Your governor says your business can open May 1, so COVID 19 is no longer contagious, right? Wrong. Not only is it still contagious, but the virus is living among your customers, staff, delivery drivers and suppliers. Since we’re not testing adequately, we don’t know who or how many people pose risks. Arguably, some geographic areas are riskier than others, but the risk is real everywhere. While you MAY open your business, you may also be putting people’s lives at risk if you don’t make some very important changes. Putting a bottle of hand sanitizer at the counter isn’t going to cut it.
Yesterday a client told me she is hoping her governor will specify what she needs to do to open her business safely. Some states are doing spectacular work on this front, and others are doing absolutely nothing. Washington’s Department of Labor and Industries has some great resources, including COVID 19 General Requirements and Prevention Ideas for Workplaces. Washington and Oregon’s labor departments are actually doing spot checks of businesses to check on COVID-19 infection prevention policies and procedures. It seems reasonable to turn to states for guidance since there are no federal guidelines to follow. Or are there? It’s still a workplace, and the Occupational Safety and Health Act exists to keep workers safe. While there is no specific OSHA standard covering COVID-19, the US Department of Labor has issued some helpful guidelines.
Enter OSHA Pub 3990 – Guidance for Preparing Workplaces for COVID-19. Every employer needs to read it. It contains tips for implementing basic infection prevention measures, communicating with employees, improving controls over workplace hazards, safe practices, use of PPE, and my personal favorite, the Occupational Risk Pyramid for COVID-19.
OSHA has divided job tasks into these four risk exposure levels. Health care workers are in the high and very high categories. Most workers are in lower (caution) or medium exposure risk levels (hence their positioning to the wider part of the pyramid). Job functions are medium risk if they require frequent and/or close contact (within 6 feet) of people who may be but are not known or suspected COVID-19 patients (e.g., everyone who isn’t sick). In addition to providing guidelines for determining your risk level, OSHA Publication 3990 includes recommended steps all employers can take to reduce workers’ risk of exposure and additional steps for jobs with medium or higher-risk.
The Centers for Disease Control (CDC) has also issued Reopening Guidance for Cleaning and Disinfecting Public Spaces, Workplaces, Business, Schools and Homes.
They are not rules, they are guidelines. This means you’ll need to use judgement when deciding how to make your workplace safe for your employees and customers. How do you make judgement calls? Based on knowledge, values and empathy.
Find publications and resources. OSHA Pub. 3990 is a good starting point. The Centers for Disease Control website also contains guidance for preparing workplaces to reduce transmission and maintain healthy business operations. Trade associations and state commerce and health department websites can also be useful. Talk to your peers, particularly those who are in regions more impacted than you. They are probably ahead of you in their planning. Consult your professional advisors (especially human resources and workplace safety professionals). Then apply values and personal empathy to decide on your own policies and protocols. Company values come in handy at times like this.
How Do Company Values Help?
Defined company values guide leaders grappling with tough decisions. Common values include integrity, boldness, honesty, accountability, trustworthiness, customer experience, innovation. If you value collaboration and transparency or the wellbeing of your employees and community, you’ll start by having a conversation with your team. What fears do they have about returning to work? What could you all do differently to make your team and your customers safer?
Have them walk through (or visualize) your physical space and see it as they never have before. Are there things that people touch that don’t really need to be there? Could non-essential items be moved or removed? What surfaces get touched over the course of a day? Who will clean them? How often? Everybody thinks about doorknobs and bathrooms, but what about telephones, credit card readers, cash registers, showcases, cabinets, keys, inventory, money? Should you stop accepting cash?
Which business processes or interactions require workers to be within six feet of a co-worker or customer? What could you do differently to assure customers and staff maintain a six-foot space bubble? Ask your team to apply common sense and company values as they answer all of these questions.
How Does Empathy Fit In?
Empathy is the ability to understand and share the feelings of another. Of course you have business reasons to open now. You’ve lost money this year, and every week that goes by without revenue puts you deeper in the hole. Your decisions are driven by your fears and as a business owner burning cash is terrifying. Your employees and customers are the same. What do they fear about interacting with your business? How can you change to ease their minds by making them safer? Get innovative with VIP-level personal services that set you apart from your competition. Find a new way forward that serves your customers and your employees as well as it serves the economic needs of your business.
Now What? New Procedures and a Pre-Opening Checklist
Based on your research, empathy and values, create a list of new procedures and protocols. Then assess what investments you’ll need to make (procure supplies and PPE, hire contractors, design and order sneeze guards to name a few). Next, create your pre-opening checklist, which includes finalizing procedure documents, getting the right supplies and services in place, communicating with customers and staff, and training all team members on the new processes, procedures, values and judgements that will keep everyone safe. Ongoing conversations are essential. This is not a “one and done” talk.
Many business owners will choose not to open, even though they are allowed to. Many customers will choose not to shop because staying home feels safer. Everybody will use their own judgement, which will change as our environment changes and we learn more. Make your judgement calls based on knowledge, values and empathy – and be safe.