The ABC’s of Returning Safely to Work!

Darcy Cook is the Director of Emergency Management for Safety Trainers, located in Worcester, MA. She delivered a five-part content-rich webinar series “The ABC’s of Returning Safely to Work” that forms the foundation for the following information. This serves as ‘cliff notes’ for the series and has been linked to each webinar so can watch them and delve into the details that were provided for each one. Webinars #2 through #5 also feature audience Q&A.

As you read through this and/or watch these videos, you may decide that you would like some help in developing your plans, policies and procedures. If that is the case, MassMEP has just added a course to called “Navigating a Pandemic” delivered by Darcy Cook. It’s available through an Express Grants (#1125526) if you would like to pursue a Workforce Training Fund Grant.

#1 Navigating the Alphabet Soup of Regulations As We Get Back to Work

The first webinar in the series provided a broad overview of what’s to come in detail in the following four. Darcy spends hours poring over information, guidance and advice that is available from a variety of sources including CDC, OSHA, DPH, Mass.gov, and many trade organizations. The information has been assimilated in this series. She understands that it can be overwhelming for anyone to determine what needs to be done as we re-open for business. “It’s a matter of understanding what applies and what doesn’t apply. No two manufacturers are the same, no two restaurants are the same, no two bakeries are the same, so you have some flexibility,” she opens.

“In a nutshell, the CDC is guiding us around face masks, social distancing, hand washing, and if you’ve had contact with someone.  OSHA is the only organization designed for protecting employees and for providing a safe and healthy workplace. This will be the foundation of building your COVID-19 Safety Site Plan. It stems from OSHA regulations. If already have been following, complying, written documentations, and training according to their guidelines and standards, it will be an easier transition to develop a COVID-19 plan and procedures. Key points to remember are that you must comply with the minimum of what is being recommended. You can also step it up more if you choose. For example, 6’ is the minimum for social distancing, but you could make it bigger if you want. There is a 14 day quarantine to return to work, and you could make it more days if you choose. It’s okay to make your policies stricter.”

This definition by the CDC of how COVID-19 spreads should be the foundation of how you make decisions: You can become infected by coming into close contact (6’ or 2 arm lengths) with person who has COVID-19. COVID-19 is spread from person to person. You can become infected from respiratory droplets when an infected person coughs, sneezes, talks. You may also be able to get it by touching a surface or object that has the virus on it and then by touching your mouth, nose or eyes.

COVID-19 is all about infectious control. Most companies don’t have an infectious control plan in place, but DO have the OSHA Blood-Borne Pathogen standard in place. You can build out from this to develop your infectious control plan and disinfecting policies and practices.

The following websites provide guidance around COVID-19 that will be referred to throughout the series:

MA Reopening Mandatory Safety Standards for Workplaces

MA Department of Public Health/Mass.gov/Mandatory Safety Standards

Interim Guidance from CDC and OSHA

OSHA Guidance on Preparing Workplaces for COVID-19

List of Applicable OSHA Standards

OSHA COVID-19 Guidelines for the Manufacturing Industry Workforce

Hierarchy of COVID-19 Controls

#2 Who Will Be Your COVID-19 Safety and Health Coordinator?

There are no laws yet about COVI-19, however there are lots of recommendations. These are likely to become future regulations and laws. Darcy anticipates that infectious control standard will become a directive about how will offenders will be cited and fined.

How are recommendations being enforced? OSHA won’t show up right now unless there is a fatality, but employees can call them if they feel you aren’t protecting them. Right now OSHA is focusing on the highest risk – which is front line responders etc. Manufacturing is considered to be in the low risk category. But you might get a letter asking to respond if there is a complaint. Complaints can also come from vendors, visitors and guests. Make sure you respond if you get a letter – Safety Trainers can help you with that if you need it.

What do the risk categories mean? Low risk means you do not have frequent close contact with co-workers, customers or the public. The higher the risk, the more the requirements and expectations. Medium risk includes traveling, international travel, schools, and retail. High risk is healthcare, funerals, and medical transport, and very high risk is paramedics, nurses and doctors, dentists, lab personnel, and morgues.

Your company will want to make new revisions with COVID updates to your OSHA documents and document the dates. You must show a good faith effort, and part of that is your paper trail. As you review the information being presented in this series, evaluate your policies and procedures on a 1,3,5 scale as follows:  1) We don’t have it but are working on it, 3) This is in place and needs improvement, and 5) Based on what know we are rock solid and in a good place.

