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COVID-19 Re-Opening: How to Create an Exposure Control Plan

Even though the curve has flattened, COVID-19 is and will remain a significant threat until a vaccine or treatment is found. Accordingly, provincial governments are making it clear that there’s a price employers will have to pay to re-open and remain open until the danger subsides: creation and implementation of a workplace COVID-19 exposure control plan. Because the challenge is so unique, there’s nothing in your current HR handbooks that will meet the immediate need and you’ll need to build your plan from the ground up. Here’s how to do that. There’s also a Model Plan template on the HRI website you can adapt for your own use.

What’s At Stake

An exposure control plan is a set of measures to protect workers, clients, customers, contractors, visitors and other people at your workplace against exposure to COVID-19 infection and ensure compliance with your obligations under OHS laws and public health guidelines. Alberta, BC, Ontario, Québec, Northwest Territories and Nunavut are among the jurisdictions that have expressly stated that having such a plan in place is a condition for re-opening. While you don’t have to submit the plan to the government for approval, you do need to make it available to all workers, their representatives and government OHS officials. (Note: In Alberta, you also have to post your plan on either your website or in a conspicuous location in the workplace.)

This is more than a mere formality. If you don’t have the right exposure control plan in place, OHS and public health inspectors can hit you with hefty fines and even shut you down. Failure to implement an effective plan also heightens the risk of liability and lawsuits by persons claiming to have contracted COVID-19 at your facility, including massive class action suits if you experience outbreaks or clusters of infections.

Bottom Line: The stakes are incredibly high.

Creating the Exposure Control Plan

Best Practice: Designate the HR director or other competent individual who understands the OHS laws and public health guidelines to serve as COVID-19 coordinator responsible for creating and implementing the plan. If possible, the coordinator should carry out these responsibilities in consultation with not only management but also the workplace joint health and safety committee (JHSC), health and safety representative (Rep) or directly with workers if there is no JHSC or Rep. And while the COVID-19 exposure control plan is something novel, you can base it on your current OHS and HR policy templates, starting with a statement describing the plan’s purposes (Plan, Sec. 1) and an allocation of roles and responsibilities (including management, the coordinator, supervisors and workers) (Plan, Sec. 2). But the heart of the exposure control plan are its 9 sets of safety measures.

1. COVID-19 Hazard Assessment

The starting point is to identify and assess the COVID-19 hazards at your workplace. Because the virus is so contagious, no workplace is exempt from infection risks; but what does vary from workplace to workplace is the nature and degree of risk. That’s why you need one or more competent persons to carry out a COVID-19 hazard assessment. Best Practice: Base the hazard assessment on job classification and rank exposure level as Very High, High, Medium and Low considering the following COVID-19 risk factors:

  • Physical distance of employees from co-workers, customers and other persons at the site between and/or employees and customers;
  • Effectiveness of current ventilating, air circulation and HVAC systems;
  • Operations requiring close contact, e.g., sharing of vehicles;
  • Age, respiratory or immune disorders, or other chronic medical conditions or physical characteristics making persons at the site unusually susceptible to COVID-19 infection; and
  • Availability of respirator masks and other necessary PPE.

(Plan, Sec. 3.1)

2. COVID-19 Field Level Hazard Assessment

In addition to the job classification assessment, a competent worker or supervisor at the site should carry out a field level assessment before the shift to verify that the required safety measures are in place and immediately notify the person in charge of safety if something is amiss. Work shouldn’t begin until the field assessment comes back clean or the cited problems are corrected (Plan, Sec. 3.2).

3. COVID-19 Safety Controls

The next phase of COVID019 exposure control is to select measures to address identified infection hazards based on the findings of the job classification exposure assessment following the standard “hierarch of controls,” i.e.:

  • Totally eliminating the hazard if reasonably practicable, e.g., ceasing all operations requiring workers to have close contact;
  • If elimination isn’t reasonably practicable, using engineering controls like air-circulating and ventilating systems or physical partitions, to minimize hazards;
  • Using safe work procedures and other administrative controls affecting how hazardous operations are carried out instead of in combination with engineering controls to minimize exposure; and
  • As a last resort where COVID-19 hazards can’t be eliminated via engineering and administrative controls, requiring exposed workers to use PPE.

4. Social Distancing Measures

Once business re-opens, employers must ensure that people at the workplace maintain the required 6 feet/2 meters of separation from each other. The exposure control plan must describe all the things you’re going to do to meet that massive challenge, e.g., physical workplace configuration, occupancy limits, bans on large meetings or gatherings, etc. (Plan, Sec. 5).

5. Medical Screening

Public health agencies and privacy regulators have given the green light for employers to medically screen workers and others seeking entrance to the building for COVID-19 symptoms as long as screening measures are safe, fair, consistent, nondiscriminatory and as minimally privacy invasive as possible. So, make sure your exposure control plan explains your screening measures and the safeguards taken to keep them within the legal limits (Plan, Sec. 6).

6. Self-Isolation & Quarantine Measures

Explain the policies and procedures you’ll use to bar workers (or others) who test positive for, exhibit symptoms of or are at otherwise at high risk of infection due to travel or direct and recent contact with a person that has COVID-19 from entering or remaining in the workplace. Such procedures should also provide for removal, transport, communication and ultimately return to work of workers in self-isolation (Plan, Sec. 7).

7. Sanitation & Infection Control Measures

Describe the sanitary, cleaning and disinfection measures you’ll take to minimize COVID-19 infection risk, which at a minimum should include:

  • Frequent and regular cleaning and disinfection of surfaces, equipment, door knobs, sinks, handles, keyboards, light switches and other touch points with products approved by Health Canada;
  • Keeping wash rooms accessible, clean and amply supplied with soap, water and paper towels;
  • Requiring workers to wash their hands frequently while at and immediately before leaving the facility;
  • Posting notices demonstrating proper hand washing techniques in wash areas;
  • Implementing safe work procedures for the handling of mail, packages, materials and goods entering and exiting the work site; and
  • Requiring all workers to use “respiratory etiquette” and properly cover their mouth when they cough and sneeze.

(Plan, Sec. 8)

8. PPE

PPE is an absolute must, particularly where encounters between people closer than the prescribed social distancing 6 feet/2 meters can’t be avoided. For the vast majority of worker, i.e., those falling into the Medium or Low exposure risk classifications, a non-medical face mask and perhaps protective gloves should also be adequate. Healthcare and other workers in the Very High and High risk classification need more elaborate PPE, including at a minimum, an N95 or other tight-fitting particulate respirator, gloves and an apron. Workers who make direct and close contact with COVID-19 patients or handle lab specimens will also need face masks, goggles, protective clothing and, in some cases, more elaborate respiratory protection, e.g., SCBA respirators (Plan, Sec. 9).

9. Safety Training & Instruction

All workers exposed to COVID-19 infection risks should receive safety information and training covering, at a minimum:

  • How the virus spreads;
  • The fact that there’s currently no vaccine for COVID-19;
  • How to reduce the risk of infection;
  • The measures you’ve taken to minimize infection risks; and
  • What to do and who to call if they believe they’ve been exposed.

(Plan, Sec. 10)