Post COVID-19 Employer Playbook

Employers have an obligation to maintain a safe and healthy work environment for all employees. This includes implementing preventative measures and mitigating all occupational health and safety (OH&S) risks associated with COVID-19. Failure to ensure a safe workplace can lead to OH&S liability, including fines and penalties, and in serious cases, criminal prosecutions. Federally regulated employers are obligated to comply with Canadian Occupational Health and Safety Regulations.

 

To meet safe workplace obligations, it’s important to consider the physical work environment, the readiness of your people (including training and communications) and the establishment of on-going workplace practices and supporting policies.

 

Below are links to other OH&S resources relevant to our industry:

Canadian Centre for Occupational Health and Safety

Infrastructure Health & Safety Association

Many fleets have either assigned individuals or a group of people (including pandemic committees) with managing the company’s response since the start of the pandemic.  You may keep the same individual, or groups of people, in charge of returning to work protocols as well.  What matters most is that people are assigned the responsibility, and are accountable for ensuring all return to work measures are implemented according to the appropriate regulations and guidelines, documented, and communicated to employees and customers.

Depending on the size of your organization, a recommended best practice would be to establish a cross-functional pandemic committee. The purpose of this committee, initially, is to identify new hazards as they relate to COVID-19 and to establish ways to mitigate or eliminate identified new risks. It is also to ensure accountability for key on-going areas of responsibility by creating and assigning roles, such as:

• Site Management – overall responsibility for the site’s pandemic preparedness & response plan, coordinating and aligning with other business locations and ensuring on-going compliance and best-practice awareness.
• Control Access Lead – implements and maintains all social distancing logistics within the building – including: common spaces, logistics for arriving and departing shifts, as well as, entry requirements for visitors and contractors.
• Cleanliness, Sanitization & Disinfection Lead – Ensures a thorough cleaning, sanitation and disinfection process is completed prior to re-opening. Manages on-going cleaning, sanitization and disinfection processes. Drives continuous improvement and ensures 100% compliance with the Company’s protocols.
• Communication & Training Lead - Manages all pandemic related communications, in coordination with leadership and HR. Manages and monitors training requirements, delivery and completion logs.
• PPE & Materials Lead - Secures all necessary supplies to implement and sustain the site pandemic preparedness and response plan, for opening and on-going demand. Keeps up to date on PPE protocols and implements best practices as available.

By distributing responsibility, extra resources for awareness and enforcement are secured. If your organization already has a site-specific Occupational Health and Safety committee, this could be an ideal starting place for the cross-functional committee. Ensuring there is adequate management and employee representation, you may also want to include individuals from:

·       Health and Safety	·       Human Resources	·       Procurement
·       Facilities	·       Finance & Accounting	·       IT & Security
·       Management	·       Executive	·       Other (site-specific)

 

Other Considerations:

• Communicate to all employees the purpose of the Pandemic Committee, who is on it and their specific area of responsibility (as applicable).
• Design detailed responsibility expectations for individuals assigned to key roles outlined above.
• Establish on-going committee meeting times and agenda items.
• Establish an escalation process for key decisions.
• Ensure committee members are trained on H&S and PPE requirements.

The first step in ensuring readiness for returning to regular, on-site business operations is preparing the building. The information provided in this section will outline general best practices that you can take to mitigate workplace safety risks and prepare your building for the safe return of your workforce.  It’s recommended to refer to specific requirements outlined in the Canadian Occupational Health and Safety Regulations to ensure full compliance.

 

Hazard Assessment

 

Conducting a hazard assessment for COVID-19 transmission in the workplace is a base level requirement to comply with OH&S legislation. A basic walk through the workplace to identify specific conditions or tasks that may increase the risk of exposure of COVID-19 to employees is recommended. You will have a duty to seek input from your employees (management and non-management) on where potential transmission may occur and how they think COVID-19 transmission can be controlled. This can be done through joint health and safety committees and/or by establishing a pandemic committee – see below.

Ensure all decisions related to the revised workplace health and safety protocols, resulting from COVID-19 risks, are properly documented. You will be responsible for making reasoned decisions that take into consideration governmental and public health guidance with the overall goal of meeting the employer’s duty of care to employees.

 

Cleaning & Disinfection Measures

The goal is to establish a sanitary baseline before the facility opens. The facility should be shut down, cleaned and 100% disinfected prior to anyone returning to work. Signage should be used to identify areas that have been cleaned and disinfected. Those areas should have minimal or no disruption after being cleaned.

Tight controls on who can entry the premises during the shutdown should be taken. Minimal people should be allowed to enter the facility. Document anyone who enters the facility, including external cleaning contractors.

Providers or employees should sanitize and disinfect all areas of the site with special attention given to:

¨  Workstations ¨  Computer screens and keyboards ¨  Washrooms ¨  Cafeterias or Lunch Rooms ¨  Lockers, Showers, Changerooms ¨  Common surface areas	¨  Meeting rooms ¨  Reception ¨  Door handles ¨  Shared equipment ¨  High touch areas (railings, door handles, etc)
¨  It is also recommended to replace or clean/disinfect HVAC air filters.

The safest way to prevent the spread of COVID-19 is to reduce physical contact between employees. Thoroughly reviewing and understanding ways to promote physical distancing through workspace configuration and engineering controls is critical to preparing your building for safe operations.

Workspace configuration will include the physical set up of the workspace to ensure physical distancing of at least 2 meters in space for employees to complete as many workplace tasks as possible.

In high risk or high traffic areas, engineering controls (such as physical barriers) may be required.

When conducting a walk-through of the workspace, take the time to enact or perform required tasks to get a true sense of physical risks. Physical distancing precautions should include risks from on-site employees, drivers, visitors, suppliers, and other members of the public.

