Compliance: the useful weapon to fight COVID-19 until we get a vaccine
By: Kyle Tretina
Tags: Compliance, Covid 19

Sofia Perea, PharmD, PhD, MCSO

Confinement measures are gradually being lifted across the world, with many countries starting to allow certain businesses to reopen. While it is a critical step for businesses and economies, easing the lockdown presents a key challenge for companies: how can the government and the employers ensure a safe return to the workplace for employees (1)?

No business wants to be responsible for another outbreak. Being liable for risking the health of employees or customers would not only pose a threat to the business’ reputation, but it could also potentially lead to further disruption and a temporary shutdown of operations. Employers do need to be as safe as possible in reopening, because for many firms, especially smaller ones like restaurants and retailers, being forced to shut down again due to a workplace outbreak would likely lead to bankruptcy. Lastly, the companies could also run the risk of legal action (1).

COVID-19 has created unprecedented business and regulatory disruption in a very short period of time. We are witnessing the massive changes on how companies operate, what regulators and supervisors expect, in addition to significant economic impacts on society, businesses and individuals. The pandemic’s effects have triggered extensive government action including the largest ever peacetime stimulus package in the US: The Coronavirus Aid, Relief and Economic Security (CARES) Act (3). However, Unions criticize the Government, in particular the Department of Labor, due to the lack of emergency rules for the pandemic. Thus, in June, OSHA rejected the Union’s demand for an Emergency Temporary Standard (2). In situations where COVID-19 is not compensable under a state’s workers’ compensation laws and neither the federal government nor the state has enacted legislation to protect employers from liability, employers might consider the use of employee waivers to limit their liability. However, regardless of the protection available through applicable laws or waivers, employers are required to maintain a safe workplace and comply with all of the various and changing guidance and regulations applicable to their particular workplace (3,4).

During these uncertain times, compliance will be a valuable tool to help for business to make decisions quickly by deploying frequent and dynamic risk assessments to assist the companies with the ability to respond. Compliance teams can protect their companies if they implement robust, tailored policies and plans to keep employees safe. Clear and rapid pathways for communication and escalation are also critical as this becomes a new normal. By adapting quickly and planning for the new and emerging risks and challenges, compliance teams can help mitigate risk and support business strategy for organizations to successfully navigate this crisis (5).

The risk assessment should include outlining the size of the workforce, the identification of vulnerable employees, the nature of the work carried out by employees, the level of contact with the general public, and the location and layout of the office. Once these factors have been identified, the compliance team can determine whether the company has a low, medium or high exposure risk, based on WHO’s and CDC’s criteria (6,7). Once the risk assessment is conducted, the company can develop policies or measures to mitigate the risks as far as possible. Specifically, businesses should take the following preparedness actions before allowing employees back to the company site (8):

Promote healthy hygiene practices such as hand washing and employees wearing a cloth face covering; Check temperature of the employees; Intensify cleaning, disinfection, and ventilation in the workspace; Encourage social distancing and enhance spacing between employees via physical barriers, changing layout of workspaces, closing or limiting access to communal spaces, staggering shifts and breaks, and limiting large events; Adapting/modifying travel and commuting practices; Promote telework for employees in appropriate roles who do not live in the local area; and Train all employees on health and safety protocols. All these recommendations are directed to business and companies. But what about individuals? What is the role of compliance in the behavior of the citizens?

It is clear that the society globally and the citizens individually are playing a significant role in the spread of the disease, by implementing preventive measures. Some people argue, based on political reasons, that the use of masks does not prevent COVID-19. There is already a research study that demonstrates that political conservatism, in addition to religious orthodoxy, conspiracy ideation and intellectual curiosity indirectly affect compliance with COVID-19 prevention guidelines through trust in science (9). Let me explain it: COVID-19 risk perception and trust in science predict compliance with COVID-19 prevention guidelines; specifically, individuals who perceive COVID-19 as a serious threat and those who have greater trust in science and scientists are more likely to act in accordance with the proposed guidelines. On the contrary, individuals who are higher on political conservatism, religious orthodoxy and conspiracy ideation trust science to a lesser degree, which in turn leads to a lower level of compliance with the preventive measures (social distancing, wearing masks, hand wash). The opposite is true in the case of intellectual curiosity; participants high on intellectual curiosity trust science more, which in turn leads to a higher level of compliance with COVID-19 prevention guidelines (9).

