COVID-19 Return-To-Work Planning

As states and cities begin formulating plans to reopen, it is important that companies begin planning and preparing for employees returning to the workplace. Having a well-developed Return-to-Work (RTW) plan will allow companies to safely and successfully bring employees back to the workplace and adapt to evolving guidance and regulatory requirements.

Companies should consult, and continue to monitor, guidelines and recommendations issued by federal agencies and state and local municipalities, which outline key considerations for planning and preparing workplaces for bringing back employees.

OSHA Standards and Guidance

The OSHA General Duty Clause 5(a)(1), requires employers to provide their employees with a workplace free from recognized hazards likely to cause death or serious physical harm. To minimize liability, companies should prepare a robust Infectious Disease Preparedness and Response Plan (IDPRP), and strictly adhere to its policies and procedures.

These plans are important for both the employer and employee: 1) For the employer, it requires development and implementation of policies and procedures that protect employees; and 2) For employees, it will provide them relief knowing that their employer is serious about protecting them from COVID-19 in the workplace.

Continue to follow existing OSHA standards that protect against infectious disease exposure: 1) Personal Protective Equipment (PPE) (29 CFR 1910 Subpart I) and 2) Bloodborne Pathogens (29 CFR 1910.1030).

COVID-19 RTW Risk Assessment

Implement the following to prepare for potential COVID-19 RTW issues:

Perform a Risk Assessment. Identify the steps that should be taken in order to reduce the risk of COVID-19 exposure in the workplace. The risk assessment will identify three basic elements:

1) Workers at high risk;
2) Potential sources of exposure; and
3) Appropriate control measures.

Develop an IDPRP. The IDPRP should, at a minimum, address the following:

1) The need for social distancing, staggered work shifts, downsizing operations, delivering services remotely, and other exposure reducing measures.
2) Options for conducting essential operations with a reduced workforce, including cross-training workers across different jobs in order to continue operations or delivery services.
3) Increased rates of worker absenteeism.
4) Interrupted supply chains or delayed deliveries.

IDPRPs should also consider and address steps that employers must take in order to reduce the risk of COVID-19 in the workplace which would include engineering and administrative controls appropriate to the individual workspace.

There are advantages and disadvantages to each type of control measure when considering the ease of implementation, effectiveness, and cost. In most cases, a combination of control measures will be necessary to protect workers from exposure to COVID-19.

Source: OSHA 3990-03 2020 “Guidance on Preparing Workplaces for COVID-19”

Submitted by John Gibbons, Tetra Tech, john.gibbons@tetratech.com