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Create Exposure Control Plan to Avoid COVID-19 Crackdown

OHS inspectors are issuing fines and shutdown orders for COVID noncompliance.

I know. . . You get it and you’re sick and tired of hearing this stuff. But if preventing infection isn’t motivation enough, follow these guidelines to protect your business from OHS penalties and shutdowns. Take it from us. The COVID-19 crackdown that is about to be unleashed is like nothing we’ve seen in our decades of covering OHS compliance.

But COVID Infection Control Is Real

If you don’t believe us, just ask the 2 BC businesses that felt the wrath of WorkSafeBC, including:

  • A Dairy Queen in Parksville where inspectors observed a crowd of customers not practicing social distancing barriers and nobody enforcing the supposed 5-person capacity maximum; and
  • A Prima Pizza in Summerland which didn’t have a COVID-19 safety plan.

The good news is that the orders issued to these 2 establishments were the only ones WorkSafeBC had to impose after inspecting 1,594 restaurants, bars and cafes across the province.

And it’s not just BC. All jurisdictions are intensifying their OHS enforcement efforts to ensure businesses comply with current COVID-19 public health restrictions, including Ontario which recently announced plans to hire 98 new health and safety inspectors this fall, bringing the total number of active MOL inspectors to 507. The first priority for the new inspectors: COVID-19 compliance, naturally.

Implement Exposure Control Program

Be sure to implement a COVID exposure control plan, i.e., 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.)

But the heart of the exposure control plan are its 9 sets of safety measures. You can use the Model on the HRI website as a template for creating your own policy that meets your individual needs.

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)


Model COVID-19 Hazard Assessment Policy
Model COVID-19 Hazard Assessment Form

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).


Model COVID-19 Hazard Assessment Policy
Model COVID-19 Field Level Hazard Assessment Form

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).


How to Create a Social Distancing Policy
Model Workplace Social Distancing Policy
Social Distancing: Using Paper Logs to Perform Low-Tech Contact Tracing
Model Social Distancing Contact Log Sheet

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).


The 10 Things to Include in Your Medical Screening Policy
Model COVID-19 Pre-Screening & Temperature Checks Policy
Model COVID-19 Medical Screening Form

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).


Compliance Cheat Sheet: When Is It Safe for Workers with COVID-19 to Return to Work?
You Make the Call: Is This a Valid COVID-19 Screening & Quarantine Measure?

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)


How to Create a Workplace Cleaning and Disinfection Policy 

Model Workplace Cleaning and Disinfection Policy 

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 workers, 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).


PPE: 10 FAQs on Workplace Use of Face Masks to Prevent COVID-19 Infection 

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)