The use of face masks on healthy people during the coronavirus pandemic has been a major point of contention and confusion among scientists and the public (10). To me, it is as simple as watching this video (11). It is important to highlight that as much as 40% of COVID-19 cases are asymptomatic (12). But if the video doesn’t convince you that

wearing a mask prevents COVID-19 spread, you just need to read the recent report published by the CDC (13). It shows that the universal use of masks within communities is a critical tool to fight against COVID-19, by preventing people who have COVID-19 from spreading the virus to others. The review includes two case studies, one from JAMA, showing that adherence to universal masking policies reduced SARS-CoV-2 transmission within a Boston hospital system (14), and one from CDC’s Morbidity and Mortality Weekly Report (MMWR), showing that wearing a mask prevented the spread of infection from two hair stylists to their customers in Missouri (15).

And now, let’s review the use of masks throughout the US. In a recent article published in The New York Times, it was clear that in some counties, it is hard to spot even one person outside without a face covering. Those places are, in general, areas that have experienced a lot of COVID-19 cases. In others, the odds of seeing many uncovered is quite high (16). Despite these variations, the rates of self-reported mask use in the United States are above the mean (59%), compared to other countries.

As a conclusion, let’s be compliant with the current guidelines (social distancing, wear masks, wash hands frequently) to prevent disease spread that are easy to follow, and leave the tough task of discovering a vaccine to the researchers.

References

COMPLIANCE AND COVID-19 Moving to a new normal. https://www.oliverwyman.com/content/dam/oliver-wyman/v2/media/2020/apr/Oliver_Wyman_Compliance_and_COVID-19_paper.pdf

The union battle versus Trump administration over bringing workers back, safely. https://www.cnbc.com/2020/07/10/as-workplaces-reopen-unions-ask-trump-admin-where-is-osha.html

https://uptontech.com/security/regulatory_compliance_in_business_1/

Returning to Work: COVID-19, Workers’ Compensation, and Employee/Consultant Waivers. https://www.whitecase.com/publications/alert/returning-work-covid-19-workers-compensation-and-employeeconsultant-waivers

The CARES Act Works for All Americans. https://home.treasury.gov/policy-issues/cares

Considerations for public health and social measures in the workplace in the context of COVID-19. https://www.who.int/publications/i/item/considerations-for-public-health-and-social-measures-in-the-workplace-in-the-context-of-covid-19.

Resuming Business TOOLKIT Coronavirus Disease 2019 (COVID-19) https://www.cdc.gov/coronavirus/2019-ncov/downloads/community/Resuming-Business-Toolkit.pdf

COVID-19: Top tips for a low-risk return to the workplace. https://www.lexology.com/library/detail.aspx?g=79a3680d-4a16-41ed-a6bf-f1094baeae8c

Plohl N, Musil B. Modeling compliance with COVID-19 prevention guidelines: the critical role of trust in science. Psycho, Health & Med 2020. https://doi.org/10.1080/13548506.2020.1772988

WHO says there is no need for healthy people to wear face masks, days after the CDC told all Americans to cover their faces. https://www.businessinsider.com/who-no-need-for-healthy-people-to-wear-face-masks-2020-4?IR=T

https://mail.google.com/mail/u/0?ui=2&ik=c29b7c359b&attid=0.1&permmsgid=msg-f:1674889173817346163&th=173e66d46387c873&view=att&disp=safe

Oran DP, Topol EJ, Less S. Prevalence of Asymptomatic SARS-CoV-2 Infection. Ann Int Med 2020. https://doi.org/10.7326/M20-3012

CDC’s Information on Cloth Face Coverings. https://www.cdc.gov/coronavirus/2019-ncov/prevent-getting-sick/diy-cloth-face-coverings.html

Brooks JT, Butler JC, Redfield RR. Time for universal masking and prevention of transmission of SARS-CoV-2. JAMA. https://jamanetwork.com/journals/jama/fullarticle/10.1001/jama.2020.13107

No Transmission of Symptomatic SARS-CoV-2 After Significant Exposure With Universal Face Mask Use at a Hair Salon — Springfield, Missouri, May 2020. https://www.cdc.gov/mmwr/volumes/69/wr/mm6928e2.htm?s_cid=mm6928e2_w

A Detailed Map of Who Is Wearing Masks in the U.S. https://www.nytimes.com/interactive/2020/07/17/upshot/coronavirus-face-mask-map.html