OSHA’s Guidance on Reopening Non-Essential Businesses
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As the novel coronavirus pandemic continues to make its impact around the world, economies are slowly but surely emerging from a standstill—which means that many non-essential business owners are looking for guidance as they ask their employees to come back to work again. OSHA recently released recommendations, called “Guidance on Returning to Work,” that aims to help both employers and employees with reopening businesses safely. The guidance describes reopening strategies, provides considerations for each of the three phases, and has effective suggestions for health and safety procedures that you can put in place to reduce the risk of exposure as the pandemic continues to evolve.
Considerations for Three Phases
OSHA’s guidance on returning includes general recommendations for loosening the restrictions your business may have been required to put in place in order to help slow the spread of the coronavirus. These recommendations follow the typical three-phase plan that the federal government has also established.
In Phase One:
- Telework, if possible, should continue.
- For employees who do come back to the workplace, numbers should be limited to maintain social distancing.
- Special accommodations should be made for workers who are at higher risk (either elderly or have underlying health conditions), or for workers who live with household members who are at higher risk.
- Non-essential business travel should be limited as much as possible.
In Phase Two:
- Telework should continue to be available.
- The limitations on number of people in the workplace can be eased, but still restricted to maintain moderate social distancing practices.
- Vulnerable workers should continue to be accommodated.
- Non-essential business travel may resume.
In Phase Three:
- Unrestricted staffing may resume across all worksites.
OSHA does not determine which reopening phase your business falls under; that decision lies with your state and local government, which takes into consideration recommendations from health and safety professionals. However, you may use the above as a general rule of thumb to abide by depending on which phase your business is in based on your location. If possible, employers should still be flexible and use alternative means to provide their goods and services, such as allowing remote work and offering curbside pickup.
Reopening Strategies for Employers
No matter which phase of the reopening process you are in, employers should implement specific strategies that are designed to prevent their workers from being exposed to COVID-19 in the workplace. These strategies include:
- Hazard assessments. Conducting a hazard assessment helps you determine how and where workers are likely to be exposed to the coronavirus during their job duties.
- Basic hygiene and infection prevention measures. This includes establishing a routine cleaning and disinfection program, and encouraging employees to practice hand hygiene and respiratory etiquette.
- Social distancing. The rule of thumb is still to keep at least six feet of distance between each person. Workstations may be rearranged to accommodate this distance, and in cases where such arrangements can’t be made, physical barriers such as plexiglass can be installed.
- Identification and isolation of sick employees. This includes your company’s procedure for screening employees for signs and symptoms of the virus, and how you will encourage employees to self-monitor for symptoms.
- Returning to work after exposure or illness. It’s a good idea to create a procedure for employees who come back after they have recovered from a confirmed COVID-19 case or have completed quarantine after potential exposure.
- Workplace controls, including engineering and administrative controls, safe work practices, and PPE. These controls, known as the hierarchy of hazard controls, are selected after the completion of a hazard assessment.
- Workplace flexibilities, such as your temporary policies concerning sick leave and telecommuting.
- Employee training. Workers should understand what is expected of them and receive training on signs and symptoms of COVID-19, risk factors, which sources they may be exposed to, and how to prevent the spread of disease at work.
- Anti-retaliation. No retaliatory action should be taken against employees who express concerns about workplace health and safety.
OSHA provides details on each of these strategies in its guidance, as well as examples on how you can implement them. Its guidance also answers questions on health screenings, worksite testing, applicable OSHA standards, and establishing safety and health programs.
Other Recommendations
OSHA’s “Guidance on Returning to Work” is meant to be supplementary to guidelines that have been previously developed, such as the agency’s “Guidance on Preparing Workplaces for COVID-19” and the federal government’s “Guidelines for Opening Up America Again.” The agency also recommends that all employers stay up to date with guidelines established by their local governments; this is the best way to receive information about community transmission and best practices for mitigation measures. By following local guidance and using OSHA’s general recommendations, you can slowly but safely reopen your non-essential business.
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