COVID-19: Leaving the Shelter and Getting Back to Business Safely: FACS Update #7

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As we begin looking to lift shelter in place restrictions, organizations are confronted with figuring out how to adjust to the “new normal” of operating safely in the presence of COVID-19. This starts with recognizing the purpose behind the effort:

  • Protect People. Help prevent employees, customers, and other stakeholders from contracting COVID-19, and in doing so protect the greater public health.
  • Protect Resources. Help minimize liabilities related to worker’s compensation claims and 3rd party litigation by showing appropriate diligence in controlling COVID-19 risks.
  • Protect Reputation. Help support business continuity by instilling confidence within customers, stakeholders, and local public health entities, that your organization can operate safely.

To this end, FACS is partnering with our clients to develop and implement COVID-19 safety plans. The key elements of these plans are discussed below.

Prevention. Have protocols in place for operating safely with COVID-19. These are developed through the following process:

  1. Identify the Risks. Look at your different areas, activities, and workflow both inside and outside the building. This typically starts as big picture review and dials down to specific operations, tasks and locations. Where will people be, who will they encounter, what will they touch, and can we make any changes to reduce risk?
  2. Control the Risks. Determine actions to take, tailored to specific activities, that will reduce risk of infection. Eliminate or reduce in-person contact when possible (e.g., staggering schedules, limiting the amount of people in a space, using on-line meetings, closing off portions of buildings, using physical barriers). Modifying behaviors and remaining diligent with physical distancing, hand hygiene, and disinfection of frequently touched surfaces will likely still be needed for some time. Use of personal protective equipment (e.g., gloves, respirators/N95s), masks, face shields), while a critical component, is typically viewed as a last line of defense. Medical monitoring/evaluation may also come into play to catch potential cases and help determine who is at risk and who isn’t. These measures are then translated into safe practices documents and supporting forms/tools for use by various stakeholders, which in turn help with the next steps.
  3. Communicate. Train/educate employees, customers, and other stakeholders on how you are identifying and controlling risks as we progress through different phases of the COVID-19 pandemic. Regular communication is critical as new facts are learned, public health guidance changes, and safe practices are adjusted.
  4. Validate. Observe your safe practices in action and document that they are being followed. Identify areas for improvement and modify them as needed.

Response. Have protocols in place for responding to known or suspected COVID-19 cases. These may increase in the future if the projected “second wave” of infection comes to pass. A basic framework for case response is as follows:

  1. Impact Assessment. Follow the most up to date, reputable guidance when determining who and what was potentially impacted. This involves obtaining a history of the case and their interactions with the subject environment and people during a “period of concern” when they were potentially infectious. Determination of who may have been exposed should consider the nature of interactions and what infection control practices were being followed. Determination of what surfaces and areas were impacted should consider the degree of impact and frequency of use, and lead to a scope of cleaning/disinfection or closure of work areas.
  2. Communication. Inform affected parties (e.g., other employees, clients) of assessment findings and response actions. This can help to ensure proper precautions are taken and help to reduce anxieties about the safety of an environment. Exposed parties may be subject to quarantine or enhanced medical monitoring.
  3. Cleaning/Disinfection. Clean/disinfect per the scope determined during the assessment. Care should be taken to ensure proper use of disinfectants (e.g., EPA registration, application method, contact time, safety precautions). Ensure that the proper scope and methods for cleaning/disinfection are documented through oversight of activities and post-cleaning assessment.
  4. Monitoring & Closure. Enhanced monitoring for symptoms and routine preventative cleaning/disinfection should continue through the end of the “period of concern” during which exposed parties may show symptoms and the virus may survive on surfaces. Closure of the response should include compilation of all documentation and address issues of medical criteria for cases to return to the subject location as appropriate.

Re-occupancy. Buildings subject to long-term closure (especially rushed closures) may present non-COVID-19 environmental health concerns. Degradation of water quality due to biological pathogens or chemicals (e.g., Legionella, lead) is not uncommon. Other issues include water damage and mold growth, build-up of common contaminants, expired products, pests, and disruption of HVAC system functionality. In addition, changes to workflow or partial area closures may be part of a safe re-occupancy plan depending on the operations and environments involved. Assess and address these concerns prior to re-occupancy and then communicate them to returning occupants in order to help reduce anxieties and support a smoother transition back.  This communication will also help ensure they follow the necessary plans and prevent need for future case-related response actions.

Readiness. As the pandemic continues to evolve, be prepared to adjust to changing conditions. Be cognizant of differing conditions on the ground in different locations and with associated differences in orders and guidelines from national, state, and local public health authorities. Having a dedicated internal team working with supporting outside partners to monitor and adapt to the latest developments is critical in protecting people, resources and reputation.

Shifting disruptions due to COVID-19 are likely to be with us for a long time in some form until a vaccine or game-changing treatment is available. As we all adapt our organizations and families to this “new normal”, the team at FACS is prepared to provide our environmental health expertise to help you and your organization navigate these challenges.