HBLLP Logo Client login link HBLLP Home page link Make a payment link
* *
 
 
 
 
 
PLAN FOR EMPLOYEE SAFETY AS EMPLOYEES RETURN TO WORK
BY HUTCHINSON AND BLOODGOOD | May 26, 2020 | TAX TIPS
 
 
 
 


Chances are, employers don't need the force of law to make them care about the health of their employees, especially during the novel coronavirus (COVID-19) pandemic. But it's still important to know what the federal workplace safety agency — the Occupational Safety and Health Administration (OSHA) — has to say about employees returning to their jobs with a measure of confidence in their own safety.

OSHA's recent "Guidance on Preparing Workplaces for COVID-19" report offers a helpful blueprint. However, the agency stresses it's "only advisory in nature" and doesn't set any new standards. Also, it falls under the underlying law's overall requirement that employers "provide their employees with a workplace free from recognized hazards likely to cause death or serious physical harm."

Below are some points from the OSHA blueprint to help you consider workplace safety through a new lens.

Assess Your Risk Profile
Step one in working toward a hazard-free workplace is to make an "infectious disease preparedness and response plan," OSHA states. (You might need to recycle your plan at some future time when another aggressive virus makes the rounds.)

Consider the sources of COVID-19 that workers might be exposed to. Those include both sources at work — namely coworkers and other people who regularly come to your workplace — and workers' potential exposure outside work.

For example, employees who commute to work via public transportation might face a higher risk of being exposed than those who drive their own cars. Similarly, employees with spouses or family members who work on the front lines, such as in a hospital clinical setting, could pose a greater risk than others.

While you can't discriminate against employees who might be at greater risk than others, having a complete risk exposure picture can guide your overall preparedness strategy. You might have considered that the chances of a viral outbreak at your workplace were minimal before thinking about potential indirect sources of exposure, and thus decide to take greater precautions than you otherwise would. 

Workplace Control Categories
"Workplace controls" for infection prevention, as OSHA calls them, fall into four buckets:

  • Engineering controls. Physical measures include using high-efficiency filters, increasing ventilation, and installing physical barriers such as clear plastic sneeze guards.

  • Administrative controls. This involves HR policies, safety equipment and procedure training.

  • Safe work practices. Examples include "no-touch" trash cans, alcohol-based hand rubs and required handwashing.

  • Personal protective equipment (PPE). This includes gloves, goggles, face shields, etc. Note: While there's no COVID-19-specific OSHA PPE standard, some regulations may apply here. One is general industry PPE standards laid out in 29 CFR 1910 subpart I, governing when the use of gloves, eye, face and respiratory protection is required.

As the above categories indicate, infection prevention measures highlighted by OSHA aren't limited to frequent handwashing and disinfecting of workplaces. They cover work policies you might not already have in place, for example, when employees should work from home or call in sick.

And while this isn't suggested by OSHA, you might review your paid sick leave policy to ensure that it doesn't discourage sick employees (potentially with COVID-19) to report for duty to avoid forfeiting pay.

Other possible policy responses to consider include staggered work shifts to lower the density of employees at work at any given time, and other ways to allow workers to spread out more ("social distance").

Employees' Obligations
Employees should be informed of the right person or department to contact if any symptoms consistent with COVID-19 arise, and what will happen next. Ideally, you'll have multiple options ranging from sending the employee home immediately to moving the employee's workstation to a more remote site. "Although most worksites do not have specific isolation rooms, designated areas with doors may serve as isolation rooms until potentially sick people can be removed from the worksite," OSHA suggests.

Not every respiratory infection is COVID-19 related, of course. But OSHA discourages employers from requiring every sick employee to obtain documentation from a healthcare professional before deciding how to handle the situation. Erring on the side of caution is the practical solution because swamped medical offices might not be able to generate such documentation.

"Risk Pyramid"
OSHA's guidance also features a "risk pyramid" that classifies hazard levels for different kinds of jobs and workplaces. It's encouraging to note that OSHA believes most workers "will likely fall into the lower or medium exposure risk levels."

Jobs with "medium" exposure risk include those "that require frequent and/or close contact with people who may be infected but are not known or suspected" to be infected. The least risky ("lower exposure risk") jobs "are those that do not require contact with people known to be, or suspected of being" infected, nor frequent contact with the general public."

In contrast, jobs with "very high" exposure risk include healthcare workers and those who perform autopsies working with known or suspected COVID-19 patients. The next level down in the risk spectrum are jobs with just "high" exposure risk. This includes healthcare delivery personnel (for example, ambulance drivers) and medical support staff working around known or suspected COVID-19 patients.

Your infection minimization strategy and policies can be suited to the risk classification of the jobs your employees have. For example, for jobs in the "lower exposure risk" class, special engineering controls are "not recommended," beyond any that may already be in place for risks not specifically associated with COVID-19. In contrast, some engineering controls are recommended for medium exposure risk jobs. Those include "physical barriers, such as clear plastic sneeze guards, where feasible."

Final Thoughts
As noted, OSHA's suggestions are merely that — suggestions and not strict requirements. It's helpful to read the OSHA guidance to ensure you're aware of how contagions spread. But for your company, you and your trusted managers and advisors are in the best position to evaluate the risks that exist in your workplace, and how to minimize them.
© 2020

 
 
 
 
 

HOW CAN WE HELP?

With the uncertainty of the situation surrounding coronavirus (COVID-19) continuing to evolve, we understand that it is affecting businesses and individuals in many different ways. 

At Hutchinson and Bloodgood, we value the relationships we have built with you. We will continue to be accessible so that we can serve and assist you while providing the level of attention that you deserve.

We will work alongside you throughout this ongoing situation to develop and build the optimal solutions for you.

Please contact us with your questions and concerns.

 
Disclaimer: This material has been prepared for informational purposes only. It is not intended as a substitute for speaking to your accountant, tax planner or financial planner. All information is provided “as is.” With change happening on a daily basis, we do not guarantee completeness, accuracy, timeliness or results obtained from the use of this information.
 
 
 
 
 
 
Megaphone  

GET NEWS DELIVERED TO YOUR INBOX

Stay current on tax and accounting issues, business
strategies, technology and general business information.

Sign up for our newsletter and
receive regular emails from us!

  Register Newsletter Form Registration
 
 
 
 
  grey spacer    
 
         
Social media icons Email Us HBLLP's LinkedIn page Link to Instagram HBLLP's Facebook page Contact Us Office Locations
  " "      
       
       
       
Glendale, CA
550 North Brand Blvd.
14th Floor
Glendale, CA 91203
Phone (818) 637-5000

blue spacer
El Centro, CA
3205 South Dogwood Ave.
El Centro, CA 92243
Phone (760) 352-1021

blue spacer
San Diego, CA
7676 Hazard Center Dr.,
Suite 1150
San Diego, CA 92108
Phone (619) 849-6500

blue spacer
Watsonville, CA
579 Auto Center Drive
Watsonville, CA 95076
Phone (831) 724-2441

blue spacer
The Consulting Group
550 North Brand Blvd.
14th Floor
Glendale, CA 91203
Phone (818) 637-5000

       
       

Hutchinson and Bloodgood LLP is an affiliate of PKF International and Allinial Global, associations of legally independent accounting and consulting firms who share education, marketing resources, and technical knowledge in a wide range of industries. We are independent accounting firms coming together to support the success of independent client companies.


@ 2019 Hutchinson and Bloodgood LLP