TOP TIP: CDC Provides Coronavirus Guidance to Employers
Last month, pending official guidance for employers from the Centers for Disease Control on how to address Coronavirus (which has now been named COVID-19), we provided recommendations to employers in our January Top Tip – Coronavirus in the Workplace: A Practical Guide for Employers, which extrapolated from CDC guidance on past outbreaks. Now, the CDC has issued guidance specific to COVID-19 that offers suggestions for employers to take now to address illness generally in the workplace, to plan for a possible COVID-19 outbreak in the U.S. and to consider in developing an outbreak response plan.
Recommended Strategies to Use Now. We summarize the CDC’s detailed recommendations as follows:
- Actively encourage sick employees to stay home. The CDC also encourages employers to ensure their policies are consistent with public health guidance, and are flexible with regard to caring for sick family members. It also recommends that employers communicate with their temporary staffing agencies about sick employees and leave policies. It further suggests that employers should not require return to work clearance from doctors, who may be too busy to provide timely notes.
- Separate employees who become sick at work from other employees and send them home.
- Emphasize respiratory etiquette and hand hygiene. Provide posters to remind employees, as well as tissues, no-touch disposal containers, alcohol-based hand sanitizer, and soap and water.
- Perform routine environmental cleaning of frequently-touched surfaces. Provide disposable wipes for additional cleaning.
- Advise employees before traveling to check the CDC’s updated Traveler’s Health Notices, to self-monitor for signs of illness, and obtain any necessary medical care.
- Employees with sick family members should notify their supervisors and refer to CDC guidance for risk assessment.
- If an employee has confirmed COVID-19, notify co-workers so they can conduct a risk assessment as to potential exposure, while maintaining confidentiality as required by the Americans with Disabilities Act.
Planning for a Possible Outbreak. The CDC asserts that employers should be prepared to respond in a flexible way. It identifies some key considerations in determining appropriate responses:
- Disease severity in the community.
- Impact of the disease on vulnerable employees, such as those who are older or with chronic medical conditions.
- Preparation for increased absences. This includes business continuation plans, cross-training employees, and possible changes to business practices (e.g. alternative suppliers, prioritizing clients, partial suspension of operations) to ensure maintenance of critical operations.
- Authorize local managers to take appropriate action based on conditions at separate facilities.
- Coordination with state and local health officials.
Developing an Infectious Disease Outbreak Response Plan. The CDC suggests that any plan be flexible, with input from employees. Employers should review the plan in a manner that will identify gaps or problems. Employees should be educated as to the plan. Employers should share best practices with other businesses. The CDC provides the following recommendations for a plan:
- Identify possible work-related exposure and health risks to employees.
- Review policies and practices to ensure consistency with public health guidance and workplace laws.
- Explore social distancing strategies such as telecommuting and flexible work hours to increase physical distance between employees, and minimize contact with the public.
- Identify essential business functions, essential jobs or roles, and critical elements within supply chains, and plan for disruptions to these.
- Set up authorities, triggers, and procedures for activating and terminating the outbreak response plan, altering business operations, and transferring business knowledge to key employees.
- Plan communications on the outbreak plan and COVID-19 information.
- Institute flexible workplace and leave policies for employee and family illness, as well as possible school closures.
- Learn about the public health plan for the local community. Establish channels of communication with local public health officials.
- Consider canceling non-essential business travel per CDC guidance, as well as large work meetings or events.