 

Specific considerations:

• Rearrange workspaces and floor plans, including increased separation between desks or workstations, converting multi-occupant offices into single-occupant spaces, arranging furniture in common areas such as lunchrooms, waiting rooms and meeting rooms. Removing chairs to enforce physical distancing in common spaces is an example.
• Take special care in high traffic and high-risk areas such as washrooms, showers, lunch rooms, meeting rooms, and other shared spaces.
• Install physical barriers between workers and workers and third parties where required. For example, reception, between workstations that physically touch, etc.
• Create markers to promote physical distancing where needed. For example, taping off every second urinal in a men’s washroom and implementing signage to reinforce new expectations.
• Ensure the introduction of COVID-19 measures do not introduce new occupational health and safety risks.
• Remove communal items that cannot be physically cleaned, such as newspapers, magazines, and candy bowls.
• Limit the number of riders per elevator or entry in other confined spaces.
• Reduce or eliminate the sharing or physical transfer of workplace materials – paper, tools, equipment. Where sharing is required, establish practices where disinfecting is required between uses.
• Consider opportunities to use technology as a way to minimize physical contact and interactions.
• Policy and procedure changes that are required to enforce the measures you will take.

Where workspace configuration and engineering controls are deemed inadequate and/or as an added precaution, employers should consider the implementation of personal protective equipment (PPE).

Ensuring that adequate supplies of PPE are ordered and available for the first day of on-site operations is imperative and for a minimum of 30-days of operations.

 

Specific considerations include:

 

• Ensure fire extinguishers, eye wash stations, first aid cabinets and AEDs are filled/stocked/inspected as appropriate and accessible.
• Determine PPE stock requirements based on number of employees and amount of PPE allotted per day.
• Ensure a system is in place to track PPE usage and communicate needs for replenishment.
• Verify a process for the on-going distribution of PPE supplies (masks, gloves, face shields, etc.).
• Develop or source proper use of PPE employee training.
• Implement a practice for holding employees accountable for wearing PPE.
• Establish locations for hand sanitizer stands. Consider building entry points, high traffic common areas such as photocopy stations, lunch rooms and reception.
• Ensure there is a defined process to restock masks and other PPE for drivers.
• Stock disinfectant wipes for cleaning personal workstations throughout the day.
• Verify all washrooms have soap, water, paper towels and toilet paper, and other facility sinks have soap, water and paper towels.
• Consider adding more restrooms if needed for social distancing.
• Determine if touchless thermometers will be used for employee screening. Order if they will be.

• Face masks: this is a critical risk mitigation to reduce the spread of COVID-19, especially where social distancing cannot consistently be practiced. Use of face masks for all employees should be considered. At a minimum, employees with broad exposure to others should be required to wear face masks. The company should consider the pros and cons of reusing face masks and the use of employee supplied face masks that meet World Health Organization specifications (handmade masks are not recommended).
• Medical grade face masks: it’s important to have a supply of medical grade masks in case of suspected or confirmed site contamination.
• Face shields: face shields provide extra protection and may be required where close contact (within 2 meters or 6 feet) is required.
• Protective Eye Wear: where face shields cannot be worn and close contact is required, protective eye wear (with side shields) may be considered for use with a mask.
• Gloves: current research indicates that hand washing and sanitization are more effective than gloves. Gloves may not be a mandatory requirement for all. You may want to supply gloves for short-term use while using centralized and commonly shared equipment. Gloves may also be required to be worn to protect against facility cleaning and sanitation products.
• Medical Grade Nitrile Gloves: it’s important to have a supply of medical grade nitrile gloves in case of suspected or confirmed site contamination.

 

Communication and training on the protocols and proper use of PPE is required.

People flow congestion can lead to a reduction in physical distancing and therefore, an increase in risk. Ensuring an effective practice for controlling the flow of people before, during and after work shifts is a critical component to creating a safe work environment (see also Scheduling Considerations).

 

Specific considerations include:

 

• Determine the best way to control the flow of people for building entry and exit (for example, establishing an entry/exit only location or door).
• Implement a signage system to clearly mark entry and exit points.
• Consider whether emergency evacuation plans need to be updated to address changes to entry and exit points.
• Is there a way to create a one-way traffic flow system throughout the building to allow safe distancing in hallways?
• Implement visual cues to ensure distance is maintained, for example taping physical distancing lines where people might wait (photocopier, washroom, vending machine).
• Pre-determine the number of people allowed in common-space areas such as lunchrooms, locker rooms, washrooms, and meeting areas. Create signs to indicate entry restrictions. For particularly high-traffic areas, consider posting an employee at the entry point to monitor ins and outs.

Ensuring the safety of all employees requires the implementation of protocols for both drivers and on-site workers. Having drivers adhere to the safety guidelines, outlined by Transport Canada, will reduce the risk of COVID-19 entering the work premises. Additional considerations for drivers may include:

 

• Building access restrictions – driver to office and office to driver;
• Hazards and cleaning protocols related to driver lounges, accommodation areas, and showers; and
• Communication and training for drivers on updated building protocols, policies and expectations.

Some employers are choosing to delay the return to work process, beyond when they are legally able to return to on-site work. Others are electing to have small groups of individuals with essential on-site functions return to work when allowed. Should you choose to have employees continue to work from home, a work from home policy and ergonomics assessment may be useful for maintaining on-going, safe, at-home operations.

 

Work from Home Policy

Many employers, forced to implement work from home structures, have limited or no formalized policies and practices to mitigate the risks associated with remote work arrangements. Taking action now will help decrease current risks and enhance opportunities to offer more flexible work from home arrangements in the future.

 

You may wish to consider some or all of the following for work from home policies and processes:

 

• Ensure your work from home policy addresses mandatory and optional work from home arrangements.
• Establish processes and controls to address data security, privacy requirements, and the acceptable use of company equipment.
• Remind employees of their obligation to keep company information safe and secure.
• Determine what standard safety protocols will be required (such as fire protection, emergency evacuation procedures, electrical safety,
• Provide guidelines and best practices for safe at-home work.
• Understand and communicate what parts of the home are included in the workplace and establish a process for safety inspections. These should be consistently applied across your workforce.
• Inform employees of their obligation to report workplace injuries and establish an incident investigation process.
• Outline details on company and employee supplied equipment and furniture.
• Support proper ergonomics for at-home work (see Self-Assessment – Work from Home Safety & Ergonomics).
• Establish work from home health and safety requirements and have employees agree to a work from home health and safety statement.
• Decide if and how work from home expenses are covered (for example telephone and wifi charges, office supplies, technical support).
• Establish company expectations for work hours and attendance obligations.
• Formalize structures to reinforce attendance expectations, such as morning and afternoon check-ins or computer monitoring (if deemed necessary). Inform employees of the company’s expectations and monitoring practices.
• Inform employees how breaks and overtime can be logged.
• Apply the same attendance monitoring practices to all employees, unless increased measures are being taken to monitor under performance, in which case, it needs to be outlined as a disciplinary measure.
• Notify employees that all workplace policies (including discipline policies) apply when working from home.
• Determine if in-person business meetings can be held within a person’s home (post-COVID).
• Clarify what job roles will be permitted to work from home going forward.
• Establish evaluation criteria to ensure on-going work from home is effective (at the organization and individual level).

