You can help end the COVID-19 pandemic.
You have the power to prevent transmission of the coronavirus in your workplace. And you have the responsibility to keep your workforce safe, healthy, and informed about the disease. It’s up to you to keep case numbers down—not only for the sake of your team and community, but also because of the many COVID-19-related liabilities that threaten your organization’s bottom line.
So, how do you minimize COVID-19 in the workplace? We’ve got 10 strategies for you.
How do you minimize the chances of COVID-19 infection in your workplace and mitigate the many associated operational, regulatory, legal, and intangible risks?
To help you out, we’ve pulled together a list of 10 practical strategies from KPA’s EHS and compliance experts. Here’s what you need to know about protecting your employees and your organization from COVID-19 risks.
Note that the information in this article is provided for general informational purposes only and may not reflect the current law in your jurisdiction. Nothing in this article should be construed as legal advice, nor is it intended to be a substitute for legal counsel on any subject matter.
1. Trust Official COVID-19 Guidance
The Occupational Health and Safety Administration is your friend. For as strenuous as COVID-19 regulations may seem—and for as costly as fines for non-compliance can be—the people at OSHA want the pandemic to end as much as we all do. The only way we’ll get through this is if employers know, trust, and abide by the agency’s guidance.
The same is true for the Centers for Disease Control and Prevention. It’s crucial to pay attention to the CDC’s informational materials about COVID-19, and to stay up-to-date on the latest guidance as circumstances change and scientific consensus develops. Access the CDC’s Coronavirus (COVID-19) hub at cdc.gov.
If you’re looking for a place to start, download OSHA’s Guidance on Preparing Workplaces for COVID-19 (PDF). You’ll find recommendations for minimizing transmission of the virus beginning with “Steps All Employers Can Take to Reduce Workers’ Risk of Exposure to SARS-CoV-2” on page 7.
OSHA offers 6 steps for reducing COVID-19 exposure in the workplace:
- develop an infectious disease preparedness and response plan
- prepare to implement basic infection prevention measures
- develop policies and procedures for prompt identification and isolation of sick people, if appropriate
- develop, implement, and communicate about workplace flexibilities and protections
- implement workplace controls
- follow existing OSHA standards
We’ll discuss these measures in greater detail throughout this article.
2. Make Good Faith Efforts to Keep Workers Safe and Healthy
So far (as of October 2020), OSHA has provided “interim guidance” on the coronavirus rather than hard and fast regulations. The agency recognizes that the pandemic is a rapidly changing situation in which the best course of action isn’t always clear. To that end, OSHA expects employers to make “good faith efforts” to protect workers from the pandemic.
Here’s how OSHA explained its stance in a national news release published in April 2020:
“During an inspection, compliance safety and health officers should assess an employer’s efforts to comply with standards that require annual or recurring audits, reviews, training or assessments. Officers should evaluate if the employer:
- Explored all options to comply with applicable standards (e.g., use of virtual training or remote communication strategies);
- Implemented interim alternative protections, such as engineering or administrative controls; and
- Rescheduled required annual activity as soon as possible.
Employers […] should demonstrate a good faith attempt to meet applicable requirements as soon as possible following the re-opening of the workplace.
OSHA will take employers’ attempts to comply in good faith into strong consideration when determining whether it cites a violation. The agency may issue a citation if it finds an employer cannot demonstrate any efforts to comply. […] OSHA will develop a program to conduct monitoring inspections from a randomized sampling of cases where the agency noted, but did not cite, violations.”
In other words, what matters most is that you’re aware of OSHA’s standards and guidance and are taking every possible precaution to comply with them and keep your workers safe—and can prove as much if an inspector comes calling.
3. Locate Reliable Sources of Information
Be careful about what information you and your employees pay attention to and trust. In addition to the CDC and OSHA, the Environmental Protection Agency and the Food and Drug Administration both offer some reliable COVID-19 guidance.
Equally—if not more—important are all state and local safety and health authorities in the region or regions in which you do business. In fact, your public health department should be your go-to source for information and news about COVID-19. The department will have local mandates and statistics available, and will tell you what you need to do if there’s an outbreak or confirmed case at your facility.
Proven sources of EHS expertise, such as KPA, are essential as well. We can provide you with up-to-date, detailed information and a plan of action specific to your industry, organization, and team. Reach out to us at any time.
