Businesses within the counties of the Greater San Francisco Bay Area are all experiencing the impacts of COVID-19 and shelter-in-place orders. Each county has stringent requirements that employers must implement before returning employees to the workplace and open their doors to customers. To insure employees feel safe to return to work, they need assurance that their employers are taking all reasonable precautions to ensure their safety and prevent the spread of COVID-19 in the workplace.

Following the roadmap below will help you meet this challenge and ensure that you also will be compliant with the requirements from the various state and federal agencies. You can find county specific requirements and updates on the department of public health website for the county in which your business is located. If you have locations in multiple counties, a county specific plan is required for each county.

Create your COVID-19 Team

Identify and appoint an individual or team to complete initial assessments, create and implement the overall plan including employee training, follow changes to governmental guidance as published, and ensure periodic review and updates to the plan.

Assess the Workspace and Adapt as Needed

  • Identify which employees may continue to carry out their duties remotely.
  • Walk the floor. Start at the front door and walk the workspace, looking for areas that should be physically adapted or placed off limits. Can desks be moved to allow 6 feet distance? Should a plexiglass barrier be mounted at the reception desk? Should chairs be removed from the conference room to limit the number of attendees? Or should in person meetings be cancelled completely?
  • Pay close attention to where employees tend to congregate and implement rules for their use. Post a sign limiting one person in the copy room at a time. Encourage employees to eat at their desks.
  • Note commonly touched surfaces, including shared or individual workspaces and equipment for specific cleaning and disinfecting protocols.

Returning Employees

  • Determine who will be returning to work on-site. Use objective criteria that is non-discriminatory in your decision-making process.
  • Assess for potential wage issues. Consider the need for premium pay or changes in status based on increase or decrease in hours.
  • Determine how you will screen employees for symptoms. All employees must complete a symptom checklist prior to starting their shift. This may be done at home or upon arrival.
  • Consider if you will also implement temperature screenings at the workplace. Specific privacy concerns would need to be addressed, including HIPPA, OSHA and possibly the California Consumer Protection Act.
  • Consider creative ways to decrease the number of employees in the building at any given time.

Develop Your Return to Work Plan

  • Review state and county shelter-in-place orders for business and industry specific requirements.
  • Complete the county specific Social Distancing Checklist and Protocol. This can be found on the county’s department of public health website. It is required to be filed with the County by July 13, 2020. It must be specific to the layout of your business.
  • Complete a county specific Disinfecting Checklist and Protocol. This may be included as part of the Social Distancing Protocol or as a separate document, depending on the county.
  • Draft a written policy to compliment the above checklists.
  • Ensure all required postings related to these protocols and place at each entrance to the building or workspace and where needed throughout.
  • Ensure all needed PPE and disinfecting supplies are readily available to employees.
  • Develop reporting and notification protocols for confirmed or suspected COVID-19 in the workplace.

Communication and Training

  • Provide all employees with relevant policies and protocols and provide full training on each document.
  • Provide additional training for supervisory personnel. Employees must receive consistent communication and trainings as updates are provided from the COVID-19 team.
  • Schedule safety meetings go over the return to work plan and employer and employee responsibilities.
  • Ensure each returning employee and new employees receive this information.
  • Set an ongoing plan and communicate often. Provide updates on the what the business is doing to keep its employee safe, but also consider providing updates from county health departments, OSHA, or CDC.

Your COVID-19 team will also need to establish recordkeeping protocols. Employers must maintain training records, proof of dissemination of and training on the plan and document exposure incidents. Additionally, the COVID-19 is responsible for regularly evaluating the workplace for compliance with the plan and government updates, as well as document and correct any deficiencies.

Additionally, it will be important to review your existing policies and procedures and revise as needed to meet the expectations of your new workspace and to comply with updated government guidance and requirements. Consider reviewing, and updating, your Injury and Illness Prevention Program, Leave of Absence Policies, and possibly job descriptions.
Additional resources:

COVID-19 will be with us for the foreseeable future. A quick reminder – as the state and local counties move through reopening phases you will need to stay appraised of changes and how they impact your business.  SBHRS can assist with getting your teams back to work and in setting measures in place so your business stays in compliance while addressing the fear and concerns of your employees.  To learn more, reply to this email or call me at 408-834-9069.