The Basics
Let's start with the basics, according to OSHA. The first step of a workplace COVID-19 Prevention Program is choosing an employee to be the "Workplace Coordinator". This person will be responsible for dealing with all COVID-19 issues on the business' behalf.
Even though the thought of being in charge of your company's Prevention Program is enough to make anyone want to call in sick, let's face it: no program is going to run itself. Besides, if it helps keep your workforce safe and healthy, we can understand why it's important to have someone in charge.
Once the Workplace Coordinator is assigned, his or her job is to develop the program based on OSHA and CDC guidance. The best way to start is by conducting a COVID-19 risk assessment. Now, if your company is large enough to have its own Internal Audit department, or if you operate in a regulated industry like health, finance or defense, you might already have a risk assessment framework available to you. For the rest of us, you should start by getting familiar with what OSHA calls the "key elements" of a COVID-19 Prevention Program:
- Assessing
your company's COVID-19 risk profile and current practices;
- Identifying
the type of factors that create risk for your employees;
- Adopting
protective steps you can take to reduce these risks; and
- Implementing
the steps you decided to adopt, including by training your workforce.
The Four P's
Fair warning: coordinating a risk assessment, or what OSHA refers to as a "Hazard Assessment", is a lot of work, and not something we can cover completely in this guide. Instead, our goal is to give you a framework for thinking about what your company's COVID-19 Prevention Program should be able to accomplish. Let's do this by breaking your goals down into four categories:
place,
people,
processes, and
protection.
Place means the physical space in and around your office. How close to one another will people be sitting. Are there opportunities to spread out? What about communal areas like meeting rooms, or areas where people are likely to remove their masks, like kitchens or cafeterias? Can you reduce the risk of transmission by upgrading your ventilation system, or improve airflow by opening windows or keeping external doors open? On the flip side, are there unnecessary gaps you can close, like raised stalls in shared bathrooms, or openings between adjacent offices? It might sound silly, but where and how will people safely rehydrate?
People means the employees, contractors and guests who share space. We recommend using a risk-based approach to accommodating your workforce, especially those employees who may be at a higher risk than others. OSHA suggests things like alternative work schedules, relocating higher-risk employees to more spacious or better-ventilated areas, and implementing clear policies for what to do if a worker becomes infected or exposed. Of course, training your personnel so they understand what's expected is critical. More on training, below.
Processes means modifications to your office routines that help reduce the risk of workplace infection. It might help to think of this in two parts: processes that are completely new, and current processes that will need to be updated. New processes include things like requiring face masks and other form of PPE as appropriate, additional routine cleaning and disinfection, and ongoing tracking to let you know how well your program is (or isn't) working. Just as important are changes to existing processes, like updating the policy on office celebrations, additional rules around the use of shared spaces, and a way for employees to escalate concerns that makes it easier for leadership to learn about potential red flags. As an example, very few of us make it a habit to tell our HR representative if we think we've been exposed to the flu, but coronavirus is a different ball game, and changes to the employee handbook are going to be expected.
Protection
means using tools like facemasks in order to suppress the spread of germs in the workplace. OSHA suggests employers provide face coverings or masks to employees, rather than allowing employees to bring their own. Why would this be the case? Making sure everyone uses the same high-quality covering, like an ASTM F3502-compliant mask, is what the CDC recommends. According to the principles of "Universal Source Control", your workplace is only as safe as the worst-quality mask. Keep in mind that PPE may be more appropriate than face coverings in some cases, but this will depend on the results of your Hazard Assessment.
Training and Education
All successful programs have one thing in common, and it's not a polished powerpoints or genuinely genius flowcharts. It's buy-in! And good luck getting buy-in without training and education. OSHA expects an effective COVID-19 Prevention Program to include training in two key areas, and they aren't necessarily what you would expect.
For starters, OSHA recognizes that there are as many incorrect facts about Coronavirus and COVID as there are sources of news, and Americans tend to get their news from a large number of sources. That's why the first part of your education program should be to get everyone on the same page about the scientific facts. This isn't always going to be easy in a workplace setting, which is why experts recommend bringing in third parties, such as local doctors or public-health policymakers. A non-baised expert can help to make sure your workforce is aligned about the basics, including why having a COVID-19 Prevention Program is so important.
The blessing of basic scientific facts is they are true for everyone. This makes it easy to use templates, like those provided by Puraka. At the same time, your company's COVID-19 Prevention Program is going to have specific details that are unique to your companies location, people and company culture, so getting your personnel on board is going to require a tailored approach. Our templates and email language will make it easier to create and communicate your plans, but ultimately the risks and controls for every workplace are different.
The Big Picture
At the end of the day, most elements of your COVID-19 Prevention Program are going to be temporary in nature. How much time and money should a business invest in putting together a process that we all hope won't be needed in the near future? And if your business is large enough to need a full-time coordinator, what does that person do afterward?
Employers and workers, even those
outside
the healthcare industry, are already being asked to identify and reduce the risk of being exposed to and/or contracting COVID-19 in the workplace. Up to this point the recommendations have been advisory in nature, but now that the Emergency Temporary Standards are published, we expect OSHA to pursue the goal of a "safe and healthful workplace" by requiring a Mask and Prevention Program nationwide.
The science is clear that COVID-19 is a highly infectious disease, one that spreads from person to person via aerosols produced when an infected person coughs, sneezes, talks or even exhales. Importantly, people who have no symptoms can still spread the virus, and we now know airborne particles carrying the virus can travel beyond six feet, especially in an indoor setting. Fortunately, after more than a year of hard lessons, we finally know how to stop it.
Visit soon for a flowchart that maps out the most important steps of your COVID-19 Prevention Program, along with templates and sample policies that make it easy to get started.
Learn more about Puraka's Workplace Mask Program and download a free attorney-drafted Facemask Policy.
Looking for more data on how different companies are approaching masking? Participate in our first-of-its-kind Workplace Mask Program Survey for the results. Survey open through May 30th.
