This document is intended address frequently asked questions regarding return to work considerations by providing a summary of publically available advice from medical experts, the CDC, OSHA and others regarding measures that should be in place in order to implement a return to work strategy.
Question: How should health screenings be conducted?
- The EEOC has issued guidance on temperature checks: https://www.eeoc.gov/wysk/what-you-should-know-about-covid-19-and-ada-rehabilitation-act-and-other-eeo-laws
- FDA Electronic thermometer: https://www.fda.gov/regulatory-information/search-fda-guidance-documents/enforcement-policy-clinical-electronic-thermometers-during-coronavirus-disease-2019-covid-19-public (fever is 100.4°F/38°C)
- Health questionnaires (Form is located at the bottom of the blog)
- Apple screening tool: https://www.apple.com/covid19
Question: What are the hygiene best practices and what are the approved disinfectant products?
- EPA list of disinfecting products against COVID-19: https://www.epa.gov/pesticide-registration/list-n-disinfectants-use-against-sars-cov-2
- NYC Health cleaning/disinfecting for businesses’ guide: https://www1.nyc.gov/assets/doh/downloads/pdf/imm/disinfection-guidance-for-businesses-covid19.pdf
- How to clean and disinfect (NYC Health): “Remove any visible dirt and grime before using disinfectants. Disinfecting surfaces removes most germs and are most effective on clean surfaces or objects. Coronaviruses are relatively easy to kill with most disinfectants. When using cleaning and disinfecting products, always read and follow the manufacturer’s directions (e.g., application method, contact time). Staff should follow label directions and existing procedures for using gloves or other personal protective equipment (PPE). When used, gloves should be discarded after each cleaning.”
- All frequently touched surfaces in the workplace, such as workstations, keyboards, telephones, handrails, and doorknobs should be routinely cleaned and disinfected. And the following items should be available to aid in controlling the spread of the COVID-19 virus:
- Tissues and no-touch disposal receptacles.
- Disposable wipes for disinfecting commonly used surfaces.
- Soap and water for hand washing as well as the cleaning of surfaces, tools, and equipment.
- Alcohol-based hand sanitizer that is at least 60% alcohol. If hands are visibly dirty, soap and water should be chosen over hand sanitizer.
- Posters and other information that encourage hand hygiene to help stop the spread of COVID-19 in our workplace.
Question: How can we ensure employee personal information remains private when conducting health screenings?
- SHRM sample policies: https://www.shrm.org/resourcesandtools/tools-and-samples/policies/pages/cms_014967.aspx
- Federal OSHA recordkeeping requirements: https://www.osha.gov/recordkeeping/
Question: How should tools and equipment be cleaned properly?
- Focus on the areas that are touched by employees frequently throughout the day
- CDC Cleaning and Disinfecting Your Facility: https://www.cdc.gov/coronavirus/2019-ncov/community/disinfecting-building-facility.html
Question: How can our business plan for and respond to the coronavirus?
- CDC Interim Guidance: https://www.cdc.gov/coronavirus/2019-ncov/community/guidance-business-response.html
Question: What happens if an employee becomes sick at work?
- Employees who have symptoms (i.e., fever, cough, or shortness of breath) should notify their supervisor that they are ill and stay home.
- Employees who appear to have symptoms (i.e., fever, cough, or shortness of breath) upon arrival at work or who become sick during the day should be sent home.
- Employees who are ill should be encouraged to follow the steps listed below recommended by the CDC:
- Stay at home, get rest, stay hydrated.
- Communicate with their healthcare provider.
- Be sure to get care if they have trouble breathing or if they think it is an emergency.
- Employees should not return to work until the criteria to discontinue isolation are met in accordance with healthcare providers, state and local health departments, and company policy.
- Employees who are well but who have a sick family member at home who has been diagnosed with COVID-19 should notify their supervisor and maintain quarantine in accordance with healthcare providers, state and local health departments and company policy.
- EEOC Employer Rights: https://www.fisherphillips.com/resources-alerts-eeoc-clarifies-employer-rights-during-covid-19
Question: What do we do if an employee tests positive for COVID-19?
- Direct the diagnosed employee not to return to the workplace and to seek appropriate medical care.
- Identify all employees who may have come into close contact with the diagnosed employee while at the workplace.
- The CDC defines "close contact" as being approximately six feet from an infected person for more than a 10-minute period. Close contact also includes instances where there is direct contact with infectious secretions. Close contact generally does not include brief interactions, such as walking past a person.
- Human Resources should reach out to the diagnosed employee to identify who they felt they may have been in close contact with at work.
- The identity of the diagnosed employee should be kept confidential. Discrete knowledge of the employee’s identity may be needed to identify and notify impacted employees.
Question: How can we maintain physical distancing?
- Staggered work shifts if possible
- Limit amount of employees in breakrooms, restrooms, lunchrooms, meeting rooms, etc.
- CDC Social distancing: https://www.cdc.gov/coronavirus/2019-ncov/prevent-getting-sick/social-distancing.html
- Follow the policies and procedures in place related to illness, cleaning and disinfecting, as well as work meetings and travel.
