COVID-19 Returning to Work - CNA Hardy
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COVID-19 Returning to Work Risk Control
Prep guide
As governments begin to ease business closure orders in the wake of the COVID-19 outbreak,
employers face the task of reopening their physical workplaces. Regardless of whether employees
are returning to corporate spaces, manufacturing complexes, industrial factories or other commercial
settings; employers need a workable, detailed re-entry plan in order to protect workers from
unintended harm and minimise further disruption to business operations.
Non-compliant handling of the reopening process can have serious risk and liability consequences,
including worker injury and exposure due to substandard safety protocols, fines and penalties for
regulatory noncompliance, and employment-related legal challenges.
This CNA Hardy resource presents strategies to help employers navigate the re-entry process,
including critical first steps in the planning process and initiatives to ensure that workplace re-entry
plans comply with essential safety and exposure control requirements. By taking time to prepare and
plan for re-entry provisions, employers minimise disruption, encourage trust in the workplace and
fulfil their responsibility to safeguard employees.
Getting started
Successful transition to a post-pandemic workplace In addition, appoint a committee chairperson who is
depends upon organisational readiness for change, risk responsible for overseeing the workplace re-entry
identification and mitigation, regulatory compliance and period, to manage and oversee the immediate and
effective communication. The following preparatory effective change required. Together with committee
measures, among others, are essential to achieving members, the chair will facilitate a workplace risk
impactful change in the workplace: assessment, draft a re-entry plan, and serve as a
highly visible contact for employees regarding policy
Appoint a return-to-work committee and procedure directives.
The first step in addressing the realities of a new work
environment is to initiate a dialogue among Identify workplace risks and hazards.
individuals who bring a range of experience and Risk assessment
expertise to the reopening process. A suitable and sufficient workplace risk assessment is a
statutory legal requirement. It allows employers to
Assemble a committee comprised of key stakeholders, understand their vulnerabilities, implement measures
including managers, workforce representatives, human for a safe working environment and enhance their legal
resources professionals, occupational safety advisors, position in the event of liability claims.
security personnel and environmental health experts,
among others as appropriate.
Risk Control – COVID-19 Returning to Work
An assessment should encompass all work locations Develop a communications plan
and shifts, and include the following areas of focus,
at a minimum: An organised and transparent approach for conveying
workplace directives is essential for building trust in
• Business practices and critical operations
the workplace. A written communication plan should
• Business continuity plans encompass re-entry objectives and management
• Potential points and methods of COVID-19 expectations, utilising various methods of conveyance,
exposure for returning workers including the following:
• Shared workspaces, and potential for flexible work • Dedicated sections on company intranet websites,
sites and hours designed to allow and encourage communication
• Work travel (including to, from and during work, channels between management and the workforce
and use of public transport) and meeting options • Virtual meetings intended to promote workplace
• Employee/visitor access controls transparency regarding employee responsibilities,
• Risks relating to suppliers, contractors and clients performance goals and compliance issues
• Employee training requirements and capabilities • Employee contact helplines, established to relay
• Cross-training needs in the event of absenteeism urgent updates and safety messages
and/or agency coverage • Appointment of ‘Compliance Supervisors,‘
• Environmental cleaning and disinfection practices selected to advise and instruct employees on the
• Social distancing and work station arrangements safe use of workspaces
• Personal protective equipment (PPE) and • Signage, leaflets and alert bulletins, posted and
respiratory protective equipment (RPE) provisions circulated to reiterate social distancing protocols
and training in the use of it, including hand and housekeeping measures, among other safety
hygiene protocols initiatives
• Alternate supply chains for critical goods • Communication documents, including Question &
• Provisions to identify and isolate employees with Answer postings and stay-safe guidance
symptoms of COVID-19
• Services and delivery options Key re-entry plan initiatives
• Sick absence policy and management Businesses that lack a formal re-entry and exposure
• Methods for monitoring public health information control plan are at a disadvantage in the areas of
and reporting communicable diseases regulatory compliance and legal defence. Employers
• Confidentiality provisions for employee and visitor can customise a written plan to fit their circumstances
health information in compliance with the General – considering operational requirements, facility
Data Protection Regulations (GDPR). locations and workforce capacity – but most contain
these key initiatives:
To help employers assess the potential for workplace
exposure in a comprehensive manner, a checklist is Sanitise and clean the workplace
available from CNA Hardy – Restarting Business Maintaining a clean, safe and healthy work environment
Premises Following Shutdown. is essential to reducing COVID-19 exposures and
reassuring apprehensive employees as they return.
