Designing a COVID Response Plan to Fit Your Needs: Q & A

COVID-19 presents a new and challenging dynamic for managing a business, and planning for the “new normal” and our future with COVID-19 requires vigilance and flexibility. The phased re-opening of businesses means companies must adapt to ensure they can function effectively while COVID-19 remains a threat.

The Centers for Disease Control and Prevention (CDC) and Occupational Safety and Health Administration (OSHA) have developed multiple guidance documents on reducing COVID-19 risks in the workplace. Implementing these recommendations in your workplace requires an understanding of how the virus spreads and the specific risks of exposure associated with daily activities and work responsibilities. Employee health and safety risks should be addressed by conducting a hazard assessment and using the hierarchy of controls, implementing a written Infectious Disease Preparedness and Response Plan, improving communication with employees and stakeholders, and re-vamping employee training and education programs. By employing a combination of exposure risk assessments and multiple layers of controls tailored to your facility, you can help keep your workplace safe and maintain business continuity in the face of evolving health recommendations from government agencies and the scientific community.

If you did not get a chance to listen in on our webinar One Site Does Not Fit All: Designing a COVID Response Plan to Fit Your Needs last week, click for a recording of the webinar or to download the slide deck.

We received a number of questions during and after our webinar, and we have addressed them below:

We have had our first identified COVID-19 case at our facility. Where should we start with handling this specific case, as well as mitigating a wider, facility-wide outbreak?

Ideally, before re-opening or expanding operations a facility would have a written procedure in place for sending employees home who have tested positive for COVID-19 or are displaying symptoms. Such procedures should include the criteria to be used in determining whether an employee should be sent home, procedures for reporting positive cases to local health departments if applicable, and guidance for those individuals performing the screening. In cases where a facility does not have such procedures, it is important to first make sure that communication with the employee is clear and that any decisions to have them stay home are in line with state and local health department and CDC recommendations.

Rather than requiring employees to get a test, it’s best to recommend that such employees obtain additional medical advice from their primary care provider or from a medical clinic familiar with COVID-19. If you have a workforce that likely does not have medical insurance, providing information on where a low-cost clinic is located can encourage employees to seek such advice. As discussed below, you’ll also want to make sure you provide them with information on when they can return to work.

You will also want to perform contact tracing in the form of a discussion with the employee about any other employees they have had close or direct contact with, including traveling to and from the workplace and in the daily performance of their job, including common areas. CDC considers close contact to be anyone who was within 6 feet of an infected person for at least 15 minutes starting from 2 days before illness onset and/or prior to a positive test result. CDC considers direct contact to include coming into contact with any respiratory secretions of an infected person (e.g., being coughed on, touching a surface an infected person coughed on).

You will need to know where the employee typically ventures within the building and whether they may have gone elsewhere within the facility during the 2 days prior to the positive test and/or symptom onset. At that point, you will need to assess whether additional individuals and/or a facility shutdown is warranted. By conducting a hazard assessment of each workspace ahead of time, this is a simpler process, as you can more quickly determine if you have to shut down the whole facility for cleaning and disinfection or just the area that employee was working in.

By proactively implementing regular health screenings as part of the entry procedure to the facility, you should have a good baseline of how your workforce is feeling. This may allow you to predict the likelihood that an outbreak at the facility is occurring based on recorded vital signs and symptoms. Administrative and engineering controls implemented as part of your response plan may also prevent the infected individual from spreading the disease.

How do we know whether it is safe for an employee to come back to work after a positive COVID-19 test or being sent home with COVID-19 symptoms?

More and more health agencies are recommending using a symptom- and time-based strategy for allowing employees to return to work.

For employees that test positive for COVID-19 but do not display symptoms, the time-based strategy is to wait 10 days from the positive test result. In the event these employees develop symptoms within the 10-day time period, the symptom-based strategy is then appropriate. The symptom-based strategy notes that employees may return to work after:

• At least 3 days have passed since the employee experienced a fever without fever-reducing medication

AND 

• Improvement in respiratory symptoms (e.g., cough, shortness of breath)

AND 

• At least 10 days have passed since the first symptoms appeared.

As you can see, ensuring you have a clear understanding of what constitutes a fever and a respiratory symptom are critical to using this approach. Having a plan in place ahead of time will ensure there is no ambiguity when the situation for allowing an employee to return to work arises.