If employees continue to be able to work from home in any capacity, establishing proper ergonomics is important to reduce workplace injuries associated with poor work station set up. The self-assessment attached below can be customized and distributed to employees. You may wish to use it as an employee assessment tool or to collect back and retain as confirmation of proper set-up.

 

Work from Home Safety & Ergonomics Assessment

Once the building has been prepared and the decision is made to return people back to work on-site, it’s important to invest time in preparing your people for a safe and productive return.

 

Scheduling Considerations

After conducting a thorough hazard review of the building, it’s important to consider how the following scheduling factors can impact potential risks to your employees:

• Scheduling work-shifts;
• Lunch and break schedules;
• Washroom visits; and
• Transportation to work.

Scheduling Work-Shifts:

Limiting the number of employees (and others) within the workplace is a recommended measure to reduce COVID-19 related risks. Adjustments to employee schedules may be required to realize on-site reductions. Conducting a thorough review to determine who returns to work when, and how, is necessary. Specific decision prompts to help with the planning process may include the following:

• What percentage of our workforce can safely return to work at the same time based on physical distancing guidelines and your building hazard review assessment?
• Is there an opportunity to phase in a return to work plan (for example, start with 25%, then 50%, then 75%, then 100%)?
• Is there an opportunity to create A & B groups (or more) so that employee groups only report to work certain days of the week?
• Can start-times be staggered to reduce people flow congestion at building entry points?
• If lay-offs were performed, what will the call-back process and timeline be?
• What are the job functions that would benefit from working on-site due to technology requirements and efficiency concerns?
• Is there an opportunity to have employees self-select when they return to work?
• Are there PPE supply concerns that will require a reduced on-site workforce?
• Is there an opportunity to adjust operating hours (stagger start and end times) to manage people flow and maintain physical distancing?

Other considerations include:

• Ensure scheduling decisions are founded in business need to avoid potential discrimination or “favouritism” complaints.
• Ensure current workplace policies and employment agreements allow for changes to schedules.

Lunch and Break Schedules:

To control the flow of people within common spaces, assigning specific times for lunch and breaks throughout the day may be required. Remember to allow for enough separation in assigned break/lunchtimes to wipe tables, eating surfaces, refrigerators, vending machines and microwave ovens. Employees should be reminded (and provided time) to wash their hands and/or use hand sanitizer before and after eating on-site.

 

Washroom Visits:

If there are multiple facilities available within your building, consider restricting access to each of the facilities by proximity to individual work stations or locations. Ensure maximum capacities are labelled on the entrance and consider a way to denote the number of occupants to be viewed within a safe physical distance (for example, occupied signs per available occupant). If washroom facilities are shared with other building occupants, speak to the landlord about how facilities will be monitored and managed to ensure physical distancing requirements are met.

 

Transportation to Work:

Understanding that commuting to work on public transportation can increase the risk of exposure to COVID-19, employers should consider the following:

• Will changes in public transportation schedules (if applicable) affect employee ability to come to work, and on-time?
• Can additional PPE be provided for the employee’s commute to and from work?

If the employer provides company-sponsored transportation in any capacity, the following should be considered:

• If transportation is provided by a third-party vendor, have the health screening, cleaning and disinfection, and safety protocols of the vendor been vetted?
• Will employees be provided PPE for use on company-sponsored transportation?

Accommodation Considerations

COVID-19 introduces a variety of unique challenges that employees are facing that could lead to them not being able to return to work at a physical location at this time. Employers should consider, plan for and address the following situations:

 

• High-Risk Employees: Certain individuals may be at a greater risk of contracting COVID-19 or of having more severe complications from COVID-19 should they contract it. Further, they may live with someone who is at a higher risk of contraction. To effectively identify and respond to accommodation requirements for individuals within your workplace with increased risks, you may want to implement:

• A self-disclosure policy so that employees can disclose that they are higher risk (without disclosing personal details or sensitive medical information).
• Mitigation measures should the employer become aware that an employee is at higher risk.

Employees may require special accommodations due to personal medical or physical restrictions (or because they live with someone with increased risk). Special consideration should be given for people:

·       Aged 65 and over;	·       Women who are pregnant;
·       With serious heart conditions;	·       Who are immune-compromised;
·       That are severely obese;	·       With diabetes;
·       With chronic kidney disease who               are undergoing dialysis;	·       With chronic lung disease or           severe asthma;
·       With liver disease;	·       With cancer; and
·       Individuals with hypertension.

 

• Employees with childcare issues or who are required to care for a sick relative: Individuals who cannot return to the workplace due to childcare, or care for a sick relative, may require special accommodations (to the point of undue hardship). They may be eligible for unpaid job protected leaves. Employers should consider:

• Accommodation requirements under the Canadian Human Rights Act – specifically as it relates to family status and disability. Accommodations may include the requirement to continue to allow the employee to work from home, adjust work schedules, or provide extra time off.
• The Canadian Labour Code’s Leave Related to COVID-19 - temporarily in effect (until October 1, 2020 at the time of playbook distribution). For this leave, a medical note is NOT required. The leave provides 16-weeks of unpaid job-protected leave for employees who are:
  • being quarantined or asked to self-isolate as a result of COVID-19
  • being required to provide care to a family member as a result of COVID-19, or
  • otherwise unable to work for reasons related to COVID-19

• Employees concerned about workplace safety: Subject to Part II of the Canadian Labour Code, workers have a statutory right to refuse work if they believe that there is reasonable grounds that the work constitutes danger to their personal health and safety. This includes their right to refuse “to work in a place” they believe is dangerous. Should an employee deem the worksite to be unsafe, the employer must follow the work refusal process: 

• The employee reports the hazard or area of concern to the employer.
• The employer shall investigate the situation in the presence of the employee and provide a resolution if necessary.
• If the employee disagrees with the decision or resolution, the employee can continue to refuse to work and has an obligation to advise the employer of their continued refusal. The employer must conduct an investigation by the workplace committee or representative. A formal written decision report must be generated.
• If the employee still disagrees with the employer’s decision, they shall notify of their continued refusal to work and the employer shall immediately inform the Ministry of Labour who will conduct an investigation of the worksite.
• The employer has an obligation to comply with Ministry recommendations and findings or to file an appeal.