Compliance monitoring Using disinfectants perform an initial preventative
The COVID-19 pandemic has been characterised by decontamination of workspaces, including all high-touch
rapidly changing compliance requirements updated by surfaces, such as desks, tables, chairs, door handles,
the relevant governments in each country. elevator controls, light switches, and toilets.
Employers must frequently monitor compliance Also clean and disinfect shared equipment, such as
protocols and instructions during the re-entry period to phones, pens, keyboards, touchscreens and remote
ensure compliance with the government updates. By controls.
appointing a Compliance Manager or department,
employers are more likely to produce a comprehensive To further mitigate exposure, determine a workable
history of compliance mandates and activities during schedule for ongoing environmental cleaning and
critical site surveys, as well as a thorough record of disinfection, especially of highly trafficked areas and
important action implementation and revision dates. services. Consult the government advice relevant to
your country. Lastly, cases of confirmed on-site
exposure prompt immediate decontamination of
potentially contaminated areas, as set out in a
written procedure.Risk Control – COVID-19 Returning to Work
Modify workspaces for social distancing. • Mandatory hand washing requirements, using
Social distancing requirements will be essential in appropriate sanitizers that are available
disease prevention, including limited office attendance throughout the premises.
numbers and a minimum of 2 metres (or specified • Respiratory Protective Equipment (RPE) provisions
government distances) separation from co-workers. The determined by Face-fit testing. Physical controls to
following environmental modifications can further assist prevent congestion in elevators, stairways, restrooms,
in safeguarding employees: meeting rooms and cafeterias, along with centralised
waste receptacles
• Limit points of entry, and use covered egress and
ingress portals for buildings and other structures. • Discontinued self-service food / drink stations -
ban on shared work equipment, such as headsets,
• Remove chairs and computer monitors from
keyboards/mouse controls, and other objects that
unused workstations.
come in frequent contact with hands, or are used
• Revise seating and workstations in common areas
near the eyes, nose or mouth
workspaces.
• Clear work stations from personal items.
• Apply floor markings or other visuals to
establish one-way directional traffic and Address the safety needs of employees in
movement patterns. higher-risk settings.
• Install transparent shields and other physical Special guidance is required for employees who work in
barriers between workstations, in reception areas environments that are residential, located off-site or
and on assembly lines. high public areas such as banking and retail operations.
Draft an exposure control plan. The threat of exposure can be substantially higher
To reduce work-related exposures to COVID-19, for these workers than that of employees in a
governments recommend development of an contained work environment.
infectious disease preparedness and response plan.
As part of a plan, develop measures to promptly The following can assist with high-risk worker
isolate employees who report illness during protections:
workhours. This includes a designated area where • Advise employees to minimise contact with
workers can be isolated and receive medical support. high-touch surfaces, such as key entry pads, card
Strictly enforce an employee’s home isolation in line readers, door handles, light switches and restroom
with governmental requirements as part of the surfaces.
exposure protocol. In addition, implement contact • Adopt paperless payment systems, and instruct
tracing procedures to identify potentially exposed customers to use their own pen if a signature is
employees, and follow legal requirements on required, or have a designated receptacle for pens
reporting occupational disease that require sanitising after customer use.
• Disinfect key entry or touchpad surfaces regularly.
Implement essential safety protocols.
Once workplace hazards have been spatially mitigated • Erect Perspex barriers where employees are in
and potential exposure points identified, both close proximity to customers, or if they are
business and employee risks must be addressed. Be expected to converse with them.
sure to document all measures taken, as these records • Provide suitable and sufficient PPE, including face
may be critical to limiting employer exposure to coverings, gloves, shoe covers, and hand and
potential claims. surface sanitizers, as well.
