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.