An important part to preparing your employees for re-entry into the physical work environment, is understanding if they have any specific concerns, fears, accommodation requirements, or other restrictions that should be addressed prior to their coming back to work in an on-site location.

A template ‘Employee Readiness Survey’ is included below. This template can be used as is, or with modifications, to gather necessary return-to-work information from your employees.

This survey can be conducted in a number of ways, your work environment and norms will dictate the best method for distribution for your workforce. Some examples include:

• One-to-One Discussion with Manager: Managers can personally reach out to members of their teams and talk through the survey information. This method allows managers an opportunity to provide on-the-spot responses or reassurance and it provides the ability to probe for additional information on accommodation requirements. Be sure managers are fully versed in legislative obligations for accommodation and that they understand that no promises should be made to employees during these discussions.
• Survey Automation Tool: Human Resources can load the survey questions into a survey tool (like Survey Monkey), so that information return is centralized and automated. This method provides an opportunity to assemble company- and department-wide statistics for analysis, presentation to senior leaders and decision making. Follow up and clarification would be additional work.
• Document Distribution: The provided template can be branded and sent to employees with the request for information to be returned to managers or centrally to Human Resources.

Employee Readiness Questionnaire

Along with increased protocols that may prevent individuals with minor ailments from working on-site, COVID-19 has introduced new physical, emotional and economic pressures for employees. As such, you may experience higher than normal absenteeism. Proactively establishing plans to address absenteeism will be imperative to minimizing business disruptions.

Specific considerations include:

• How will employees who are asked to stay home (due to symptoms that may or may not be COVID-19 related) be documented? Determine when and why they will still be required to work from home.
• Establish an escalation process for managers and employees should disputes about attendance, accommodations or unique individual circumstances arise.
• Provide/remind employees and managers how and when to report absences.
• Determine if there will be additional flexibility to your attendance policy due to concerns from COVID-19. Amend and communicate related policy and process changes to managers, employees, payroll and/or human resources as required.
• Document company and government legislated leave options for easy reference.
• Familiarize managers with updates to employee documentation requirements for certain leaves.
• Determine and document critical tasks by individual and department.
• Formally assign back-up responsibilities.
• Proactively cross-train on back-up duties.
• Vet third-party staffing companies in case of need.

2-Way Communication Best Practices

Creating two-way channels of communication and feedback will help ensure employees are brought back to work safely, commitments and expectations are relayed both-ways, and care and compassion for the overall wellbeing of your people is demonstrated.

Creating a COVID-19 Communication Plan:

 

Ensuring messages are consistently relayed, through a variety of channels, with increased frequency will be key to employee understanding, adoption and belief.

There are a number of ways to provide regular, on-going updates to employees, such as:

·       Personalized letters	·       Company-wide town halls
·       Updates on the Intranet	·       Team meetings
·       One-on-ones	·       Message from the CEO
·       Newsletters	·       Sharing of task force meeting minutes
·       Infographics	·       Training
·       Information videos	·       Q&A sessions

A comprehensive communication plan will include several delivery methods to reinforce key messages and ensure understanding and remembrance. On average, it is though that a person needs to hear a message 7 times in order to remember it.

By way of example, your return-to-work communication plan could consist of the following:

1. All-company video or conference call outlining re-opening plans and timelines.
2. CEO message indicating the company’s commitment to on-going safe operations.
3. Pre-recorded video or all employee call where H&S or HR, specify pre-opening actions taken.
4. Written summary of policy and procedure updates.
5. Personalized letter outlining specific return-to-work details and expectations.
6. An infographic outlining personal responsibilities for the safe return to work.
7. One-to-one discussions with managers to address personal concerns and questions.

When establishing a COVID-19 return-to-work communication plan, consider the following:

¨  What have you done to prepare? ¨  What is left to do to be ready? ¨  Timelines ¨  Policy and process updates ¨  Team, function, committee responsibilities ¨  Escalation processes ¨  Short-term changes

¨  Permanent changes ¨  Expectations of employees ¨  PPE requirements ¨  Why is this being done? ¨  Who does it impact and how? ¨  Who needs to hear this message? ¨  What is the best mode of delivery?

Seeking Employee Feedback:

Seeking and providing opportunities for employees to give feedback is imperative. Employee feedback is a key driver of safety, engagement and continuous improvement. By listening to input from employees, you understand their priorities and as such, can help shape decisions, policies and procedures to prioritize actions.

Remind employees of the feedback channels that already exist, and if possible and required, consider increasing the frequency of formal employee feedback outlets (such as distributed or automated pulse surveys).

Employee feedback channels can include:

·       One-on-one discussions	·       Centralized mailbox
·       Employee surveys	·       Formalized Q&A sessions
·       Designated experts to reach out to	·       Escalation processes

If you seek input from employees, responding is a base-line requirement. The following are tips to help you manage the company’s response process:

• Acknowledge feedback in a timely manner using automation if appropriate/available;
• Communicate standard response times to manage expectations;
• Thank employees for their feedback;
• Communicate back only what is known, if something is unknown, indicate that;
• Create a log of inquiries to help determine frequency of concern;
• Assess logs and determine proactive approaches to address common concerns; and
• Indicate if decisions are made that were the result of employee input.

Sample Employee Communication - Returning to On-Site Work

As part of your Health and Safety responsibilities, it’s very important that all employees understand the safety requirements, protocols and expectations for their safe return to work.

Your current training team may need additional support and/or training themselves in order to fulfill this responsibility. Overall, the key to success will be having someone assigned and accountable for this.