The steps your company needs to take to manage COVID-19 are:

1) Identify who will participate in each of these areas for sub-groups, as they will not all the same people: sick policy, operational flow, pedestrian traffic, SOP’s, signage, housekeeping, PPE, First Aid and medical, and training

2) Choose members and form your team. Suggestions for members include coordinator, owner, HR, General Manager or Head of Ops, plant/facilities person.

3) Set a regular meeting schedule. Create safety briefings and evaluate how quickly you’ll be able to get information out. There is a need for frequency of meetings and communications – things change regularly with COVID-19. Many companies are doing morning, just after lunch and evening calls to evaluate and adjust what is happening in their facility.

The coordinator and teams’ job is to constantly be observing how practices and policies that you put in place are working. Figure out if there is a safer and better way to do it. Make changes and document the changes. This is all about prevention, to decrease the risk of exposure happening all together. Interview your employees – they will come up with great ideas of how to improve health and safety. Good solutions save time, energy, money, and resources.

#3 New Rules, New Procedures. Which Ones Should I Apply to My Business?

You are in the process of building your COVID-19 Safety Site Plan. Darcy makes this analogy, “We are all in the same storm, but we are not all in the same boat. No two restaurants, no two bakeries, no two manufacturers are the same.” According to the MA Mandatory Safety Standards for Workplaces, there are four categories covered as well as sector specific workplace specific safety protocols and best practices: social distancing, hygiene protocols, staffing and operations, and cleaning and disinfecting.

Social distancing – Identify your core activities or basic minimum services as social distancing is in place until the end of the year. Identify activities that you will cease or scale down recognizing that demand for certain services will change in a pandemic. Identify key employees and supplies needed to provide critical services. Create redundant or double teams for all critical staff functions. Develop staffing plans and identify work that must be done in the office and work that can be done from home.

Considerations include: Decrease gathering around the time clock; limit number of employees in elevators, control rooms and vehicles; reconfigure worker common spaces; partitions for workspaces that can’t be spaced for social distancing.

Hygiene protocols – There is a laundry list of considerations here that include: Hand sanitizer stations and handwashing facility or access increased; disconnect air blowing hand drying systems; use disposable paper towels; automatic soap and hand sanitizer dispensers; change door handles to include handless/no contact to open door (crash bar, automatic); disposable toilet seat covers. Practices might include: all visitors, customers, etc. must wash hands and/or use hand sanitizer immediately upon entry; must wash hands before meals, breaks, leave building, entering building, after sneezing coughing, touching another person, cleaning, smoking, putting on and off chapstick/lipstick; no smoking on company property.

Operational changes – This is a vast area to cover and procedures to look at include: Temperature check before enter building; pre-qualifying questionnaires for employees, vendors, clients; update sick policy and training on signs and symptoms and return to work criteria as well as reporting; scheduling changes and flexibility; contactless deliveries/pickup; paperless documentation; payments using tap technology and online payment systems; invoicing and online quick books, payments – no more cash or checks; online ordering; change work flow process – rearrange floor space, storage, equipment used to move or touch something, etc.; train new flow with intent to decrease number of times that your staff touch raw material to final product; no sharing equipment; no one  but employees allowed in the building; rules for travel interstate and out of US; rules for meetings – timelines, everyone in masks, no food allowed, seating arrangements; plexi-glass barriers; designated separate entrance and exit doors; alternate blocked parking spaces; reduce/eliminate the number of seats in cafeteria, lobby and common areas; food offered needs to be packaged in break room; increase air flow; change out HVAC filters in buildings; open doors and windows; all visitors, customers, etc. entering our building must wear mask and or gloves; limit number of people in building, kitchen, departments, break room etc.; no pot luck, buffet/self-serve catering.

Emergency response and exposure control include: add eye wash stations and shower pull stations according to SDS for new chemical in use (disinfectants etc.); get eye wash and shower3rd party tested once/year; purchase AED or add supplies to emergency first aid kits including PPE; create sick room/isolation; check first aid kit and AED monthly and teach staff hands only CPR; write isolation protocol for a person who might have COVID-19 but cannot leave building; emergency cleaning protocols.

Communication practices to evaluate include: Identify platforms and backup systems for communication with staff, vendors, suppliers, customers for timely updates and emergency contact systems; choose web based meeting and training platform; update emergency call card and personal contact information; require all visitors to provide contact information for contact tracing purposes and notifications.

Signage must be increased throughout the facility about PPE, social distancing, directional, educational, and warnings. Laminate them so they last longer and train on signs posted. Issue PPE and train on the limitations of how to use, store, clean and replace PPE>

Disinfecting controls- This topic will be covered in the final webinar so we’ll get to those details there.

