Redefining Business as Usual – Health & Safety Planning for Manufacturing Facilities

By: Monica Meyer

While we all are looking forward to things returning to “normal” in our personal and work lives, we are also recognizing COVID-19 is redefining what “business as usual” will look like in the coming months.

What does this uncertainty mean concerning the health and safety of your employees?

Time is of the essence and we need to innovate, not hibernate. While critical business operations continue, it is vital that companies adapt their safety efforts. Deliberate actions must be taken to develop safe-distancing protocols and provide training on the new norms and expectations. Open lines of communication will be critical for personnel to grasp and apply this “new normal” to protect themselves, their families, as well colleagues and the public.

The lack of understanding around how long it will take to manage this outbreak is causing volatility in the markets, businesses, and our personal lives. One thing we can all do is share lessons learned and key information with one another in an effort to define best practices quickly.

We are working with clients and colleagues to develop best practices and assist clients in COVID-19 contingency planning as recently defined by OSHA. Some of the common questions and concerns we have been addressing with clients include:

  • Are we over/under reacting?
  • How are other companies minimizing contact?
  • How do we reduce fatigue while having personnel work longer hours?
  • Can a company regulate personnel interaction during off-work hours?
  • What measures should be in place during lunch and work breaks?
  • Is my company responsible for the costs of medical tests if an employee feels they have been exposed during work hours?
  • Is contraction of COVID-19 a recordable case?

While the world is on pause, accidents are not. We know distractions and additional stress can lead to a rise in workplace incidents. EHS Support has been working side-by-side with our clients and preparedness experts to gather the best data and information possible to provide valuable and practical guidance. Our intent to is offer help and support so we all can progress safely through this turbulent time.

EHS Support is virtually supporting clients’ health and safety planning using the typical hierarchy of controls – elimination, substitution, engineering controls, administrative controls, and personal protective equipment. When implemented, these controls can include:

Prevention

  • Actively encourage and train employees to self-monitor temperature and wellness
  • Actively encourage sick employees to stay home.
  • Ensure that sick leave policies are flexible and consistent with public health guidance and that employees are aware of these policies.
  • Talk with companies that provide your business with contract or temporary employees about the importance of sick employees staying home and encourage them to develop non-punitive leave policies.
  • Do not require a healthcare provider’s note for employees who are sick with acute respiratory illness to validate their illness or to return to work, as healthcare provider offices and medical facilities may be extremely busy and not able to provide such documentation in a timely way.
  • Maintain flexible policies that permit employees to stay home to care for a sick family member. Employers should be aware that more employees may need to stay at home to care for sick children or other sick family members than is usual.
  • Recognize that workers with ill family members may need to stay home to care for them. See CDC’s Interim Guidance for Preventing the Spread of COVID-19 in Homes and Residential Communities: www.cdc.gov/coronavirus/2019-ncov/hcp/guidance-prevent-spread.html.
  • Provide adequate, usable, and appropriate training, education, and informational material about business-essential job functions and worker health and safety, including proper hygiene practices and the use of any workplace controls (including personal protective equipment (PPE)). Informed workers who feel safe at work are less likely to be unnecessarily absent.
  • Be aware of workers’ concerns about pay, leave, safety, health, and other issues that may arise during infectious disease outbreaks.
  • Work with insurance companies (e.g., those providing employee health benefits) and state and local health agencies to provide information to workers and customers about medical care in the event of a COVID-19 outbreak.

Implement Workplace Controls

Occupational safety and health professionals use a framework called the “hierarchy of controls” to select ways of controlling workplace hazards.  The best way to control a hazard is to systematically remove it from the workplace, rather than relying on workers to reduce their exposure.  During a COVID-19 outbreak, when it may not be possible to eliminate the hazard, the most effective protection measures are (listed from most effective to least effective): engineering controls, administrative controls, safe work practices (a type of administrative control), and PPE.   In many cases, a combination of control measures will be necessary to protect workers from exposure to COVID-19.