- Employees should wash their hands often with soap and water for at least 20 seconds. (Use hand sanitizer with at least 60% alcohol if soap and water are not available.)
- Employees should remember to avoid touching their eyes, nose, and mouth with unwashed hands.
- Employees should cover their mouth and nose with a tissue when coughing or sneezing or use the inside of their elbow. Used tissues should be thrown in the trash and the individual should immediately wash hands with soap and water for at least 20 seconds. (If soap and water are not available, use hand sanitizer containing at least 60% alcohol.)
- Frequently touched objects and surfaces such as workstations, keyboards, telephones, handrails, and doorknobs should be cleaned frequently. Dirty surfaces can be cleaned with soap and water prior to disinfection.
- Individuals should avoid using other individual’s desks, offices, or other work tools and equipment, whenever possible. If necessary, clean and disinfect them before and after use.
- Practice social distancing by avoiding large gatherings and maintaining distance (approximately 6 feet or 2 meters) from others when possible. Strategies that may facilitate social distancing include:
- Implementation of flexible worksites (e.g., remote work).
- Implementation of flexible work hours (e.g., staggered shifts).
- Increasing physical space between employees at the worksite.
- Increasing physical space between employees and customers (e.g., drive through, partitions).
- Implementation of flexible meeting and travel options (e.g., postpone non-essential meetings or events).
- Downsizing operations.
- Delivering services remotely (e.g. phone, video, or web).
- Delivering products through curbside pick-up or delivery.
Question: How do we deal with the growing anxiety staff may have?
- CDC Stress and Coping: https://www.cdc.gov/coronavirus/2019-ncov/daily-life-coping/managing-stress-anxiety.html?CDC_AA_refVal=https%3A%2F%2Fwww.cdc.gov%2Fcoronavirus%2F2019-ncov%2Fprepare%2Fmanaging-stress-anxiety.html
- Consider offering childcare support and/or resources to employees.
- Offer financial assistance
Question: What are employee’s responsibilities when returning to work?
- All employees should follow established CDC preventative procedures for preventing the spread of the COVID-19 virus.
- Employees should report any potential occupational exposure to the COVID-19 virus to management, human resources or their operations manager.
- Employees should be strongly encouraged to, inform their physician of any signs or symptoms of the COVID-19 virus and follow their healthcare providers instructions
Question: What are the responsibilities of an operations manager when returning to work?
- Your operations manager is best positioned to administer your COVID-19 response program and as such should be responsible for:
- The issuance of personal protective equipment for handling potential occupational exposure to COVID-19.
- The evaluation of the effectiveness of your COVID-19 response program as well as any required updates if new information is released.
Question: What are the responsibilities of Management when returning to work?
- Management should understand and communicate all safety hazards to employees, including those that may be related to COVID-19 or other pathogens.
- Management is responsible for enforcing the proper use of personal protective equipment (PPE) and social distancing protocols.
- Management works with the safety committee to provide any resources necessary as it relates to safety and the policies set forth in this program.
- Management should remind employees of their access to an Employee Assistance Program (EAP) or other resources that may offer additional support.
Question: How can the safety committee assist when employee’s return to work?
- The Safety Committee works collaboratively to provide guidance, communication and actions to ensure the safety of our workforce related to COVID-19.
Question: Should all employees participate in orientation when returning to work?
- Yes, all new hires, employees who were furloughed, and employees working remotely should participate in orientation upon returning to work. Employees should follow company and local guidance pertaining to distancing during orientation, training, and typical work duties.
- Maintain training consistencies on new policies and procedures related to COVID-19
Question: Can employees refuse to come to work for fear of infection?
- According to OSHA regulations, employees may only refuse to work if they believe they are in imminent danger. Section 13(a) of the Occupational Safety and Health Act (OSH Act) defines “imminent danger” to include “any conditions or practices in any place of employment which are such that a danger exists which can reasonably be expected to cause death or serious physical harm immediately or before the imminence of such danger can be eliminated through the enforcement procedures otherwise provided by this Act.”
- SHRM guidance on employee absenteeism due to fear of Covid-19: https://www.shrm.org/resourcesandtools/legal-and-compliance/employment-law/pages/coronavirus-when-scared-workers-do-not-report-to-work.aspx
- Additional information available from Marsh & McLennan Agency and other viable sources to help shape your return to work program.
- MMA Coronavirus Resource Page
- MMA CARES Act Information
- MMA Article regarding Families First Coronavirus Response Act
- CDC Interim Guidance for Businesses
This document is not intended to be taken as advice regarding any individual situation and should not be relied upon as such. Marsh & McLennan Agency, LLC shall have no obligation to update this publication and shall have no liability to you or any other party arising out of this publication or any matter contained herein. Marsh & McLennan Agency LLC may assist employers in evaluating workplace safety exposures and conduct surveys, which may not reveal every hazard, exposure and/or violation of safety practices. Inspections conducted by MMA do not result in any warranty that the workplace, operations, machinery, appliances or equipment are safe or in compliance with applicable regulations. Appropriate policies and protection are ultimately the responsibility of the employer.