As states continue to move through the reopening process, employers, building owners, and building managers are beginning to allow non-essential office workspaces to reopen, and a list of those states can be found here. Most states - and in some cases, counties and municipalities - have issued specific guidance and requirements that office workspace employers, as well as office building owners and management companies, need to comply with. On May 28, 2020, the CDC issued its own set of guidelines for office buildings, which creates a minimum set of requirements that businesses should comply with whenever possible, even if they are not required under relevant state or local orders.
The following chart provides a summary of the key provisions. It is important to note that some aspects of the guidance are applicable to building owners and property managers, some are applicable to employers, and some are applicable to both, so we have organized this information based on the groups that are responsible for each task. In addition, this is a summary, not a complete list of every detail contained in the CDC Guidance, so businesses should conduct their own review, adapt the guidance to their specific circumstances, and consult with counsel where appropriate prior to reopening.
Create a COVID-19 Workplace Health and Safety Plan
Property Owners/Management Companies
Worker Hazard Assessment
Hazard Assessment Considerations
Property Owners/Management Companies (Multi-Tenant Office Buildings)
Engineering Controls: Physical Distancing
Modified Workstations and Other Office Areas
Modified Building Common Areas (Multi-Tenant Office Buildings)
Increased Ventilation and Filters
Administrative Controls: Workforce Modification
Staying Home When Ill
Daily Health Checks
Changes in staffing and workforce
Cleaning, Disinfection, and Personal Hygiene
Social Distancing Policies
Commuting by Public Transit and Rideshare
How to Deliver Educational Messages Regarding COVID
As employers, building owners, and building managers navigate the return to work process, they will need to be nimble in adapting to the demands of protecting workers and guests from COVID-19 exposure. The CDC, state and local authorities have continued to evolve their guidelines as scientists discover more about this disease, and as various jurisdictions grapple with balancing the progression of this disease through their communities with economic needs. Our teams are actively monitoring all of these changes and advising our client on reopening plans, and we would be happy to discuss any specific questions that you might have.