Reopening Your Business After COVID-19 Closures

Businesses that close down for any period due to a pandemic, such as COVID-19, must take careful considerations when choosing to resume operations. The first concerns employers must address are local, state, and federal orders for business closures, quarantines, and social distancing. These rules must be adhered to, and you should only reopen your business if allowed by law. Additionally, although they may not be legally mandated, employers should consider recommendations made by reputable public health entities, such as the Centers for Disease Control and Prevention (CDC) and local health departments, regarding the safety and wellbeing of employees and customers.

Reopening a business, whether or not the facility is open to the public, should be treated as a process requiring planning and preparation. Many times, employers must adapt their normal operations to protect workers and customers from transmitting the virus. The following checklist may guide businesses looking to reopen after a pandemic.

Adapting to new operational requirements

• Identify essential and non-essential employees to take a phased approach in reopening the business.
• Decide if coming into the workplace will be mandatory or on a voluntary basis if employees can conduct business remotely.
• Actively encourage sick employees to stay home. Develop policies that encourage sick employees to stay at home without fear of reprisals, and ensure employees are aware of these policies.
• Have conversations with employees about their concerns. Some employees may be at higher risk for severe illness, such as older adults and those with chronic medical conditions.
• Develop other flexible policies for scheduling and telework (if feasible) and create leave policies to allow employees to stay home to care for sick family members or care for children if schools and childcare close.
• Talk with companies that provide your business with contract or temporary employees about their plans. Discuss the importance of sick employees staying home and encourage them to develop non-punitive “emergency sick leave” policies.
• Consider the need for travel and explore alternatives. Check CDC’s Travelers’ Health for the latest guidance and recommendations. Consider using teleconferencing and video conferencing for meetings, when possible.
• Establish alternating workdays or extra shifts that reduce the total number of employees in a facility at a given time.
• Create additional space for customers; for retailers, this might mean adding drive-thru or curbside services.
• Replace face-to-face conversations internally, as well as those with customers, clients, and vendors, with phone calls or other forms of communication as much as possible.
• This may include scheduling services when customer facilities are closed to the public, wearing personal protective equipment, and maintaining distance from other people as much as possible when completing the service.
• Establish customer/visitor policies regarding the use of personal protective equipment, social distancing when visiting the business, limiting the number of customers allowed in the building at a time, etc.

Conducting business at customer locations

• Employees that conduct service or repairs at customer locations (e.g., HVAC, electrical, plumbing, janitorial, and pest control businesses) are subject to unique hazards that need to be addressed to ensure the health and safety of both workers and customers.
• Encourage workers to practice social distancing as much as possible when visiting customers. Remain six feet away from any individuals occupying the space, and reduce direct contact by speaking with the customer over the phone prior to the service.
• Consider scheduling services with commercial business customers when their facilities are closed to the public (e.g., early in the morning or late in the evening) to reduce contact with other people.
• When conducting business with residential customers, schedule services for when the resident(s) will not be home. Customers who remain in their homes during the service should be asked to go into a different room to reduce contact.
• Develop and implement policies to disinfect company vehicles before, during, and after work shifts. Also, equip vehicles with disinfectant, cleaning wipes, and personal protective equipment, such as gloves and face masks, so they may be easily accessed by employees.
• The minimum number of employees for the service should occupy one vehicle at a time to prevent close contact.
• Encourage workers to wear personal protective equipment, including gloves and face masks, when possible.
• Disinfect tools and other equipment after each service call, and do not allow workers to share tools with other employees.

Reopening building facilities

• Buildings that were shut down abruptly due to the pandemic or not maintained during the closure period could pose a health hazard to their occupants and staff.
• Measure the adequacy of indoor environmental conditions, specifically controlling relative humidity. Building heating, ventilation, and air-conditioning systems are designed to operate under a heat load produced by people, computers, lights, and other activities. Closures and additional reductions in occupancy reduce a building’s heat load, which can affect an HVAC system’s ability to control relative humidity levels where mold and moisture damage can occur. If deficiencies are found, consult a qualified contractor to make necessary repairs and adjustments.
• Ensure that building water systems are operating properly. Water that sits stagnant for an extended period in water mains, plumbing lines, and water heaters loses residual chlorine disinfectant, which increases the risk of waterborne pathogens. Assess current conditions and implement preventative and remedial measures if needed.
• Consider installing high-efficiency air filters and increasing ventilation.

Redesigning workspaces and customer areas

• Consider redesigned workspaces that promote social distancing and reduced contact between workers, as well as customers.
• Install glass or plexiglass barriers where people have to meet and talk, including at secretarial workstations and customer service desks.
• Some retail establishments have taken actions to identify six-foot distances with floor tape in checkout lines and direct foot traffic through one-way aisles.
• Workplaces where social distancing is a challenge should consider innovative approaches, such as opening every other cash register and temporarily moving workstations to create more distance.

