"If you need to be right before you move, you will never win. Perfection is the enemy of the good when it comes to emergency management. ...The greatest error is not to move." - Dr. Mike Ryan, WHO
Over the course of the past several weeks, we’ve been helping employers triage through the various workplace health and safety issues that are emerging from the COVID-19 crisis. And far too often, despite what is oftentimes the best of intentions, we’re seeing employers, whether paralyzed by fear, uncertainty, or yes, just plain recklessness, moving too slowly, or in some cases, not at all.
That needs to change. And it’s our hope that, providing this brief overview of steps that employers can (and indeed should) take, will help make that happen:
ESTABLISH A COVID-19 COMMITTEE: Regardless of whether you already have a health and safety committee or representative, or one or more health and safety professionals, they’re going to need support. It’s both unreasonable and disingenuous to simply expect them to address COVID-19 as though it were any other hazard. It’s not. We’re dealing with an unprecedented situation, where new information is constantly coming in, and the landscape and potential risks are constantly shifting. You need a team that is able to immerse themselves in that knowledge, to understand what’s happening, to share that information with you and your workers (as required under the OH&S legislation), and to consider and implement the preventive measures and steps that you, as an employer, need to take in order to respond to it.
IMPLEMENT THE ADVICE OF THE CHIEF MEDICAL OFFICER (CMO) AT THE WORK SITE: COVID-19 and its spread are very real hazards, and as an employer, you have an obligation to eliminate or control them to the lowest level possible. While not all employers will have access to a virologist or other specialized resources to assist in the development of such controls, the fact is that the CMO and Government of Alberta have been identifying controls since the pandemic started, and those controls need to be in place at your work site. Better access to washing or sanitization stations and routines, self-isolation (for recent out-of-country returnees, and those with COVID-19 related symptoms), working from home, and social distancing (in the sense of maintaining a distance of 2 or more metres from other workers), must all, at an absolute minimum, be part of your response.
BREAK DOWN YOUR WORK SITE & THE TASKS WORKERS ARE PERFORMING. AGAIN. BUT THIS TIME, WITH A VIEW TO THE CONTROLS IDENTIFIED BY THE CMO: Where are your wash stations? Do you need more? Are you continuing to maintain an “open door” policy? Are workers car-pooling or taking public transit to and from the work site? Do you really need a team of 10 workers in that particular area of the work site, or performing that particular task? Or can it be accomplished with less than that, thereby decreasing the potential spread / exposure, and making social distancing easier? What tasks and areas pose the biggest risk of an interpersonal exchange, and how can the work be structured differently so as to prevent or limit those interactions? Can the work be staggered, or even done remotely?
START A SPREADSHEET TO TRACK WORKER STATUS & MOVEMENTS: Don’t limit it to recent out-of-country returnees and workers with COVID-19 related symptoms, but include the movement and status of all your workers at the work site. Having access to that information will prove crucial to your response (and even continuity) in the event one of your asymptomatic workers suddenly experiences symptoms, or tests positive for the virus.
ESTABLISH A REMOTE WORK / TELECOMMUTING POLICY & PROCEDURES: Even when workers are working from home, employers still have obligations under the OH&S legislation. While we first identified this obligation when the new legislation was introduced in 2018, understanding its implications is even more important today. Regardless of the fact that it’s a home office, it’s still considered a “work site” for the purposes of the OH&S legislation, and employers need to treat it as such in order to comply with their statutory obligations. At a minimum, that means assessing, with the assistance of the workers involved, the hazards associated with the work in the context of the home office environment, on all of the physical, psychological, and sociological fronts, and then implementing policies and procedures to address them. While I appreciate that this step is one that a lot of employers may struggle to address in the initial stages of the COVID-19 pandemic, it’s important that it not be overlooked. Particularly if this is, as many would suggest, indicative of what will be the “new normal”.
And finally, a word of CAUTION: We’re now well into the pandemic, and yet we continue to receive calls about employers that are forcing support (and other) workers to come into the office (including, in some cases, ones that are considered to be high risk), even though there is nothing that would prevent them from working from home. This NEEDS to stop. Such employers are not only failing to adequately control the COVID-19 hazard and increasing the public risk, but they are actually putting themselves significantly at risk for work-refusals. Given the situation we are currently dealing with, there is no doubt in our minds that COVID-19 constitutes a “dangerous condition” at the work site, such that these work refusals would, if challenged, be justified. Similarly, there is no doubt in our minds that the way employers “remedy” that dangerous condition, is by having workers (that are able to), work from home. The end result, whether employers implement the change, or workers bring it about themselves, is that workers that can work from home or remotely, should be working from home or remotely. If it takes a work refusal for that to happen, the employer not only loses control over that entire situation (since the regulator will, at that point, become involved), but opens the door to exposure of an entirely different variety.
Are there additional steps that you’re taking at your work site(s), that other employers may find helpful? Share them in the comments section below. And remember, we’re all in this together!
Questions about what COVID-19 means for your work site(s)? Join our weekly Friday Morning Muster, or give us a call at 1-780-720-1586 (Edmonton & Northern Alberta) or 1-403-456-5835 (Calgary & Southern Alberta), and let our experience benefit you.