Information contained in this publication is intended for informational purposes only and does not constitute legal advice or opinion, nor is it a substitute for the professional judgment of an attorney.
The Centers for Disease Control (CDC) recently issued a roadmap of critical tasks for employers ready to get their staff back in the office. To date, the majority of guidance has focused on workplaces that remained open during the pandemic, from healthcare to retail and manufacturing. Those workplaces have already received guidance and taken measures to help minimize the potential risk of exposure to COVID-19. Now, it is time for those workplaces vacated during the pandemic to do the same. Office spaces are top of the list, and the CDC’s guidance provides recommended steps to take in office settings to mitigate the risk of COVID-19 transmission. To accomplish these tasks, coordination among stakeholders, including building owners, managers, operations specialists (including security, custodial services, etc.), tenants and all those employed by these entities may be crucial.
Planning to Reopen
The CDC recommends that employers begin planning even before they reopen their offices by maintaining open communication with building management and reopening only once the building is ready. Any reopening plan should first account for the unique hazards that can arise in a building left unoccupied for several weeks. Mold may have developed, and rodents or other pests may have infested the premises. Stagnant water might be toxic. In particular, the CDC highlights the need to evaluate the status of mechanical, life safety, ventilation, air conditioning, heating, and similar vital systems. Some of these systems may require specific start-up procedures. Building staff can consult ASHRAE Standard 180-2018, Standard Practice for the Inspection and Maintenance of Commercial Building HVAC Systems, and determine how far in advance of reopening the systems should be started and tested.
Improving Air Ventilation
After addressing these hazards of dormancy, the CDC recommends considering ways to improve ventilation and COVID-19’s airborne spread. These include:
- Increase the flow of outdoor air, for example by using economizer modes of HVAC operations after verifying compatibility with HVAC system capabilities for both temperature and humidity control;
- Disable demand-control ventilation controls that reduce air supply based on temperature or occupancy;
- Open windows to improve natural ventilation and dilute indoor air if safe to do so (this may pose particular challenges in high-rise settings);
- Increase air filtration, inspecting filter housing and racks to ensure appropriate fit, and checking for ways to minimize filter bypass;
- Consider redirecting airflow between office spaces, adjusting the position of supply and exhaust air diffusers to establish strategic pressure differentials;
- Consider using portable high-efficiency particulate air (HEPA) fan/filtration systems to enhance air cleaning (especially in higher-risk areas);
- Ensure exhaust fans in restroom facilities are operating at full capacity when the building is occupied; and
- Consider using ultraviolet germicidal irradiation (UVGI) to help kill the virus.
Rearranging Physical Workplaces and Schedules
Changes to common spaces could be necessary. Redesigning or rearranging reception areas, routes of entry and exit, meeting rooms, breakrooms, cafeterias, and other areas where employees congregate can reduce foot traffic and allow for proper social distancing to reduce potential COVID-19 transmission. The CDC’s specific recommendations include:
- Encourage social distancing by spacing seats and workstations. This may require removing chairs or posting notices prohibiting their usage;
- Where rearrangement is less feasible, employers may consider installing transparent shields or other physical barriers;
- If neither distancing nor barriers are feasible, post signs, or visual cues like floor tape placed six feet apart to indicate where employees should stand;
- Assign employees to workplaces with cleaner and better-ventilated air;
- Encourage use of outdoor seating areas for any small group activities such as lunches, breaks, and meetings;
- For building managers, limit use of elevators to maintain social distancing; and
- Replace high-touch communal items, such as coffee pots, water coolers, and bulk snacks, with alternatives like pre-packaged, single-serving items.
Relatedly, the CDC recommends employers not only consider rearranging the workplace, but carefully arranging when employees use that space. Employers may stagger employee shifts and break times, as well as guests’ visits. To further control the pace of traffic in the workplace, employers may consider posting signs in parking areas and entrances that ask guests to phone from their cars to inform the tenant or building security when they reach the building.
Training Employees in Preparation to Reopen
In reopening, the CDC recommends that employers post information, communicate directly with employees, host trainings on proper safety protocols, post information online and use posters and signage in the workplace. Such information should focus on the risks of asymptomatic transmission, social distancing and self-isolation when necessary, proper protective equipment, personal hygiene, and relevant leave policies. Many governmental authorities are requiring certain COVID-19-related training. The CDC has provided a variety of free posters in several languages that employers can download, print, and post in high-risk common areas to educate employees and guests about COVID-19 and healthy precautions.
Policies to Promote Healthy Conduct in the Workplace
Having involved employees through training, the CDC encourages employers to consider other policies to mitigate COVID-19 exposure by adjusting employee conduct, including:
- Testing employees daily in person or virtually for high temperature or other COVID-19 symptoms before entering the office. In doing so, employers should strive to maintain social distancing between employees during such checks. The CDC has provided further guidance on conducting such checks here.
- Recommend or require that employees and guests wear masks or face coverings in the workplace, at least in common areas, while accommodating individual employees who may have trouble with their usage. Sometimes a face shield can be used instead.
- Prohibit handshaking, hugs, and fist bumps at work.
- Remind employees to wash their hands often with soap and water for at least 20 seconds, and/or make available and promote the use of hand sanitizer where appropriate.
- Evaluate how employees commute to work. The CDC suggests incentivizing employees that bus or carpool to switch to commuting alone by providing some sort of reimbursement.
- Clean and disinfect high-touch surfaces in accordance with the CDC’s Guidance for Cleaning and Disinfecting, including workstations, keyboards, telephones, handrails, printer/copiers, drinking fountains, and doorknobs. Involve employees by providing them with disposable wipes and similar materials to wipe down surfaces before contact.
Further Guidance on Addressing COVID-19 Cases in the Workplace
Lastly, the CDC expands on its earlier guidance with suggestions on how employers may address cases of COVID-19 in their workplace or workforce.
- Encourage employees with COVID-19 symptoms or who live with a COVID-19-positive person to notify their supervisor, stay home, and self-isolate until healthcare providers deem them fit to return to work.
- Immediately separate employees who become symptomatic while at work, provide them a facemask/face covering if necessary, send them home, and have them follow up with their medical provider.
- Consider asking employees who report COVID-19 symptoms or have a diagnosis disclose their recent personal contacts, at least in the workplace, so that employers can identify where and how other employees might have been exposed.
The new guidance follows several other documents the CDC and other agencies have provided to employers in meeting the challenges of the current pandemic, including:
- CDC Interim Guidance for Businesses and Employers (COVID-19)
- CDC General Business Frequently Asked Questions
- NIOSH COVID-19 Workplace Safety and Health Topic
- OSHA Guidelines on Preparing Workplaces for COVID
- AIHA Reopening: Guidance for General Office Settings
- Building Owners & Managers Association International: Getting Back to Work: Preparing Buildings for Re-Entry Amid COVID-19
The CDC recommendations undoubtedly impose a burden on employers, exacerbated by additional state and local requirements. At least one high-rise office building has reported its reopening plan exceeds 40 pages. Reopening will not be easy.