Cleaning and disinfecting the workplace

• Increase the cleaning of commonly touched surfaces, such as workstations, countertops, handrails, and doorknobs.
• Follow CDC recommendations for disinfecting the workplace.
• Ensure that cleaning sprays, surface wipes, and other products are being used effectively.
  • Use products that are registered by the U.S. EPA. Not all cleaners kill the virus, so check to see that adequate products are being selected.
  • To kill the virus, the surface must stay wet for the entire time on the label. Look for “contact time” or “dwell time.”
  • Surface wipes can dry out during use. They must remain wet to be effective.
  • Disinfectants may not work on all surfaces. Follow the label carefully.
• Individuals performing cleaning must take precautions to ensure their health and safety.
  • Follow the product label’s precautionary statements to avoid chemical exposure. If no label guidance is provided, consider wearing gloves, eye protection, shoes with socks, and long sleeves/pants.
  • Keep children, pets, and other people away during the application until the product is dry and there is no odor.
  • Open windows and use fans to ventilate.
  • Wash your hands after using any disinfectant, including surface wipes.
  • Keep lids tightly closed when not in use to prevent spills.
  • Throw away disposable items like gloves and masks after use.
  • Do not use disinfectant wipes to clean hands or as baby wipes.

Monitoring and screening for symptoms

• Consider taking employees’ temperatures and screening for symptoms before they enter the workplace. One way this can be accomplished is by having them fill out and sign a COVID-19 symptoms form. Encourage employees who are feeling ill to stay home and seek medical advice.
• If an employee becomes sick during the day, separate them from other employees, customers, and visitors and send them home immediately. Follow CDC guidelines for cleaning and disinfecting areas the sick employee visited.
• Develop procedures for reporting and dealing with viral symptoms noticed by employees at work.

Personal protective equipment and other materials

• When feasible, require workers to wear face masks over their nose and mouth to prevent them from spreading the virus.
• Test the use of face masks to ensure they don’t interfere with workflow.
• Provide workers and customers with tissues, no-touch trash cans, soap and water, and hand sanitizer with at least 60% alcohol.
• Provide workers with disinfectants and disposable towels to clean their work surfaces throughout the day.

Social distancing guidelines

• Practice social distancing in the workplace as work duties permit and maintain six feet between workers and customers.
• Do not allow employees to use other workers’ phones, desks, offices, or other work tools and equipment.
• Discourage employees from congregating in break rooms, lunchrooms, or other crowded places.
• Promote etiquette for coughing and sneezing and handwashing.
• Stagger entrances, departures, break times, lunch activities, etc., to optimize social distancing.
• Limit the number of people allowed at any one time in meetings, work areas, elevators, bathrooms, hallways, parking lots, etc.

Employee training

• Provide education and training materials that are easy to understand in the appropriate language and literacy level for all employees, like fact sheets and posters.
• Train workers in proper hygiene practices and the use of workplace controls.
• Train employees on the steps they can take to prevent the spread of the virus (e.g., washing hands, social distancing, coughing and sneezing etiquette, and avoiding touching your face).

Administrative duties

• Stay up to date on guidance from federal, state, and local health officials.
• Develop and implement a communication plan to:
  • Communicate accurate and up-to-date information to employees about the transmission and symptoms of the illness, or direct them to appropriate resources from federal, state, and local health officials.
  • Communicate actions being taken at the workplace to prevent the spread of the illness.
  • Address employee questions and concerns on issues such as pay and leave.
• Keep medical information related to employees who have the coronavirus confidential. Both the Americans with Disabilities Act (ADA) and the Family and Medical Leave Act (FMLA) require you to keep medical information about employees confidential, including information about the coronavirus.
• Employers that are covered by the Families First Coronavirus Response Act (FFCRA) must post a notice of FFCRA requirements in a conspicuous place on their premises.
  • Covered entities include certain public employers and private employers with fewer than 500 employees that are required to provide their employees with paid sick leave or expanded family and medical leave for specified reasons related to COVID-19.
  • These provisions will apply from April 1, 2020, through December 31, 2020.
  • Visit https://www.dol.gov/general/topics/posters for specific requirements and to obtain a copy of the poster/notice.

The items in this checklist can help employers preparing to resume business operations during these challenging times. However, another essential component of reopening your business in light of COVID-19 is to remain informed on the ever-changing situation and adapt as needed. Evaluate your workplace policies and procedures regularly and implement changes and improvements. Please consult with legal counsel to ensure that your business is compliant with applicable local, state, and federal laws.