The Centers for Disease Control and Prevention (CDC) released new guidance on Wednesday describing how office buildings can reopen safely as states ease restrictions on non-essential businesses. The new voluntary recommendations, which build on prior CDC guidance discussed in a previous WilmerHale alert available here, emphasize that employers should create a COVID-19 workplace health and safety plan that is clearly communicated to all staff and visitors.
Per the guidance, office building employers should ensure, prior to reopening, that the building is ready for occupancy after months of inactivity. This includes confirming that the ventilation system is working properly, opening windows and doors to increase circulation of outdoor air if possible and safe to do so, and checking for dangers associated with a prolonged facility shut-down, such as mold growth or stagnant water.
Next, the CDC’s guidance for offices advises employers to implement “hazard controls” to reduce the likelihood of disease transmission. The CDC recommends the following measures:
- Installing transparent shields or other physical barriers to separate employees and visitors where maintaining proper social distance is not possible;
- Using signs or floor markings placed six feet apart to indicate where employees and visitors should stand;
- Encouraging employees to conduct meetings and small group activities outside;
- Replacing “high-touch communal items” like coffee pots and shared snacks with pre-packaged, single-serving items;
- Providing accommodations for employees who use public transit to commute to work, including by reimbursing parking costs;
- Prohibiting “handshaking, hugs, and fist bumps”; and
- Using “ultraviolet germicidal irradiation” to help inactivate the virus.
Finally, the CDC encourages office employees to wear a cloth face covering in all areas of the office, but cautions that face coverings are not personal protective equipment and may not protect the wearer from exposure to the virus that causes COVID-19.
Office building employers planning to resume or maintain their onsite operations should consider incorporating the above guidance (as well as guidance from the Occupational Safety and Health Administration), while also ensuring that their return to work and operations plans incorporate applicable guidance and requirements from state and local authorities.
The WilmerHale Labor and Employment team is following these developments closely and is available to provide customized guidance to employers as they resume normal business operations.