• Reinforce the importance of hand hygiene and the
A preventative approach begins with the implementation use of sanitiser before and after customer contact.
of basic safety protocols, including the following: • Establish a disinfection/cleaning routine for off-site
• Social distancing signage and face mask environments, including work surfaces, tools and
expectations equipment, service uniforms. Also adopt strict
• Access control systems that restricting and waste removal specifications.
monitoring building or area access, along with • Refrain from using customer restrooms, and
health screening protocols decline to accept any beverage or food offering
• Maximum occupancy limits and an enforceable • Allow additional time to ensure precautions are
procedure to ensure compliance with social complied with, and inform customers of all
distancing requirements measures being taken to protect them and the
• Staggered shifts and break times to reduce the employee.
number of employees in one location • Avoid nonessential employee travel requirements.Risk Control – COVID-19 Returning to Work
Plan ahead for PPE supply demands Remain cognisant of employment law
In order to prevent problematic shortages of compliance standards.
protective supplies and equipment, assess and project As workers return, employers are obligated to
the amount of PPE required which may include gloves, extend employment protections in line with
disposable facemasks, full-face shields, respirators, government advice relevant to your country and local
hand hygiene supplies, overalls and waterproof shoe laws. Failure to do so may result in unwanted legal
and boot covers, among other items. challenges, including the following:
When selecting suppliers, consider the lead time Discrimination
necessary for ordering and delivering PPE, as well as Do not base decisions regarding returning employees
whether it is procured from a local or foreign to the workplace on protected characteristics such as an
manufacturer, as the latter can present additional employee’s age, disability, gender, race and/or religion,
risks for product delay and contamination. All PPE or any other class protected against discrimination laws
must be to the standard required in the country of relevant to your country. Employers may not exclude an
use. Adopt engineering controls. employee from returning to work, or take any other
adverse action, solely because they may be at a higher
An effective re-entry programme encompasses the risk for serious complications from COVID-19, such as
use of engineering controls, such as improved air age or certain underlying medical conditions. All
filtration and ventilation systems minimising employee employment decisions, including re-entry, should be
exposure to air toxins. In addition, a combination of based upon legitimate, non-discriminatory business
the following engineering controls, along with others, reasons and should be documented.
can help kerb liability, heighten compliance levels and
contribute to a workforce peace of mind: Employers should ensure they comply with the
• Place card readers a safe distance from cashiers. discrimination and equality laws relevant to the
• Offer remote shopping arrangements, including country at all times.
online ordering, home delivery and collection. Employees may be subject to COVID-19-related
• Rearrange furnishings to promote 2 metres (or set discrimination and/or harassment because of their
government distancing) of separation. national origin, race, or membership in other
protected classes. To mitigate this risk, offer training
Draft employee return to work plans.
sessions for managers and employees that reinforce
Re-entry of employees will vary by setting depending
the employer’s commitment to promoting equality in
upon risk factors, lines of business and operational
the workplace. Attendance at all training sessions
capacities. For some employers, a tiered phase-in
needs to be documented.
plan may initiate with critical staff members who
report no COVID-19 symptoms, as well as those who Failure to accommodate
cannot work remotely. This approach may require on- Employers may, for both physical and mental disabilities,
site health screening and/or employee temperature in the COVID-19 transition period receive requests for
checks before workers are permitted to return as job task alterations such as light works or modified
well as requesting that the employee informs the works. If an employee requests this, an employer must
workplace of any symptoms personally or household acknowledge and determine if a reasonable solution
prior to attending the workplace. exists which will permit the employee to perform the
Regardless of the scope of a return to work, re-entry essential functions of his or her position.
can cause stress potentially leading to increased This may include remote working, temporary job
employee absenteeism, abuse of work-flexibility options transfers, work restructuring and / or flexible work hours.