Social media, on the other hand, is not trustworthy unto itself. Nor is any single newspaper, website, radio station, or television channel. Many news outlets present incomplete, biased, or misleading information about COVID-19. If you spend any time reading articles or scrolling through social media platforms such as Twitter and Facebook, be sure to check multiple sources and remain open-minded but skeptical of everything you see, read, listen to, and watch. If something sounds suspicious or too good to be true, it probably is.
Again, when in doubt, check with your local public health department. And make sure to stay informed by checking back with your sources of information often, because guidance tends to frequently change.
4. Establish a Pandemic Response Team
Once you’ve located reliable sources of information and brought yourself and your team up-to-date with all relevant COVID-19 guidelines, the first step in protecting your workforce is to establish a pandemic response team. This team is roughly equivalent to a safety committee, and serves a similar function in steering the organization’s health and safety program.
Like any effective safety committee, a pandemic response team should have representatives from all levels and departments of the organization:
- top executives
- human resources
- facilities management
- union representatives (if applicable)
For more information, read our article, “Your COVID-19 Response Team: Who, What, Why and How.”
Ensure the Pieces of an Effective EHS and Compliance Program Are in Place
To reliably prevent COVID-19 transmission in the workplace, your compliance program needs to be more than a vague intention to keep people safe or a mere collection of policies in a binder. You need to develop a detailed, action-oriented plan and well-functioning EHS and compliance program.
An effective program is built on 4 pillars:
- Documentation serves as the foundation of the program memorializing policies and instructing employees. Remember: if it wasn’t documented, it didn’t happen.
- Audits validate processes, ensure employees consistently conform to the rules, and identity program gaps as well as opportunities for improvement.
- Corrective and preventive actions resolve existing and potential problems in the program.
- Training educates the workforce, conveys policies, and shapes employee behavior, while allowing leadership to manage liability.
We’ve written numerous articles about each of these topics here on the KPA blog. Dive in at any of the links below:
5. Conduct a Workplace Risk Assessment
Not every worker faces the same level of COVID-19 transmission risk.
Very high-risk workers are those likely to come into contact with the coronavirus through medical, postmortem, or lab procedures. Healthcare professionals are one example of workers in this category.
High-risk workers are those with high potential to come into contact with COVID-19. For instance, people who deliver healthcare supplies can be considered high-risk.
Medium-risk workers are those who work closely with others. At many organizations, salespeople would fall into this category.
Lower-risk workers are those with minimal contact with other people. Long-distance truck drivers are an example of lower-risk workers.
To conduct a workplace risk assessment, consider the different risks your employees may face, placing those employees into the appropriate categories. Also consider what risks may be present in your overall facility. Think geographically: What do case numbers look like in your city, state, and region? Is your workplace located in a COVID-19 hotspot? Are there specific areas within the workplace, such as a cafeteria or locker room, that present greater risks than others?
KPA can help you conduct a thorough workplace risk assessment that accounts for all EHS and regulatory uncertainties. Learn more.
6. Develop Written COVID-19 Policies—and Keep Them Updated
Your written policies are your playbook for preventing COVID-19 transmission in the workplace. They should spell out what protocols and controls are in place, how employees are expected to keep themselves and others safe, and what steps will be taken in the event of a suspected or confirmed positive case of the virus.
Your policies are also important tools for reducing liability. Given that this crisis will likely continue to spawn a wave of lawsuits in the months ahead, policies are among the best defenses employers have to demonstrate that they’ve taken necessary precautions. Your policies will also establish a good faith record of compliance if regulators show up after a complaint.
In any event, make sure to revisit your policies often, and revise them when necessary—e.g. if CDC guidance changes or new state laws come into effect. If you’re not sure whether your policies are comprehensive and up to date, contact us.
7. Implement COVID-19 Prevention Controls
This strategy is actually a collection of strategies, big and small, to minimize the chances of workplace COVID-19 infection. Indeed, the most effective defense we have against the coronavirus is the hierarchy of controls,[a] a system of protective measures that lays out strategies in 5 tiers, in order of most to least effective:
- Engineering Controls
- Administrative Controls
- Personal Protective Equipment
The first control, elimination, isn’t possible at the moment. We can’t yet eliminate COVID-19 with a vaccine or cure.
