if you already use Keurig (or similar) machines because you can ask each user to wipe them down before or after use. If you use coffee pots, I strongly recommend finding an alternative method ASAP.
Remember that your janitorial service is going to play a vital role in keeping your employees safe. While you are going to be asking staff to wipe down areas after they use them, some people won’t comply, and all of us will occasionally forget. It will be important to have someone periodically come through and sanitize the common areas.
Some portion of your staff will likely be considered part of the “vulnerable population.” Special considerations to protect them could include some or all of the following: let them continue to work from home; give them access to a less frequently used restroom; and have them attend internal meetings virtually even if everyone else is in the conference room. You should also expect that some who are offered special considerations will decline them because they won’t want to be singled out or given special treatment.
Finally, determine what you are going to do when an employee notifies you that they have tested positive for COVID-19. According to the Occupational Safety and Health Administration (OSHA), COVID-19 is a recordable illness. OSHA recently published several reports outlining steps employers can take to help protect their workforce. These reports and other COVID-19 guidelines can be found here.
As we all know, policies and procedures only work if your employees are committed to following and enforcing them. It may be beneficial to have all employees sign a “Commitment to Keep Myself and my Coworkers Safe” document to emphasize the importance of the situation.
This is a situation that is very complex and is evolving on a daily basis with no precedent for anyone to follow. Therefore, I recommend that you have your plan reviewed by an employment law attorney before implementation.