 

You may also consider creating a phased training plan, as some requirements will take place in the early stages (i.e. when the building is being prepared) and different employee audiences will require different messages.

Phased Training Plan Example:

 

PHASE	TRAINING CONTENT	AUDIENCE	MEDIUM	TRAINERS
PHASE 1: Preparing the Building	- Roles and responsibilities of pandemic committee - Facility preparation requirements - Hazard identification process and protocols - Safe handling of cleaning materials - Cleaning and disinfection protocols - Contractor vetting protocols - Use, donning and doffing of PPE - Workspace configuration and engineering control expectations - People flow assessment and set up - Signage & physical indicator set up - Escalation process and key contacts	- Sr. Leaders - Pandemic Committee	- Video training	- OH&S Manager - Head of HR - Operations lead
PHASE 2: Preparing Managers	- Roles and responsibilities of pandemic committee - How the building was/is being prepared - Entry/Exit points - Shift and break scheduling - Accommodation obligations - Reporting absences - Daily health check protocols - PPE Requirements (& why) - Donning and Doffing PPE - Escalation process for PPE mis-use - In-person meetings (on & off-site) - Staying safe: physical distancing, hygiene, cleaning protocols & shared spaces - Other policy and procedure updates - Employee communication requirements & best practices - Employee training process	- Site Managers and Leads	- Video training	- OH&S Manager - Head of HR - Operations lead - Pandemic committee members
PHASE	TRAINING CONTENT	AUDIENCE	MEDIUM	TRAINERS
PHASE 3: Preparing Employees	- Roles and responsibilities of pandemic committee - How the building was/is being prepared - Entry/Exit points - Shift and break scheduling - Daily health check protocols - PPE Requirements (& why) - Donning and Doffing PPE - Discipline process for PPE mis-use - In-person meetings (on & off-site) - Staying safe: physical distancing, hygiene, cleaning protocols & shared spaces - Other policy and procedure updates	All on-site employees	- Video training	- OH&S Manager - Head of HR - Operations lead - Pandemic committee members
PHASE 4: Preparing Drivers	- Roles and responsibilities of pandemic committee - How the building was/is being prepared - Health check protocols - Access restrictions (if applicable) - Use of driver facilities - PPE requirements (& why) - Donning and Doffing PPE - Discipline process for PPE mis-use - Staying safe: physical distancing, hygiene, cleaning protocols & shared spaces - Other policy and procedure updates	- Drivers	- Video training	- OH&S Manager - Head of HR - Operations lead - Pandemic committee members

Remember:

• Some subject-matter experts may not be trainers.
• Training should be reinforced through other communication methods.

Control Access Protocols – Employees and Visitors

To ensure the on-going safety of anyone working within the building, controlling entry point access is required.

Specific considerations include:

• Identify all entry points and determine if/how people flow can be re-directed to restrict the number of entry sites (if there are multiple).
• If you use temporary or contract employees from an agency, ensure the agency is made aware of new control access protocols.
• Determine who, outside of on-site employees, will be allowed entry into the building and if restrictions will be implemented within building areas. Restrictions may be implemented even for employees (e.g. will drivers be restricted to driver lounges).
• Post health compliance expectations outside doorways.
• Determine how safe distancing will be maintained in peak times (such as shift start/end times).
• Disable touch screens.
• Ensure each active entry point has a person assigned to monitor and manage to all entry protocols.
• Review how deliveries arrive and implement protocols to minimize in-person contact (for example, there can be a box installed outside the reception door).
• Reconfigure the gathering areas upon entry (such as in the lobby), so that physical distance can be maintained and people are discouraged from ‘hanging out’.
• Decide whether health checks upon entry will be required and establish a process for legislatively compliant execution .
• Set up a sanitizer stand upon entry.
• Establish a process for the safe retrieval of PPE upon building entry – for employees and visitors.
• Create a log of all individuals who enter the worksite with time and date.
• If visitors or off-site employees are deemed access, establish a process for entry, ensure PPE donning and doffing awareness, and have a set process for host employee protocols.
• Implement a review process to review and adjust engineering and people flow requirements as needed.

Example of a simple sign that can be posted outside the door at office entry point(s).

 

Health Check Protocols

Given the nature of COVID-19 and known information on how it spreads, you may need to rely on self-screening in order to restrict the entry of infection to your facility. In addition to self-screening protocols, some employers may choose to install temperature screening. Within Canada, special care must be taken to ensure health checks protocols are compliant with governing legislation, in particular, the Privacy Act and the Human Rights Act. Before implementing health check protocols (of any degree), it is strongly recommended that you get advice from legal counsel. If health check protocols are introduced, they should be consistently applied to all individuals who enter the workplace, including employees at all levels, visitors, delivery persons, or others.

Self-Screening:

To mitigate the risk of COVID-19, employers will rely on a higher level of trust and disclosure from employees. Employers are cautioned that while increased protocols are required to instill health and safety compliance, other governing legislation, such as the Privacy Act, may prevent the introduction of self-screening questionnaires or your ability to directly ask direct questions regarding an individual’s symptoms.

Specific considerations include:

• Consult with legal counsel to determine specific risks, legislative obligations and best practice implementation for employee self-screening.
• Implement a communicable illness policy (see Communicable Illness), requiring employees to self-disclose if they, or someone they live with, has contracted COVID-19.
• Encourage a culture of trust so employees feel safe disclosing confirmed or suspected illness.
• Establish formal escalation and communication channels for employees to report COVID-19 suspected or confirmed illness.

It is strongly advised that employers seek legal counsel prior to implementing a self-screening process.

For additional information on potential legal risks, and best practices, associated with self-screening, you may wish to review this article published by Fasken.

Temperature Screening:

At some worksites, temperature scanners are being implemented based on the fact that one of the primary symptoms for COVID-19 is an elevated body temperature (+38°C or 100.4°F). This is somewhat controversial given that employees who are not ill may have elevated temperatures. Additionally, there are potential privacy concerns (even at the common law level) that may arise from implementing a temperature screening process upon entry.

Given the potential health risks caused by COVID-19 and the infection rates across Canada, temperature screening may be a reasonable health and safety measure in some workplaces. It is strongly advised that employers seek legal counsel prior to implementing a temperature screening process.