The test-based strategy combines the symptom-based requirements above with a requirement for two consecutive negative test results using an FDA-Emergency-Use-Authorized COVID-19 molecular assay for detection of SARS-CoV-2 RNA. Given the time lag and lack of written results associated with tests, it can be difficult for employers to use this approach. Further, it requires making sure that employees are getting tested using an approved diagnostic testing method. As such, it is often more straightforward to have a well-thought-out plan in place that does not rely on testing.

What kinds of approaches are you seeing facilities use to implement employee health screenings?

The CDC’s most recent recommendations for employers include health screenings and conducting daily health checks to reduce the spread of COVID-19 in workplaces. We recommend conducting these activities in areas outside the facility or immediately inside the entrance, in an area where employees do not have to congregate while waiting.

Typically, you can use a daily health screening form available from your state or local health department, or create your own. Criteria to include in your screenings would include temperature checks (e.g., using a non-contact thermometer) and a set of screening questions about recent potential exposure to infected individuals (e.g., through travel or social activities not sufficiently distanced). It is important that you provide training to both the individuals performing the screening, as well as the employees being screened, so that all are aware of what physical conditions constitute experiencing COVID-19 symptoms. Training should be specific to the questions being asked, and updated if the CDC updates or modifies its symptoms list.

To allow for 6 feet of physical distance between employees during the screening process, employees can take their own temperature before getting to the facility. Or, upon arrival at the facility, a screener can stand behind a physical barrier and use a non-contact thermometer to complete the temperature check. The remaining portion of the screening question process can be completed while social distancing. Where physical distancing is not possible, facilities may encourage use of electronic forms. Facilities are encouraged to involve human resource professionals when developing a screening program to ensure compliance with medical privacy rules and regulations.

I've been hearing a lot about contact tracing in the news. What is it and how can I use it in my workplace?

Contact tracing in the workplace allows employers to identify who has come into contact with an employee that tests positive for COVID-19 in order to interrupt the spread of disease within the workplace. You should create contact tracing protocols that make sense for your workplace conditions, and include procedures such as:

• Interviewing infected or potentially infected employees with COVID-19 to identify other employees they had close or direct contact with during the time they may have been infectious (typically 2 days prior to the first symptom or positive test result);
• Notifying these employees of their potential exposure;
• Determining which if any of these employees may need to be sent home to self-quarantine;
• Referring employees to medical professionals for further health advice; and,
• Isolating and cleaning any areas of your workplace that the infected employees may have been while infectious.

Typically, this is conducted through interviews; however, we have seen facilities that are considering using a more expansive program involving cellular applications and/or Bluetooth-enabled devices to identify all employees that had close contact with an individual testing positive for COVID-19. You should choose the methodology that will work best for your facility.

Are there known alternatives to face coverings in loud facilities?

Face coverings can make it very difficult to hear those around you, especially in loud settings. Employees may also move within six feet of each other in order to communicate more easily, which increases the risk of COVID transmission. Government agencies and industry are working hard to develop suitable face masks that include some form of clear panel which may make it easier for employees to understand what their coworkers are saying by allowing them to read lips and see facial expressions. The CDC does not currently recommend face shields as a substitute for cloth face coverings as it is not known whether they provide the same source control benefits as cloth face coverings, but suggests that if they are worn they should extend to the chin and wrap around the sides of the face.

In the interim, in loud settings where employees have to verbally communicate frequently and a 6-foot separation is not possible, consider whether you can provide employees with headsets that include OSHA-compliant hearing protection and microphones for use with facial coverings. Alternatively, conduct a job-specific hazard assessment with the employees themselves to see if they have suggestions for alternative means of communication, such as hand signals or using written communication either on boards or via cellular technology. The important thing is to find a solution that considers the most likely way for the virus to spread and the most workable solution for your situation, which may include more than one layer of control.

For additional information, please see the links below.

https://www.cdc.gov/coronavirus/2019-ncov/community/guidance-business-response.html

https://www.osha.gov/Publications/OSHA4045.pdf

https://www.eeoc.gov/wysk/what-you-should-know-about-covid-19-and-ada-rehabilitation-act-and-other-eeo-laws