and other performance-related issues. Job performance
objectives must be consistent with employee well- Whistleblower and retaliation claims
being. During the critical re-entry period, provide Employees may assert complaints regarding health
employee assistance programs, ranging from simple and safety or complaints asserting retaliation, such as
one-to-one interactions to structured support groups. for testing positive for COVID-19 or for requesting
These offerings not only stabilize the workforce in the disability-related job alterations or absence leave. In
short term, but also contribute to future gains in the written policy, strictly prohibit retaliation against
areas of company culture, employee satisfaction, employees who raise concerns regarding working
engagement, productivity and retention. conditions or for exercising their rights under laws
relevant to your country. Appoint COVID-19
coordinators in the workplace to serve as liaisons
between the workforce and management, in an effort
to defuse conflicts and disagreements.Risk Control – COVID-19 Returning to Work
Breach of privacy Document the initial training of all employees,
Disclosure of information regarding employees who including names of attendees and the dates of the
have tested positive for COVID-19, or other training, as well as annual refreshers.
identifiable medical data, may violate GDPR or
government laws relevant to your country and/or Employers face unprecedented complexities as they
disability laws. Even routine tasks, such as checking begin to the return to work process in the wake of the
employees’ temperatures or screening for health COVID-19 outbreak. In order to establish a safe work
conditions, can trigger privacy and recordkeeping environment and ensure business continuity,
requirements, especially as they relate to employers must implement a re-entry plan that is
occupational disease exposure and access to medical tailored to individual needs, yet compliant to
records. All medical information, if retained, should regulatory demands and infection control
be maintained as per GDPR requirements. Consult a requirements. The guidance provided in this risk
legal representative to ensure adequate safeguards management guide can help employers plan a
are in place to protect the privacy and confidentiality coordinated and deliberate response to return to
of workers. work, thereby potentially reducing exposure to worker
injury claims, employment-related challenges and
Train employees on COVID-19 precautions disruption in business operations.
and requirements.
Training should include all categories of employees and Resource links
encompass different workplaces and facility locations. • UK government latest news
Training sessions should include the basics of COVID-19
• HSE guidance on health and safety
exposure and describe the following:
• ECDC risk assessments for disease prevention
• Public health and safety protocols, as well as and control
control measures such as hand hygiene and
• EU Science Hub updates
respiratory requirements
• BOHS worker health protection advice
• Common transmission methods between
• REHVA guidance for designers and building
employees in the work environment
services engineers
• Essential cleaning and disinfection expectations,
including safe work practices to prevent chemical Risk Control Guides from CNA Hardy
exposures • Ergonomic tips for working remotely
• Reporting procedures for potential COVID-19 or • COVID-19 returning to work prep
suspected symptoms as defined by government • Equipment and systems outage preparation
guidance and recover
• Required personal protective equipment use, and • Hygiene controls in the workplace
instructions on the disposal or maintenance / washing
of contaminated equipment and respirators
• Complaints handling procedure and workplace
reporting
• Occupational health practices including mental
health
• Absence leave policies and return-to-work
procedures for employees who test positive and/
or have recovered from COVID-19 illnesses
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cnahardy.com
Tel +44 (0)20 7743 6800
The information contained in this document does not represent a complete analysis of the topics presented and is provided for information purposes only. It is
not intended as legal advice and no responsibility can be accepted by CNA Hardy for any reliance placed upon it. Legal advice should always be obtained before
applying any information to the particular circumstances.
Please remember that only the relevant insurance policy can provide the actual terms, coverages, amounts, conditions and exclusions for an insured.
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(“HUAL”, company registration number 1264271) and/or CNA Services (UK) Limited (“CNASL”, company registration number 8836589) and/or CNA Hardy
International Services Limited (“CHISL”, company registration number 9849484) and/or CNA Insurance Company (Europe) S.A., UK Branch (“CICE UK”, company
32594/0820
registration number FC035780). CICL, HUAL and CICE UK are authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority
and the Prudential Regulation Authority (firm reference numbers 202777, 204843 and 822283 respectively). The above entities are all registered in England with their
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