For additional information on potential legal risks, and best practices, associated with temperature screening, you may wish to review this article published by Gowling WLG and this article published by Osler.

Safe Package Handling Protocols

It is recommended to practice precaution when handling packages and before allowing their entry into the workplace. When a package is delivered to the workplace, it’s important for the individual handling it to:

• wear appropriate PPE (such as gloves);
• thoroughly clean all package surface areas with a disinfectant;
• transfer the package to a clean, disinfected surface; and
• cautiously remove PPE.

Specific considerations include:

• Designate specific individuals for package handing.
• Ensure designated individuals are properly trained on PPE requirements and safe handling protocols.

Office Cleaning Protocols

On-going building cleanliness will be a required step in maintaining a safe workplace. While many employers have standard cleaning practices in-place already, increasing the scope and frequency of those practices may be required.

Specific considerations include:

• Identify if any additional cleaning protocols are required – by scope and frequency.
• Take special note of items that are not commonly cleaned – for example, coat hangers, posters and picture frames, telephones, handles and knobs, soap dispensers, etc.) and ensure cleaning protocols for these items are established.
• Determine how additional cleaning requirements will be managed – i.e. who is responsible for extra cleaning measures.
• Increase the collection and disposal of waste in common areas, washrooms and meeting rooms.
• Order extra cleaning and disinfectant supplies and any associated PPE.
• Prepare daily/weekly cleaning check-lists, with responsibility assignments.
• Create a monitoring protocol to ensure additional cleaning measures are complete.
• Supply employees with individual cleaning and/or disinfection wipes for their personal workspaces.
• Determine how shared office tools, machines and appliances will be cleaned and disinfected between use (for example, photocopiers, printers, water coolers, coffee machines, microwaves). Employers may wish to provide cleaning supplies and/or disinfectant wipes nearby and inform employees of self-cleaning requirements before and after use.
• If meeting rooms will be open, determine cleaning and disinfection processes and responsibility assignments for before and after use.
• Communicate expectations and updated cleaning protocols to all employees.

Common Space & Meeting Protocols

Social distancing may be more challenging in common spaces and meeting rooms. Ensuring your company has comprehensive plans in place to address if/how employees will gather in these spaces is important.

Common Spaces:

Take careful consideration on how common spaces are used during the preparation of the Building hazard assessment. Configurations of furniture and engineering controls should also take place prior to re-opening the building.

Specific considerations for common spaces include:

• Communicate common space closures and revised expectations based on hazards and re-configuration requirements identified when preparing the building.
• Revise security badges to restrict access to closed common spaces (if applicable).
• Common space areas should be arranged so that entrance and exit directions are indicated with physical markings.
• Social distancing guidelines should be posted.
• Discourage or cancel all non-essential activities, social events and in-person meetings.
• Along with scheduling breaks, consider assigning seating plans in lunch rooms.
• Determine additional cleaning requirements – scope and frequency – and assign responsibility.
• Determine and communicate personal cleaning requirements – for example, after use of microwave.
• Establish an audit process to determine if safe practices are being followed.

Meetings and Meeting Rooms:

In-person meetings are discouraged, however, if your company deems them necessary, participation should be limited to 10 people and video conferencing options should be made for all meetings to accommodate personal health concerns or fears.

Specific considerations for meetings include:

• Create criteria for in-person meetings (if any).
• Determine and communicate personal cleaning requirements at the beginning and end of meetings.
• Social distancing guidelines should be posted.
• Establish and communicate guidelines for when in-person meetings would be required. It’s recommended that this be in extreme circumstances only.
• Provide disinfectant wipes and/or cleaning materials and ensure high-touch items are removed from meeting rooms (for example, remotes for television sets and whiteboard markers).
• Meeting rooms should be arranged so that entrance and exit directions are indicated with physical markings.
• Establish an audit process to determine if safe practices are being followed.

Reinforcing New Workplace Practices

Once employees are back working in the company’s physical work location, everyone has a responsibility to maintain a safe and healthy work environment. Expectations will be heightened due to COVID-19. The employer will have a responsibility to reinforce new workplace practices.

Specific considerations include:

• Remind employees of personal responsibilities for health and safety to reduce risks associated with COVID-19 (see Hand Washing Infographic).
• Adhere to designated shift changes and pre-scheduled lunch and break assignments.
• Establish formal and informal channels for employee feedback (see Sample Survey – Employee Safety Impressions).
• Require strict adherence to the proper use of PPE.
• Ensure “prevention” supplies are well stocked (including hand-soap, tissues, paper towels, disinfectant wipes, PPE, and hand sanitizer).
• Create and adhere to in-depth cleaning processes and schedules.
• Communicate COVID-19 symptoms so that employees can recognize if they have them.
• Allow employees increased flexibility to stay home or work from home if they are sick.
• Commit to continuous communication by establishing a communication schedule (for example, daily written updates, weekly conference calls).
• Provide training to ensure on-going compliance. Special consideration should be made to the areas that are proven most effective for preventing the spread of COVID-19.
• Determine the short- and long-term role of the Pandemic Committee.
• Formalize individual roles and on-going responsibilities for the Pandemic Committee.
• Produce, communicate and enforce a progressive discipline process for employee non-compliance to new policies and procedures.

Infographic – Hand Washing

Frequent and proper handwashing is one of the most proactive and effective ways to prevent the spread of COVID-19. Employers are encouraged to display hand washing reminders in common spaces and near sinks. Here is an example of a handwashing infographic designed by the Government of Canada that you can download.

Sample Survey – Employee Safety Impressions

To ensure on-going safe work practices, it’s recommended to ask for feedback from employees, to gauge their comfort levels with the current health and safety practices, and to gain input into their ideas on improvement areas. A sample safety impression survey, that can be distributed to employees either as a stand-alone document or through a survey tool, is attached above.

With increased pressures and forced changes that employees are experiencing come increased stress and uncertainty. Employers have an obligation to create both physically and psychologically safe work environments; that includes supporting the mental health of your employees.

 

Each workplace is different, just as individual employees are unique. Implementing a multitude of practices in the area of mental health that address awareness, provide resources and address training needs will be beneficial.

 

Below, you will find examples of actions you may choose to implement to support the mental health of your employees.

