CDC Publishes New Guidance for Office Buildings

Troutman Pepper

Pepper Hamilton LLP

The Centers for Disease Control and Prevention (CDC) has published new guidance for employers, building owners and managers, and building operations specialists who are preparing office buildings to resume operations. The guidance builds from CDC’s Interim Guidance for Businesses and Employers, which only touched on building safety. The new guidance takes a comprehensive approach to the practical questions businesses face as they reopen. The guidance recommends an initial evaluation and hazard assessment and specific engineering and administrative controls to reduce transmission among employees and office visitors.

The CDC first recommends that employers, owners, managers and specialists evaluate the building to determine whether its ventilation systems are operating properly. This involves properly restarting heating, ventilation and air condition (HVAC systems) and checking for hazards related to prolonged shutdown, such as mold growth, rodents or pests, and stagnant water systems. The CDC also recommends an increased circulation of outdoor air by opening windows, using fans and other methods.

Employers should also conduct a hazard assessment of the workplace, which involves identifying hazards, identifying interim control measures, and prioritizing the hazards for control. Employers should identify areas where employees are within six feet of each other, such as in meeting rooms, break rooms, cafeterias, locker rooms, check-in areas, waiting areas and routes of entry and exit.

The CDC next recommends that employers, owners, managers and specialists undertake a number of engineering controls to isolate employees and visitors from the hazard, including:

  • Modifying or adjusting seats, furniture and workstations to ensure that there is a six feet of distance between employees. Where that is not possible, transparent shields or other physical barriers that separate employees and visitors should be installed. Communal seating areas in reception and other areas should be adjusted to maintain social distance.

  • Physically separating employees in all areas of the facility, including work areas and other areas like meeting rooms, break rooms, parking lots, entrance and exit areas and locker rooms. This can be done using signs, tape or other visual cues.

  • Replacing high-touch communal items, such as coffee pots, with prepackaged, single-serve items.

  • Improving ventilation in the building by increasing the percentage of outdoor airflow, disabling demand-control ventilation, using natural ventilation even when the building is unoccupied, improving central air filtration, and repositioning staff to work in cleaner ventilation zones.

  • Consider using portable high-efficiency particular air fan/filtration systems to enhance air cleaning in higher risk areas.

The CDC also recommends that employers implement a number of administrative controls to change the way that people work in the building. These steps include:

  • Actively encouraging employees with symptoms of COVID-19 or who have a sick family member with COVID-19 to stay home.

  • Consider conducting daily in-person or virtual health checks (symptoms or temperature screening).

  • Staggering shifts, start times and break times as much as is feasible.

  • Consider posting signs in parking areas to ask visitors and guests to call from their cars to inform administration or security that they have reached the facility.

  • Consider posting signs asking guests and visitors to wear face coverings, not to enter the building if they are sick, and to stay six feet away from others if possible.

  • Cleaning and disinfecting high-touch surfaces.

  • Providing employees with adequate time to wash their hands and access to soap, clean water, and single-use paper towels.

  • Establishing social distancing policies and practices.

  • Offering support for employees who commute to work using public transportation, including offering incentives to use forms of transportation that minimize close contact with others, allowing employees to shift hours to commute during less busy times, and asking employees to wash their hands as soon as possible after their trip.

  • Posting signs and reminders regarding hand hygiene, COVID-19 symptoms and cough and sneeze etiquette.

  • Using no-touch waste receptacles where possible.

  • Requiring employees to wear face coverings in all areas of the business unless they have trouble breathing or other inability to wear/remove it.

Finally, employers should educate employees and supervisors about steps they can take to protect themselves at work and about any modifications in work processes and requirements. This communication should be simple and straightforward and should reach all staff, including contractors. The CDC has free, simple posters in multiple languages available here.

As businesses prepare to open, they should take a cautious and thoughtful approach to incorporating these guidelines. While the guidance is not mandatory, compliance with its standards could be useful in defending against future claims of unsafe workplaces. To the extent possible, these guidelines should be incorporated into reopening safety plans, which should be developed in tandem with building owners, managers and building operations specialists.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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