June 18, 2020

Even as stay-at-home orders and restrictions are lifted, daily operations won’t be business-as-usual for many across the country. The coronavirus (COVID-19) pandemic is still going on, despite businesses reopening. Moreover, public health officials and experts are warning of a potential second wave of COVID-19 cases. Of course, no one knows if or when a second wave of infection will strike—or whether it will be as bad as or worse than the first wave. As such, businesses across the country should start planning today so they’re properly prepared for a second wave of COVID-19 cases. Review Federal, State and Local Guidance Similar to the first wave of COVID-19 cases, governmental guidance will play a large role in how your organization should respond to a second wave of COVID-19 cases. The COVID-19 pandemic has impacted states and regions in different ways. A second wave of cases may follow the same suit, affecting different regions at different times and in varying capacities. This means that businesses in one region may be able to remain open, while businesses in other regions may need to close or adjust for a second time. As such, it’s critical to understand and continually review all relevant state and local orders to determine if your business needs to take action in the face of a second wave of COVID-19 cases. Review Your Organizational Risks Even if there aren’t federal, state or local recommendations to close your business or make changes to prevent the second spread of COVID-19 cases, that doesn’t mean your organization is safe from the coronavirus. What’s more, some businesses may have greater exposures than others, underscoring the importance of performing a thorough risk assessment to determine how you should respond.   Similar to conducting a risk assessment for planning to reopen following the first wave of COVID-19 cases, your organization should conduct a risk assessment in preparation for a reemergence of COVID-19 cases. While the complexity of risk assessments will differ from business to business, they typically involve the following steps: Identifying the hazards—When it comes to planning for a second wave of the coronavirus, businesses need to think critically about their exposures, particularly if an infected person entered their facilities. When identifying hazards, it’s a good idea to perform a walkthrough of the premises and consider high-risk areas. It’s also important to consider what tasks employees are performing and whether or not they are especially exposed to COVID-19 risks when performing their duties. Deciding who may be harmed by a second wave of cases and how—Once you’ve identified hazards to your business, you need to determine what populations of your workforce are exposed to COVID-19 risks. When performing this evaluation, you will need to make note of high-risk individuals (e.g., staff members who meet with customers or individuals with preexisting medical conditions). Assessing risks—Once you have identified the risks facing your business, you must analyze them to determine their potential consequences. For each risk facing your business, you’ll want to determine: How likely is this particular risk to occur? What are the ramifications should this risk occur? When analyzing your risks, consider potential financial losses, compliance requirements, employee safety, business disruptions, reputational harm and other consequences. Controlling risks—With a sense of what the threats to your business are, you can then consider ways to address them. There are a variety of methods businesses can use to manage their risks, including: Risk avoidance—Risk avoidance is when a business eliminates certain hazards, activities and exposures from their operations altogether. Risk control—Risk control involves preventive action. Risk transfer—Risk transfer is when a business transfers their exposures to a third party. For preparing for a second wave of the coronavirus, control measures could include cleaning protocols, work-from-home orders and mandated personal protective equipment (PPE) usage. Monitoring the results—Risk management is an evolving, continuous process. Once you’ve implemented a risk management solution, you’ll want to monitor its effectiveness and reassess. Remember, the COVID-19 pandemic so far has been rapidly evolving, and guidance can change quickly. Your business should be prepared to take action at short notice. Maintain Workplace Safety Maintaining workplace safety is crucial to preventing the spread of COVID-19 at your organization, and will continue to be crucial in protecting your organization against a second wave of COVID-19 cases. There are a number of OSHA and Centers for Disease Control and Prevention (CDC) workplace controls to consider if your risk assessment determines that COVID-19 poses a threat to your employees or customers. For instance, you should: Implement administrative controls—Typically, administrative controls are changes in work policies or procedures that reduce or minimize an individual’s exposure to a hazard. An example of an administrative control for the coronavirus is establishing alternating days or extra shifts that reduce the total number of employees in a facility at a given time. Utilize PPE—Businesses should focus on training workers on proper PPE best practices. Employees should understand how to properly put on, take off and care for PPE. Training material should be easy to understand and must be available in the appropriate language for all workers. Consider engineering controls—Engineering controls protect workers by removing hazardous conditions or by placing a barrier between the worker and the hazard. For COVID-19, engineering controls can include: Installing high-efficiency air filters Increasing ventilation rates in the work environment Installing physical barriers, such as clear plastic sneeze guards Screen employees before they enter the building— To keep employees safe, consider conducting screening procedures to identify potentially ill employees before they enter the workplace. The Equal Employment Opportunity Commission permits employers to measure employees’ body temperatures before allowing them to enter the worksite. Any employee screening should be implemented on a nondiscriminatory basis, and all information gleaned should be treated as confidential medical information under the Americans with Disabilities Act—specifically, the identity of workers exhibiting a fever or other COVID-19 symptoms should only be shared with members of company management with a true need to know. Be sure to notify employees of this practice prior to implementation in