 

Examples for consideration include:

 

• Review programs available through your Employee Assistance Program or other group benefits providers.
• Proactively source local mental health organizations and communicate/post their contact information.
• Provide flexibility in expected outcomes for employees who have additional personal responsibilities and/or are demonstrating increased levels of stress due to COVID-19.
• Train managers on the importance of and how to create strong relationships with their team members and demonstrate empathy.
• Train employees on warning signs and communicate when and how to get help.
• Send weekly self-care tips and videos.
• Encourage well-being calls where the purpose is to check in to see how the employee is doing.
• Demonstrate recognition and appreciation for hard work and extra-effort.
• Engage with experts to provide wellness training (such as yoga, meditation, nutrition and sleep).
• Encourage physical fitness by providing access to fitness videos or creating fitness challenges.
• Provide opportunities for your employees to give back to their communities (especially those deeply affected by the pandemic).
• Reinforce the company’s commitment to mental health and de-bunk stigmas through executive messages.
• Establish and train a team of mental health ambassadors so that employees know they have someone to talk to. The Mental Health Commission of Canada has designed a Mental Health First Aid training program that may be of benefit to your company.
• Demonstrating care for your employee’s physical safety helps ease mental health stress. Establish and enforce sound health and safety protocols.
• Be aware that social interactions will continue to be challenging as offices maintain physical distancing practices. Determine ways to foster “connections”.
• Provide a forum for employee-generated content on mental health (such as an employee intranet).

 

Additional Resources:

 

• The Government of Canada has created a resource site for federally regulated employers that includes guides, tools and tips for both employers and employees.
• The Canadian Centre for Occupational Health and Safety (CCOHS) has developed a Healthy [email protected], hub of tools and resources to support employers in their efforts to address psychological health and safety in the workplace.
• The Mental Health Commission of Canada has an employer resource site with a number of guidelines, tools and trainings to help employers improve mental health literacy at work.

Be Prepared

Given the contagious nature of COVID-19, developing a proactive infection prevention and control plan, even after taking all reasonable and responsible actions, will allow you to respond and not react if an on-site infection, or suspected infection occurs.

Specific considerations to prepare your workplace for an infection:

• Designate an emergency response team.
• Establish a specific enclosed room to isolate any person identifying themselves with symptoms.
• Train the emergency response team on communication with local health authorities, extra safety precautions, emergency PPE requirements (surgical mask, nitrile gloves, face shield), and location of isolation room.
• Collect and make available regional numbers for COVID-19 testing sites and public health.
• Determine an escalation process for suspected and confirmed infections – on-site and off-site.
• Source cleaning vendors who are capable of performing deep and enhanced cleanings.
• Inform employees of the protocols and who to notify if they suspect or are confirmed positive for COVID-19.
• Advise employees who have been tested for COVID-19 to stay home until negative test results are received.
• Develop an emergency response plan. Examples of areas that may be included in the plan are: notification process (internal and external); employee communication requirements; process to determine exposure risks; business continuity plan; employee support; infected employee absence protocols and return-to-work requirements; enhanced facility cleaning requirements; and site re-opening criteria and protocols.

Should an outbreak occur in your facility that is deemed reportable for Occupational Health and Safety purposes, investigators will likely request a copy of preventative actions taken and your emergency response plan.

Responding to a Suspected Case

If an employee contacts you to advise that they suspect they may be infected, it’s critical to act with the utmost urgency and to respond with the assumption that the person is positive.

Specific considerations if an employee is suspected of infection include:

• If the employee is on-site, immediately advise a member of the designated emergency response team.
• The response team member must don all required emergency PPE.
• Ensure the employee is provided a surgical face mask and nitrile gloves. Explain to them that it is to help protect other employees and prevent the spread of a potential virus. The employee should stay within 2 meters of anyone else.
• Call public health to notify them that an employee is presenting with COVID-19 signs.
• The employee should call their own physician or if the situation seems to be serious, emergency medical assistance should be sought immediately.
• Public health may provide guidance on how to handle transporting the worker home, if there are notification requirements to other parties and if it’s recommended to close the worksite.
• Obtain details from the employee on exposure risks by asking who they interacted with, for how long and which parts of the building they went to in the recent days. If it’s possible, do this at the office by telephone, or follow up with the employee at a later time.
• If the situation is not an emergency, determine how the infected person will be safely transported out of the building and to a testing site. If they can drive, use of their personal vehicle is preferred. If they cannot drive, they should be driven by a member of the designated emergency response team.
• Safely dispose of the PPE worn by the emergency response team member and potentially infected employee.
• Decide if, and to whom, communication is required. It is recommended that communication, even if there are not a lot of details, be done as soon as possible. For example, we have a suspected but not confirmed case of COVID-19 from an employee. They are currently being tested. Further updates will come as available. The communication should not mention the name of the individual who is potentially infected.
• Notify individuals who may have come into personal contact with the potentially infected employee. The objective is to provide potentially exposed employees with sufficient information to obtain medical advice or be tested. To protect personal privacy, do not provide personal details or identifiers of the potentially infected individual but do provide details on when and where they may have come into contact.
• Direct the employee to stay home and self-isolate until their test results are confirmed.
• If the employee is unable to be tested, the employee should stay home for the required 14-day self-isolation period. Provided they are clear of any symptoms, they can return to work then.
• Deep cleaning of the work areas where the employee came into direct contact is required.

Responding to a Confirmed Case

Employers who are notified of a confirmed case must ensure every precaution is taken to limit the risk of spread among other employees.

