Loss Control Considerations for Re-Opening General Operations - COVID-19 Pandemic
The COVID-19 pandemic has created unparalleled challenges for business risk managers. As governmental restrictions are relaxed to the point where some employees may return to work, employers need to consider new controls to help reduce the possibility that the virus will spread in the "at-work" workforce.
This guidance is intended for office occupancies and operations. It is general in nature and utilizes our knowledge of the SARS-CoV-2 virus, its methods of transmission and infection, and the appropriate controls as of the date of this writing. Industrial settings, healthcare, and other high-risk settings will require specialized controls. See TMA Loss Control Insights Article Plant Re-Openings after COVID-19 Closures. The information presented is not intended to be all-inclusive. The reader is specifically cautioned that this is a fluid and changing situation and they should always seek and heed the advice of the Centers for Disease Control and all government agencies.
This document presents five phases of activity. Depending on your specific circumstances, you may be able to skip sections. We assume you are the tenant of the building, so you will always want to work with the building owner in consultation with your legal counsel to make sure the changes you need are implemented. You should always consult with legal counsel on all changes you are planning to make.
PHASE I – PRE-ENTRY BUILDING AND EVALUATION
- Communicate with employees and building owners continuously
- Determine if the building was simply shut down quickly, shut down following a formalized protocol, or maintained in operation during the period of absence
- If the building was unoccupied, require inspections of the HVAC systems by qualified contractors to assure that they are in good operational condition. Inspections should include but are not limited to:
- The condition of boilers,
- The condition of HVAC components such as chillers, cooling towers, ductwork, filters, etc. for operational readiness and the presence of mold,
- The condition of interior surfaces for the presence of mold,
- The condition of all water traps and drains,
- And the condition of all emergency systems including emergency lighting, fire alarms, UPS systems, etc.
- Thoroughly flush all water supplies and outlets to assure they are free of Legionella and other bacteria that can collect in stagnate water over a period of time.
- Sanitizing may not be required because studies have shown that the COVID-19 virus does not live longer than seven days on surfaces. However if the building was recently occupied, then sanitizing is recommended per CDC Guidelines.
PHASE II – PREPARING THE SPACE FOR WORK UNDER NEW RULES
- Review and reconfigure work stations to accommodate social distancing.
- Consider temporarily closing worksite amenities such as breakrooms, gyms, etc.
- If break room usage is allowed, then use disposable products such as coffee cups, plastic ware, paper plates, etc. Sanitize countertops, eating surfaces, microwaves, and vending machines after each use. Handles of coffee machines, refrigerators, and ice machines must be sanitized at least three times per day but preferably after each use. Social distancing must be observed and room capacity limited.
- Provide hand-sanitizing stations conspicuously throughout the facility.
- Provide covered trash containers for facemasks near entrances/exits, elevators, and common areas. Empty and disinfect containers at least daily as needed.
- Evaluate the need to limit the capacity of elevators to accommodate social distancing.
- Disabling or reducing the HVAC system as a means of reducing virus exposure is specifically not recommended by The American Society of Heating, Refrigerating, and Air-Conditioning Engineers (ASHRAE). Rather, work with the building owner to increase the percentage of fresh-air make up in the ventilation system to the maximum (preferably 100%) for several hours (four hours minimum), prior to occupancy and then continuously during business hours. Systems could run on minimum outside air during off business hours, but it is preferred to run the systems at the increased fresh air make up 24 hours/7 days per week. Any energy recovery device that could cause exhaust air to leak into the makeup air should be bypassed.
- In addition, work with the building owner to increase the spot efficiency rating of the filters in the air handlers, to the maximum extent possible. ASHRAE recommends, MERV-13 or higher filters. If high MERV filters are not possible, the addition of room air cleaners with HEPA filters could be considered.
PHASE III – DEFINING NEW OFFICE REALITIES
- Employees should wash hands frequently. At minimum washing should be done on the arrival at work, after touching mask or face, after touching any common contact surface, and before departing work. If hand washing causes congestion or delays, the use of alcohol-based hand sanitizers is acceptable.
- If social distancing (six feet at minimum) cannot be maintained at all times, surgical masks and/or N95 respirators should be provided. If employees prefer other purchased or homemade masks that cover their mouth and nose that meet CDC recommendations, this would be acceptable.
- Review and revise employee work rules, social distancing, and PPE rules, sick leave, and other HR policies as needed.
- Advise employees to stay at home if the COVID-19 virus is spreading in their community, and/or if they are experiencing coronavirus symptoms, such as a mild cough or a temperature of 99.1 F or above. Employees should understand that simple medications such as acetaminophen (Tylenol) or aspirin could mask these symptoms. In general, if the employee is not feeling well then he/she should be cautious and work from home.
- Conduct employee awareness training about new precautions, work rules, and contingency plans.
- Consider maintaining work from home arrangements for some employees.
- Consider staggering work shifts, or have flexible hours to avoid a rush back to work and workplace congestion.
- Consider banning all in-person meetings and events, and utilize virtual meetings exclusively. If meetings or events need to take place in person, develop and follow a plan to minimize risk.
- Amend service agreements and contracts to require vendors to follow new rules.
- Observe recommendations for social distancing.
- Do not permit vendors or visitors to enter your site if showing any signs of illness or if they’ve been in contact with a COVID-19 positive person.
- Consider suspending all business travel, including domestic travel, until the risk of contagion is eliminated.
PHASE IV – MAKING SURE YOUR WORKPLACE IS CLEAN AND HYGIENIC
- Have 'touch-free' plumbing hardware installed in bathrooms and breakrooms
- Deactivate hot air dryers and supply single use paper towels for hand drying and waste baskets for paper disposal. Recent research has shown that blower type hand dryers can efficiently spread virus aerosols.
- If an employee, other tenant, or visitor becomes ill or tests positive for COVID-19, arrange for an immediate deep cleaning and disinfection of the affected and common areas by a qualified service provider following a protocol you have approved.
- Increase the frequency of cleaning and disinfecting high density, common, and high frequency surfaces.
- Provide and require the use of approved sanitizing wipes for all surfaces.
PHASE V – CONTINGENCY PLANNING
- Create a communication plan with building ownership, property management, and other occupants of the building to immediately learn if another’s employee is tested positive for COVID-19 (remembering the need to maintain confidentiality of the individual).
- Be prepared for supply chain disruptions, especially for materials required to operate safely.
- Monitor governmental sources for the re-emergence of infection, and be prepared to change work patterns quickly.
- Consult with local authorities, and create a contingency plan in the eventuality that an employee becomes ill or reports that they have been in contact with a COVID-19 individual while at the workplace. The policy should require that the employee should immediately be isolated pending the arrival of EMS or sent home if it is safe to do so.
- Assess new risks and meet with your insurance broker to assure that insurance coverages meet your current risk management needs.
RESOURCES FOR ADDITIONAL GUIDANCE
Make sure your risk management decisions are based on scientifically sound information obtained from trusted sources. The resources below have been utilized in the preparation of this document and can be consulted for a more in-depth discussion or details.
About Tokio Marine America
IMPORTANT NOTICE - The information and suggestions presented by Tokio Marine Management, Inc. does not represent, warrant, or guarantee the appropriateness, validity or accuracy of this information in every situation. This information does not necessarily cover every possible condition, protection, hazard, situation or exposure and is not warranted to be in compliance with laws, regulations, codes or standards in every jurisdiction. This information is representative of reasonable practices in the industry. However, you may wish to investigate whether these recommendations are applicable to your specific operations. Loss control is the responsibility of your management.