#4 Two OSHA Documents That You Already Have to Help with COVID-19 Guidance

Right now you might have your COVID Control Plan as separate document, which is fine for time being. In the long term you will want to take integrate it into existing OSHA standards.

Emergency Action Plan (EAP) – 29 CFR 1910.38 (a)

Your EAP covers circumstances involving crime scene, workplace violence/active shooter, fire, severe weather, community problems such as neighbor emergency or community emergency, severe weather, compromised structural building integrity, chemical spill or leak, and loss of utilities. Different circumstances will change how your respond, for example where to meet up will. Your plan should include a one page description for each different circumstance.

The key elements of your EAP are: Reporting emergencies, alarm system, evacuation, critical operations, account for employees, first aid team, communication, appendix. You will add information regarding to COVID-19 into each of these sections. What you should be including is covered in the webinar.

Elements of Exposure Control Plan (ECP)

None of us has an infectious control plan, as only health care has an infectious control plan. Blood-borne pathogens standard may be expanded or a new standard introduced that covers infectious control in all companies and businesses moving forward. The following seven elements applies to a pandemic: 1) Determination of employee exposure, 2) Implementation of various methods of exposure control including universal precautions, engineering and administrative controls, PPE, housekeeping, 3) Hepatitis B vaccination, 4) Post exposure evaluation and follow, 5) Communication of hazards to employees and training, 6) Record keeping, and 7) Procedures for evaluating circumstances surrounding exposure incidents. You will add information regarding to COVID-19 into each of these sections. What you should be including is covered in the webinar.

Signs are covered by 29 CFR 1910.145. Educational and directive posters about PPE, social distancing, and handwashing are available for free from CDC. You also need to post: staying home when sick, cough and sneeze etiquette, and signs and symptoms of covid19.

#5 I Didn’t Know I Needed To Do All That To Disinfect and Clean Safely

We’ve all been cleaning and now we need to add disinfecting into process.

Here are a few tips to get you started with keeping your workplace clean and disinfected. Don’t share tools, desk, phones, laptop or have a plan for cleaning them between uses if they are shared. Provide a tissue box per desk and have employees empty their own trash can. Provide trash cans that opens with foot pedal or have an open top. Make sure your antibacterial gel contains 60% alcohol or more. Train employees on correct handwashing and provide posters for the process. Clean all personal work spaces yourself at the start, mid, and end of your day. Clean and disinfect all contact surfaces such as door handles, phones, computers, laptops, cafeteria spaces, appliances, shared seats, shared work services, bathroom door handles, sink, toilets etc.

Housekeeping 20 CFE 1915.81 provides guidance.

Make sure you are choosing chemicals that are EPA approved. Here is a list of a few that you probably already know: Clorox, Fantastik All Purpose Cleaner, Scrubbing Bubbles, Lysol, Soft Scrub Bleach, Arm & Hammer Wipes, Comet, Windex, Oxivir, and Sani-cloth. Get the safety data sheet for all products using. Make them available to employees and train them how to read them. You may not realize this, but you mMust keep SDS for all chemicals used for 30 years, so create active and inactive files to store them.

Who is going to do your cleaning? If you’re hiring a cleaning company they must be held accountable to all these standards. You will also be considered a Multi-Employer Worksite. Be sure to pre-qualify them with a pre-qualifying questionnaire, by checking osha.gov, getting a copy of professional licenses and certification training records, requesting their COVID-19 Site Safety Plan, Safety Data Sheets, insurance certificates from the insurance company, and a copy of their W9. If you are doing the cleaning yourself, you need to be responsible: labeling, SDS, signage, storage, what and where to clean, trash, training on safe chemical combinations. Details of the elements involved in these topics are covered in more depth in the webinar.

The number 2 most frequently cited finding during safety inspections is hazardous communications. You need to have a written program, training, materials inventory, labeling and SDS’s as part of your hazardous communications plan.

There are cleaning and disinfecting guidelines for rooms or areas occupied by those with suspected or confirmed COVID-19 that are put out by the CDC. More guidance is provided in the webinar about PPE and hygiene, cleaning hard (non-porous) surfaces, cleaning soft (porous) surfaces, electronics, linens and clothing and other items that go in the laundry, sanitation, trash receptacles, handwashing, UV lights, NFPA guidelines for flammable liquids and more.

This series had provided you with an outline of what you need to consider, as well as tips, details and links to delve deeper. For more information about the new course “Navigating a Pandemic” or about how to get assistance with your COVID-19 Safety Site Plan, contact Kristy Grignon, Marketing Director at

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