Cleaning The Workplace In Anticipation Of Reopening—And Keeping It Clean!

MoFo Employment Law Commentary (ELC)
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MoFo Employment Law Commentary (ELC)

We have waited for weeks that seemed like years for the government to allow us to reopen our businesses and schools; and, now that the big day is just around the corner, we must have plans in place to protect our employees and customers or clients (and ourselves as well). The Centers for Disease Control (CDC) has anticipated this day and, on April 28, published its reopening guidance for cleaning and disinfecting public spaces, workplaces, businesses, schools, and homes. There are three elements for employers (and everyone else), all designed to reduce the risk of exposure to COVID-19:

Develop a plan

Implement that plan

Maintain and revise that plan as needed

Here are the highlights of the CDC’s recommendations for each of these categories:

DEVELOP YOUR PLAN

Depending on the size of your organization, you may want to appoint a small committee and divide physical areas or groups of employees into to sub-groups with different needs. For your business as a whole and for each group, the plan should include:

  1. Determine what needs to be cleaned. If the area is outdoors, disinfection is not generally required, although some frequently touched outdoor items will need to be disinfected. If the premises have not been occupied for seven days or more, normal cleaning will suffice. If the entire building has been closed for a substantial period of time, the water system should be checked.
  2. Determine what needs to be disinfected. Frequently touched hard surfaces should be routinely disinfected (e.g., tables, doorknobs, light switches, handles, desk, keyboard, toilets, faucets, and sinks).
  3. Soft and porous items are more difficult to disinfect, and those items should be stored if possible. If they are necessary for your business, they should be cleaned or laundered following the manufacturer’s directions.
  4. For items that must be cleaned and disinfected, clean first (with soap and water), then disinfect with an EPA-approved disinfectant (basically, one-third cup bleach to one gallon of water).
  5. Identify the employees who will be responsible for moving items that are to be stored and those responsible for washing and disinfecting. Don’t hoard but do make sure you have sufficient soap and disinfectants on hand: and, to the extent potent disinfectants will be used, be sure you have the appropriate masks on hand. (Depending on local guidelines for reopening, all employees may be wearing masks anyways and, when necessary, gloves. See our recent ELC blog post for more information about masks in the workplace.). For details about the safety of your custodial staff, see https://www.cdc.gov/coronavirus/2019-ncov/community/organizations/cleaning-disinfection.html.  
  6. To safely reopen your business, you must be sure your employees maintain safe behavioral practices (e.g., social distancing, frequent hand washing, wearing masks and gloves, staying home when sick).
  7. Adopt practices that reduce the possibility of exposure. Encourage employees to disinfect hard surfaces before and after they use them (copy machines, printers, keyboard). Reduce the use of porous products.

IMPLEMENT YOUR PLAN

The person (or group of people) supervising your plan should read all manufacturers’ instructions for the cleaning and disinfection products you will be using (and, if you have them, the cleaning instructions that came with your furniture and equipment). The next step is obvious: put on your masks and gloves, and start cleaning.

MAINTAIN AND REVISE YOUR PLAN

If it becomes apparent that a cleaning procedure used for certain items is not working, change the procedure. Remember, the goal is to reduce the risk of exposure to the virus. If the CDC or other governmental entity publishes revised procedures, update your plan as necessary.

This CDC guidance on cleaning and disinfecting is only the beginning of the guidance on reopening. On April 30, 2020, CNN reported that the CDC “drafted a 17-page document that details interim guidance on how businesses, schools, churches, mass transit, and other organizations should handle safely reopening to the public amid the coronavirus pandemic.”[i] The document, which lays out a three phase plan for reopening, reportedly remains under review by the Trump Administration.[ii] Although the rules for reopening will vary by state and even county, many of the country’s governors and state and local public health officials will no doubt look to the CDC guidance when crafting reopening rules for employers. We are monitoring developments and will report further when the draft guidance is finalized.


[i]CDC's draft guidance for reopening amid coronavirus includes spaced-out seating in schools, disposable menus in restaurants,” CNN, 4/30/20

[ii] Id.

[View source.]

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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