Engineering Controls

Engineering controls involve isolating employees from work-related hazards. In workplaces where they are appropriate, these types of controls reduce exposure to hazards without relying on worker behavior and can be the most cost-effective solution to implement. Engineering controls for COVID-19 include:

  • Install high-efficiency air filters.
  • Increase ventilation rates in the work environment.
  • Install physical barriers, such as clear Plexiglas or see-through shower curtains.
  • Install a drive-through window for customer service (or otherwise minimize density or traffic through an area).
  • Provide no-touch style trash cans in restrooms

Administrative Controls

Administrative controls require action by the worker or employer. Typically, administrative controls are changes in work policy or procedures to reduce or minimize exposure to a hazard. Examples of administrative controls for COVID-19 include:

  • Encouraging workers to self-monitor the temperature and wellness; and sick workers to stay at home.
  • Minimizing contact among workers, clients, and customers by replacing face-to-face meetings with virtual communications and implementing telework if feasible.
  • Establishing alternating days, shifts, or lunch hours that reduce the total number of employees in a facility or area at a given time, allowing them to maintain distance from one another while maintaining a full onsite work week.
  • Encourage staff to bring packed lunches to minimize interaction with general public.
  • Implement risk review procedures for both routine and non-routine tasks and activities as risks are identified (may be done as job hazard or risk analysis (JHA/JSA).
  • Discontinuing nonessential travel to locations with ongoing COVID-19 outbreaks. Regularly check CDC travel warning levels at: www.cdc.gov/coronavirus/2019-ncov/travelers.
  • Ensure only one employee per work vehicle
  • Developing emergency communications plans, including a forum for answering workers’ concerns and internet-based communications, if feasible. Providing workers with up-to-date education and training on COVID-19 risk factors and protective behaviors (e.g., cough etiquette and care of PPE). Training workers according to their job duties: proper hygiene, PPE, cleaning and disinfecting, telecommuting, travel safety, self-monitoring, etc.. Training material should be easy to understand and available in the appropriate language and literacy level for all workers.

Safe Work Practices

Safe work practices are types of administrative controls that include procedures for safe and proper work used to reduce the duration, frequency, or intensity of exposure to a hazard. Examples of safe work practices for COVID-19 include:

  • Provide resources and a work environment that promotes personal hygiene. For example, provide tissues, no-touch trash cans, hand soap, alcohol-based hand rubs containing at least 60 percent alcohol, disinfectants, and disposable towels for workers to clean their work surfaces.
  • Requiring regular hand washing or using of alcohol-based hand rubs. Workers should always wash hands when they are visibly soiled and after removing any PPE.
  • Post handwashing signs in restrooms.
  • Ensure regular disinfection of workspaces in accordance with CDC guidelines (see attached)

PPE

Examples of PPE include:

  • gloves,
  • goggles,
  • face shields, goggles, and face masks, and
  • respiratory protection, when appropriate.

During an outbreak of an infectious disease, such as COVID-19, recommendations for PPE specific to occupations or job tasks may change depending on geographic location, updated risk assessments for workers, and information on PPE effectiveness in preventing the spread of COVID-19. Employers should check the OSHA and CDC websites regularly for updates about recommended PPE.

All types of PPE must be:

  • Selected based upon the hazard to the worker.
  • Properly fitted and periodically refitted, as applicable (e.g., respirators).
  • Consistently and properly worn when required.
  • Regularly inspected, maintained, and replaced, as necessary.
  • Properly removed, cleaned, and stored or disposed of, as applicable, to avoid contamination of self, others, or the environment.

EHS Support is here for you. We have innovated distance delivery of numerous offerings to ensure that safety doesn’t take a back seat – allowing EHS Managers and supervisors to focus on their daily activities:

  • Desktop audits
  • Safety assessments conducted via Facetime or photos
  • Facilitation of online safety committee meetings
  • Health and safety policy, program, and procedure development
  • Off-shift audits/assessments
  • Health and safety training development
  • Online health and safety training offerings
  • Incident prevention during modified work procedures
  • Stress management
  • Contingency/pandemic program development and training

We must all do our part to reduce the transmission of COVID-19 to help prevent against the collapse of the healthcare system. The pandemic needs to last at a very low level until either enough people have had COVID-19 to leave most immune (if immunity last for years, which we do not know), or until a vaccine is created. Thus, the preparation we must do now is crucial to the business continuity and the health and safety of everyone.

Monica MeyerABOUT THE AUTHOR Over the past 16 years, Monica Meyer has been providing strategic and business safety experience to the organizations she supported. During this time, she focused on development of both corporate and facility level Health and Safety programs, developing systems for both compliance and risk management… Read More

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