Cleaning & Disinfection: Cleaning and disinfecting may require additional steps (including reviewing and renegotiating - contracts with vendors that provide these services), such as: Extra cleaning and disinfecting, including attention to employee common use areas, and o items handled by customers; and Making cleaning supplies/hand sanitizer available to employees (and customers/visitors). o
Safety Communication Plan: Employers should develop a safety communication plan for returning employees that: - Explains safety protocols (what measures the company is taking and what precautions o employees should take), and where to report any issues. References any benefits or perks the company is making available (plus a potential reminder o about employee assistance programs). Potentially establishes an employee safety committee to satisfy safety planning obligations in o certain jurisdictions and provide a clear line of communication with employees. Note: These safety plans may take on particular importance given likely increase in OSHA o investigations and issues as workplaces reopen in mass.
Telework: - Employers should expect that for a wide variety of reasons, employees may request to continue teleworking even as workplaces reopen. Employers should consider impacts on management, communication, and staffing as certain operations are on site while other employees (or entire teams) continue to telework, perhaps permanently. Additionally, employers should ensure their HR teams are prepared to respond to requests for reasonable accommodations/flexible work arrangements that would have been denied before the COVID-19 pandemic.
Protocols for Tracking & Reporting COVID-19 Tests: Protocol should include identifying contacts and sharing information as appropriate with public - health authorities, employees, and workplace guests and customers. Employers should take a consistent approach regarding requiring return to work and fitness-for-duty certifications and should monitor guidance from the Centers for Disease Control and Prevention and local public health authorities regarding reporting and contact tracing.
Comprehensive Review of Existing Policies: Businesses have had to navigate mostly unchartered waters as they began to realize the breadth and effect of the COVID-19 pandemic. With the collective experience gained over the last several weeks, reopening the workplace should trigger a comprehensive review of policies/CBA provisions, especially in light of recent federal, state, and local legislation. Some factors to consider include: Leave - Employers should consider how to address leave entitlements for employees’ home and o unable to work remotely as well as updates to policies going forward, including ensuring continued compliance with applicable and recently enacted sick leave laws. Employers may consider monitoring employees’ personal/vacation travel as a safety o measure. Furlough - Employers should consider how to bring employees back from furlough, including o notification, phased rehiring, and potential new hires. Although employers may take advantage of the current instability to target new hires for key o positions, employers should be aware of new laws that require giving priority to furloughed