Communicate with your management team and employees – ask for input and ideas for creating a safe working environment.

• Review and understand the current Ontario framework. Identify where your business fits in:
  https://files.ontario.ca/mof-framework-for-reopening-our-province-en-2020-04-27.pdf
• Evaluate your workplace taking into consideration the official guidelines and plan to adapt your workplace as best as possible within them. The Ontario government has published workplace guidelines to assist re-opening:
  https://news.ontario.ca/opo/en/2020/04/health-and-safety-association-guidance-documents-for-workplaces-during-the-covid-19-outbreak.html
• The Ontario government will announce when specific businesses can open in accordance with its framework and guidelines.
• Follow the latest public health authority advice for best practices.
• Remain flexible and be creative.
• Communicate with your management team and employees – ask for input and ideas for creating a safe working environment.
• Consider which workplace modifications are short-term and which are here to stay for the foreseeable future.

As many employers are considering the various ramifications of re-starting or ramping up their businesses in the age of COVID-19, an obviously important consideration is the health and safety of their employees. Employers have an obligation to take all reasonable steps to keep workers and workplaces safe and free of hazards, including those related to COVID-19. These obligations are codified in the Occupational Health and Safety Act (OHSA) for Ontario employers (or similar legislation for those that fall under Federal jurisdiction or that of other provinces). Employers should be familiar with legislative requirements specific to their workplace and work with their health and safety committee or worker representative to ensure compliance.

Every workplace is unique, and it is important for every employer to conduct a thorough analysis of risks in their workplace related to COVID-19, and how those risks can be mitigated.

With time, information with respect to COVID-19 and its impact on the workplace will continue to be updated. It is important therefore to be consistently monitoring reliable websites – for example, those of the Federal and Provincial Governments, Public Health Authorities, and relevant industry publications – to ensure that you are armed with the most current information. It is also important to constantly monitor your current health and safety mitigation strategies to ensure they remain up to date with best practices, are effective, and are being consistently enforced.

We set out below several suggestions and considerations.

Every workplace is unique, and it is important for every employer to conduct a thorough analysis of risks in their workplace related to COVID-19, and how those risks can be mitigated.

Employers must ensure that employees are trained on safety practices, precautions and procedures relating to COVID-19.

• Best Practices – Ensure your staff are advised and that they understand the employer’s policies and practices relating to COVID-19 health and safety.
• Timing – Consider a general re-orientation for staff as they return to work.
• Checklists – Provide staff a simple and clear checklist to refer to on an ongoing basis.
• Responsibilities and Rights – Ensure that each employee understands his/her responsibilities and rights in the workplace.
• Records – Keep a record confirming that the employee has received COVID-19 orientation and training.
• Updates – Have a plan to communicate new policies or practices or changes to them.

Consider adjustments in staffing levels. Identify those positions that are critical and those that may become redundant. Make difficult decisions carefully, but don’t delay.

• Alternatives – Consider whether there are alternative business strategies allowing you to deliver your product or service in a more COVID-19 safe way (e.g. delivery services rather than in-shop, electronic meetings rather than face-to-face, eliminate business travel, innovative use of technology).
• Work from Home – Consider whether it is possible to implement or continue work-from-home practices.
• Workplace Shutdowns – Be prepared for periodic government mandated business closures and lockdowns. There is concern that local and regional outbreaks could force further closures and businesses need to be prepared to respond from a human resources perspective.
• Staffing Adjustments – Consider adjustments to staffing levels in light of changes in product demand etc. Identify those positions that are critical and those that may become redundant. Make difficult decisions carefully, but don’t delay.

• Hand hygiene – Communicate expectations with respect to frequent and proper hand washing and use of alcohol-based hand sanitizer. Ensure that there is access to hand washing sinks for both employees and customers.
• Sanitizers and wipes – Ensure that the workplace is supplied with enough sanitizers and wipes to allow employees and customers to clean hands and workstations frequently.
• Surfaces and Equipment – Ensure that surfaces and equipment – particularly those that are high use or shared (doorknobs, light switches etc.) – are cleaned regularly and frequently. Where possible, limit the sharing of phones, computers, desks, offices and work tools.
• Reminders – Post reminders throughout the workplace with respect to hygiene and cleaning.
• Housekeeping – Establish and maintain regular and frequent housekeeping procedures. Keep checklists and records to ensure compliance.

Consider the use of personal protective equipment (PPE) as part of your mitigation strategies. (e.g. Masks, Gloves, Goggles, Face Shields, etc.)

• PPE Supplies – Ensure they are sourced and supplied so that all employees have access to PPE that are effective in mitigating risk and appropriate for the employee’s tasks. If the PPE is reusable, ensure that it is properly cleaned and sanitized.
• Monitor – Ensure that employees are trained with respect to, and faithfully complying with, PPE policies.
• Cautions – Remind employees regularly, and within various workplace postings and policies, that PPE is not a failsafe solution, but only one of a variety of strategies that need to be employed in the workplace (e.g. it does not permit the relaxing of cleaning or physical distancing measures).
• Barriers – Where physical distancing is not practical or effective, consider physical barriers, such as plexiglass, or other engineered structures that would afford employees protection.

• Office Layout – Evaluate workplace layout and configurations to ensure greatest compliance with physical distancing. Where the workplace has narrow aisles or hallways, consider making them unidirectional if possible, with floor markings at two metres for reference.
• Remote Work – Encourage remote work and virtual meetings where possible.
• Stagger or Alternate Shifts – Consider staggering workdays so the number of employees within the office or workplace is minimized.
• Use of Common Rooms – Limit the use of common rooms, such as lunchrooms or reception areas, in order to maintain distance. Where needed, consider staggered use with a fixed number of employees or clients at one time, with cleaning between each use.