Specific considerations when responding to a confirmed COVID-19 case include:

• The positive employee should not be on-site because, once tested, employees would have been advised to stay home until test results were confirmed. If, however, those directions were ignored and the employee informs you of a positive result while on-site, follow the protocol outlined in the first 4 bullets above.
• Determine if the employee has been on-site within the last 14-days.
• If they have not been on-site for 14 days, ensure they stay home and only return to work when medically cleared to do so. Advise of work or leave requirements based on attendance policies.
• If they have been in the facility within 14 days, immediately action the emergency response plan, which may include partial or complete closure of the facility.
• Communicate to all employees, advise that there is a confirmed positive case, and relay non-personal details that may help employees determine their need to be tested.
• Communicate one-to-one with any individuals who may have come into personal contact with the infected employee. The objective is to provide potentially exposed employees with sufficient information and to advise of their need to be tested. To protect personal privacy, it is recommended not to provide personal details or identifiers of the infected individual, however, in the case of strong health and safety risk, there might be a requirement to provide specific details those that may have come into contact with the individual so that they can better assess their personal risk.
• Prevent employees who would have come into close contact from returning to work until a negative test result is obtained, or if testing is not possible, after a 14-day self-isolation period.
• Advise employees who have come into close contact of their responsibility to inform the employer if they do test positive or if COVID-19 symptoms present.
• Generally, there is not an obligation to report a positive case to workers compensation authorities, unless it is clear that the employee was infected due to workplace exposure. If it is clear that the infection was due to workplace exposure, you may be required to report it.
• Thoroughly clean the facility, using the pre-determined protocols set out in the emergency response plan.
• Communicate with employees on the protocols and precautions being implemented.
• Determine when the site or specific contaminated area(s) are safe to re-open.
• Inform employees of the re-opening date and additional safety protocols (if any) to be followed.
• Seek feedback from employees in the days/weeks following.

The on-set of COVID-19 has brought with it unique and challenging employment issues that may warrant revisions to some employment practices and policies, and/or require the introduction of new ones.

For any non-standard policy revisions, it is recommended to seek legal advice.

Your company may have implemented temporary policies in response to new workplace challenges. Generally, it’s advised to inform employees that these policies are in effect “until further notice”.

 

Business Travel

COVID-19 has presented new challenges that may impact business travel. A review of both short-term practices and long-term policies is likely required.

You may wish to consider some or all of the following for business travel policies and processes:

• Be aware of, comply with, communicate and enforce all federal and provincial government travel restrictions. Government of Canada travel health notices can be found here.
• Review if increased approval levels (for business travel within and/or outside the country) may be required as an interim measure to mitigate travel risks.
• Create a process to centrally log all business travel – employee, dates, location, flight numbers, hotels.
• Implement a standard or centralized booking process, through a corporate department or external corporate travel vendor.
• Encourage bookings that include cancellation clauses.
• Vet airline and hotel COVID safety practices and restrict bookings to those that have the strictest standards.
• Discourage crowded public ground transportation (e.g. shuttles, buses) and encourage ride-share and taxi services.
• Institute a PPE requirement during travel (ground and air) if the employee will not be in their personal vehicle while COVID risks are still high.
• Limit or restrict car-pooling for business travel until otherwise deemed safe.
• Make employees aware of increased risks if business travel is to an area with higher COVID cases.
• Review travel insurance and group benefits policies to understand employee and employer coverage limitations.
• Revise business travel policies to include COVID or other pandemic specific language, such as the requirement to self-quarantine and work remotely, or to take a leave of absence consistent with government quarantine protocols. Advise on how the employee will be compensated during this time.
• Create an escalation process for employee work-refusals related to increased safety risks. Each situation will need to be individually reviewed and may require legal counsel.

 

Time Off

It’s important to review how your company’s time off policies affect both employee and employer expectations and obligations during emergency situations (such as COVID-19) and beyond. Employers are encouraged to maintain a safe work environment which may mean decreasing risks of infected, or otherwise ill employees, entering the workplace. Increased flexibility in time off policies will discourage people to stay home when needed.

You may wish to consider some or all of the following for time off policies and processes:

• Determine what time off policies and standard practices already exist within the organization – vacation, sick, disability, personal days, other employer sponsored leaves – and how these policies are impacted by COVID-19.
• Expressly state how quarantine periods will be handled (i.e. paid and from what bucket or unpaid and claimed through government subsidies).
• Know when and how to issue employees who are on an unpaid leave a Record of Employment (ROE).
• Temper expectations of managers. Employees who are unpaid during self-isolation periods, or other leaves, cannot perform services for work.
• Note legislated job protected leaves that relate to COVID-19 such as the Canadian Labour Code’s Leave Related to COVID-19. Employers cannot request a doctor’s note for this leave.
• Determine if there will be flexibility in the borrowing of days from different paid time off balances – such as using vacation days as sick days. If new permissions are granted, ensure payroll is informed and update HRIS processes and controls.
• Decide if additional paid days off will be granted for a COVID-19 related leave. Expressly outline what the additional days are intended for and apply the discretion consistently. Communicate the update and advise if the change is temporary and to when.
• Be flexible on what absences require a doctor’s note. To promote a safe work environment, employees with minor illnesses may stay home due to the symptoms.
• Determine and communicate the progressive disciplinary process for policy mis-use.

 

Communicable Illness

If your workplace doesn’t already have a communicable illness policy, it’s a good idea to implement one. This will ensure required measures for managing the unique challenges associated with communicable illnesses (such as COVID-19) can be enforced.

A communicable illness policy may include the following requirements:

• That employees must notify their manager if they have been exposed to a communicable illness as identified by the Government of Canada.
• That employees who have, or suspect that they may have, a communicable illness seek appropriate medical treatment and follow medical recommendations.
• That the employer can enforce worksite access restrictions, and instill mandatory quarantine periods, if a communicable illness risk is disclosed or identified.
• Paid and unpaid leave entitlements available to employees affected by a communicable illness;
• The ability for employers to restrict business travel to high risk areas.
• Confirmation that the employer will instill, and take all necessary reasonable precautions, to uphold their workplace health and safety obligations.
• The company’s commitment to remain informed and educated on communicable illness risks and to act in accordance with the most current guidance available from medical and government sources.

 

Employment Agreements

In some cases, employers without adequate employment agreements have been left with restricted options in response to COVID-19. Employment agreements should be reviewed for the following:

• Temporary layoff clause
• Termination clause
• Provisions to change duties, compensation and work location

Additionally, employment agreements should be reviewed to determine validity (i.e. it was signed by the employee prior to the hire date or date of other consideration).

Public Health Agency of Canada Steps for COVID-19 self-assessment

 

Canadian Centre for Occupational Health and Safety Transportation Industry Coronovirus Tips

 

Human Resources Professional Association COVID-19 Resources

 

Infrastructure Health and Safety Association Transportation COVID-19 Resources

 

Government of Canada Coronovirus Portal