The second control, substitution, means replacing the hazard with something else. For many organizations, this takes the form of going virtual and having employees work from home.
But if you can’t operate entirely remotely, or if certain workers need to be in a shared physical facility, your best option is engineering controls, followed by administrative controls, and—as a last resort—personal protective equipment.
Engineering controls isolate people from the hazard. Examples of engineering controls for COVID-19 prevention include…
- eliminating shared workspaces
- partition barriers
- roping off certain areas of the facility
- increasing workplace ventilation
- using high-efficiency air filters
Administrative controls change the way people work. Examples of COVID-19 administrative controls include…
- a no skin contact policy
- social distancing
- handwashing schedules
- assigned entrances and exits
- sanitizing stations
- sanitizing schedules
- closing shared amenities
PPE is the last line of defense against COVID-19. Examples of equipment that reduce the chances of coronavirus transmission include masks, face shields, and gloves.
Keep in mind that there are certain rules for using PPE in the workplace. If you have N95 respirators for workers, you are required to train workers on how to safely put on, take off, use, and maintain the devices. You also need to provide general information on how to safely use any required mask.
It’s important to recognize that cloth and surgical face coverings have limitations—they may still allow some COVID-19 particles to pass into the lungs. And don’t forget that any form of PPE is far from the best and only option for mitigating coronavirus risks. Per OSHA guidance, masks can’t replace social distancing.
The Limitations of Controls
You need to invest in proper controls, but keep in mind that any control can be difficult to maintain. The employers most effectively reducing their COVID-19 risks are the ones who pair good controls with rigorous employee education and enforcement of workplace EHS and compliance policies.
One relatively easy way to support your prevention controls is to eliminate the sharing of most items, such as…
- key fobs
- customer amenities
8. Train Your Employees on COVID-19 Safety
Training is a critical component of COVID-19 prevention. By educating your workforce on the risks and controls within your facilities, you’ll not only ensure compliance but also empower employees to speak up and advocate for their health and safety.
Make sure to train your employees on the following:
- the characteristics of COVID-19
- signs and symptoms of infection
- workplace COVID-19 precautions
- what to do if there’s a suspected or confirmed case
- how to use, wear, take off, and maintain PPE
- how to avoid the spread of germs through handwashing, social distancing, and other measures
- cleaning, disinfecting, and sanitization
That last point can be especially tricky, as cleaning chemicals carry their own health, safety, and compliance risks. Make sure you have a Safety Data Sheet for each chemical in your SDS library; know about its hazards, efficacy, and contact time; and have any necessary PPE available for employees who use the chemical.
Keep in mind that not every sanitizer is effective or safe to use. Consult the FDA’s list of sanitizers to avoid.
For more information about training, download The Keys to Better Workforce Training eBook.
9. Embrace Online Training and Electronic Signatures
As employees are brought back from furlough and any new hires are onboarded, proper training will be critical for maximizing workplace health, safety, and compliance. Due to the pandemic, however, classroom-style group learning poses unacceptable risks.
Leverage online training instead. There are numerous benefits here in addition to improved safety. Unlike traditional workforce education, online training can be self-paced, delivered in easily digestible pieces, and updated easily as policies and guidelines change.
Whatever learning solution you use, make sure you have a record of complete training for all employees. Collect signatures electronically if you can, so employees can stay hygienic and quickly sign new policies as needed.
KPA offers a library of award-winning EHS and compliance training courses available online. Check out our selections.
10. Audit Everything
Your work doesn’t end once your policies and controls are in place and your employees have completed their training. You’ll need to stay abreast of regulatory updates and operational realities.
As new processes are introduced in your workplace, engage a third-party expert consultant to audit your facility and procedures. An audit identifies all COVID-19 risks as well as any other hazards present at your facility, ensuring your controls are adequate and your safety and compliance program is in line with your other organizational goals.
Get Expert COVID-19 Safety and Compliance Consulting + Software, Training, and More
KPA has everything you need to protect your workforce and minimize your COVID-19 risks. We offer expert consulting, available online or on-site, along with automated compliance management software and an extensive training library.
The COVID-19 crisis requires unprecedented levels of diligence to ensure the risk of spread is minimized as much as possible. In response, we’ve developed comprehensive programs to help safely guide your return-to-normal operations and ensure your business stays compliant with new federal and state guidelines and regulations.