Governor Whitmer’s Executive Order 2020-42 (COVID-19) proscribes that businesses, operations, and government agencies that continue in-person work must develop a COVID-19 preparedness and response plan, adhere to it, and make it available at company headquarters or the worksite.
The Executive Order requires COVID-19 preparedness and response plans to be “consistent with recommendations in Guidance on Preparing Workplaces for COVID-19, developed by the Occupational Health and Safety Administration (OSHA). Exec. Ord. 2020-42, Parag. 10(a).
What Should Be In Your Plan (At a Minimum)
The OSHA guidance gives non-binding guidance on the contents of plans, but is a good primer on how business leaders should start to think about their plans.
Your business should think about:
- Preparing and Implementing Basic Infection Prevention Measures
Develop Policies and Procedures for Prompt Identification and Isolation of Sick People, if Appropriate
- Developing, Implementing, and Communicating about Workplace Flexibilities and Protections, including enhancing remote work platforms and providing PPE for in-person work
- Implementing Workplace Controls, and adjust the workplace environment
- Following Existing OSHA Standards, and
- Classifying Risk and Potential Worker Exposure
One Size Does Not Fit All
Each business has different considerations, and each workplace’s plan should take those unique characteristics into account.
By example, is your business:
- A conventional commercial office space
- A medical, dental, veterinary, laboratory, or clinical workspace
A commercial warehouse or light industrial space that does not deal with the public
- A large commercial or retail space (more than 50,000 square feet that deals with the public
- A small commercial or retail space
- A licensed or certificated service, like anesthetists, cosmetologists, barbers, body artists, and phlebotomists
- Small construction and home maintenance and improvement (indoors)
- Large construction and commercial worksites (outdoors)
- Manufacturing and middle-heavy industry production
- Heavy industrial production, or
- Commercial Transportation Services
There may be transmission controls in place for transportation businesses that don’t necessarily apply to small commercial spaces. Medical environments have different considerations from manufacturing businesses. Mandatory OSHA rules take these considerations into account, and they should make their way into your plan.
Let’s handle it together.