COVID-19: Return To Work Playbook

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1. The Ontario Framework: Re-opening Amid Uncertainty

The progress we make regarding reducing the spread of COVID-19 in Ontario will determine how and when a return to the workplace is permitted. The Ontario government created a province-wide framework and workplace specific guidelines to assist employers in planning a return to the workplace. As the framework and guidelines are subject to change, it is important to regularly monitor official information provided by the government. Specifically, the following are suggestions for employers:

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

2. Health and Safety Considerations

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.

(i) Communication

It is critical to be intentional and clear with all communications with staff during the COVID-19 pandemic to not only address concerns but to ensure that staff understand their obligations and entitlements, and the employer’s expectations as the workplace re-opens.

  • Plan – create a communication plan, and update it continually, giving thought to what needs to be communicated to different levels within the organization.
  • Method – ensure that your employees know how information will be provided (e.g. company email, website, portal, postings or even text message).
  • Accuracy – ensure the information provided is accurate. Rely on appropriate authorities – government, health authorities, industry regulators etc.
  • Message – Be clear and concise about plans for re-opening the business, steps the business is taking to protect workers, training requirements, timing etc. Ensure that the employees understand that their health is a top priority.
  • Feedback – Create a way for employees to ask questions, seek clarity and raise concerns or share suggestions that they may have.
  • Point Person – Advise staff of the individual (e.g. health and safety representative) who is responsible for implementation of health and safety program.
    Repeat – Reinforce key message points by repeating them within your frequent updates.

(ii) Education and Training

As part of their obligation to protect workers, employers must ensure that employees are trained on safety practices, precautions and procedures relating to COVID-19.

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.

(iii) Business Assessment

As part of your health and safety analysis, consider different ways to conduct your business and create new working norms in the new COVID-19 context. Such an analysis should consider not only the down-side risks, but also the up-side benefits.

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.

(iv) Hygiene and Cleaning

It cannot be overstated: basic hygiene and cleaning practices are fundamental to mitigating COVID-19 risks in the workplace.

  • 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.

(v) Personal Protective Equipment and Barriers

As part of your mitigation strategies, consider the use of personal protective equipment (PPE) – e.g. masks, gloves, goggles, face shields etc.

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.

(vi) Physical Distancing

It is important to minimize close contact within the workplace. Public Health recommendations for physical distancing should be continued within the workplace – two metre distance between employees.

  • 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.

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