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The COVID-19 Return-to-Work Guide for Small Businesses

Mona Bushnell
Mona Bushnell

Find out how and when to reopen your business safely, with industry-specific advice for small business owners.

While there is no roadmap to guarantee a smooth return to work in the wake of the coronavirus, there are guidelines and strategies you can implement now to help your business ease back into normalcy, or at least some version of it. This guide for the small business reader offers information on how businesses nationwide will begin to reopen, as well as targeted industry advice for workplace safety and valuable resources to help you create an action plan for getting back to work.

How should a return-to-work program be implemented?

President Donald Trump has released a guide, Opening Up America Again, which answers some basic questions you may have about how the country will begin reopening and where your business fits into that equation. (Keep in mind that the guidelines outlined here are just that – guidelines – and each state is free to make its own decisions about reopening.) It recommends that states meet the following criteria before reopening:

  • There should be a 14-day downward trajectory of the number of patients with COVID-19 symptoms and patients with influenza-like symptoms.

  • There should be a 14-day downward trajectory for documented COVID-19 cases or a downward trajectory for positive tests as a percentage of total tests for the same period of time.

  • Hospitals should be able to meet all patients' needs without crisis care.

  • There should be a "robust testing program in place for at-risk healthcare workers, including emerging antibody testing."

Because states are managing the coronavirus independently, the White House guidelines are general advice with a lot of room for interpretation and various applications. That said, the Trump administration's guide provides some ideas on how businesses should protect themselves and their employees throughout each phase of reopening. Regardless of disease control phase, the document provides recommendations about sanitation, social distancing, protective gear, temperature checks and business travel.

Phase one guidelines

Throughout the first phase, business owners may begin to start operations again, but it's recommended to do it in stages, not all at once. All employees who can feasibly do their jobs remotely should be allowed to continue to do so. The only employees who should return to work onsite in phase one of reopening are those who cannot perform their duties from home.

The guidance says that during business operations, common areas should be closed off, nonessential travel should be minimized in accordance with CDC guidelines, and business owners should create a plan to work with their companies' most vulnerable members, who may need to continue social distancing at home.

Throughout phase one, it is recommended that schools, organized youth activities, large venues (concert arenas, movie theaters, etc.), elder care facilities and bars remain closed to the public, but that gyms reopen and elective surgeries resume.

Phase two guidelines

According to the guidelines, states should only enter phase two after they have completed phase one and allowed enough time for them to pass the preliminary disease control requirements (having a decline in cases and symptoms over a 14-day period) a second time. In other words, a state must have another decline in cases over another two-week period to reach phase two.

Even at this juncture, vulnerable populations are advised to continue sheltering at home and social distancing, so it is imperative that your company has an accommodation plan for vulnerable employees going forward. Employees who are not vulnerable but reside with someone who is should continue social distancing so as not to put their households at risk.

At this stage, the government still recommends that all businesses encourage remote work whenever possible. Workers should not be required to return to the office if they can reasonably do their jobs remotely. Only employees who cannot work from home should be in the workplace.

In phase two, youth activities may resume, large venues can operate if they maintain social distancing rules, and bars may reopen at lower capacity, but elder care facilities should remain closed to the public.

Phase three guidelines

To enter stage three, states must pass the initial gatekeeping guidelines yet again. So, for a third time, the state should be able to show a 14-day decline in coronavirus cases. At this stage, employers may resume unrestricted staffing of worksites. Vulnerable populations are encouraged to resume public interaction very conservatively, maintaining social distancing guidelines where possible.

At this stage, large venues may reopen with more lenient social distancing in place, bars can increase their occupancy, and people can visit patients in elder care facilities and hospitals.

Trump's COVID-19 reopening plan versus state reopening plans

As of the writing of this article, no states have achieved the 14-day decline guidelines laid out in Opening Up America Again. However, since states are legally allowed to reopen whether they've met these benchmarks or not, they are starting to do so.

Just because your state decides to allow businesses more leeway in operations does not mean you have to reopen. Business owners must each judge for themselves what is reasonable and financially feasible, while staying within the confines of the local law.

For up-to-date coverage on which states are reopening and to what extent, consult this comprehensive guide from the U.S. Chamber of Commerce.

What policies need to be updated as employees return to work?

Before your employees return to work, you need to have a plan for balancing workplace safety and profitability. We have compiled these guidelines and resources from various states' government websites as well as from the best practices espoused by the CDC and the U.S. federal government.

1. Create a COVID-19 business cleanliness plan.

Implement stringent cleaning plans and sanitization processes for disease control before reopening your business premises. The CDC offers the best and most detailed plan for business sanitization, and we highly recommend all business owners refer to it.

Prior to creating an action plan, reach out to the most reliable people on your team now, especially managers and department heads, and collaborate with them as you develop back-to-work strategies. Also consider the guidance from the Occupational Safety and Health Administration (OSHA) on developing an infectious disease preparedness and response plan; this guide includes direct advice on creating good workplace policies and controls to promote workplace safety.

2. Support public health while running your business.

Beyond basic sanitation, having a real, actionable plan for supporting public health and worker safety is imperative. In addition to social distancing – which may require reorganizing your workspace, or staffing workers in shifts with only 50% of them working at a time – you will need to consider providing personal protective equipment (PPE), which may include hand sanitizer, gloves, masks or shields.

In addition to procuring the appropriate PPE for your staff, you will need to create policies around using it and around sanitization efforts in general. The CDC recommends appointing one employee as the workplace coordinator to oversee the pandemic return-to-work process. Reputable sources are careful to point out that training is essential for effective use of PPE. Free training videos from the CDC are available online.

Lack of compliance with new safety measures may become an issue among employees. Your messaging around the safety precautions should make it clear that following these protocols is now part of each worker's job duties and there will be repercussions for noncompliance. If you have any in-house human resources professionals, you should work with them to make sure safety standards are clearly communicated and understood.

3. Provide reasonable accommodation and sick leave.

Reasonable accommodation for vulnerable populations is recommended throughout every phase of reopening, and continuing remote work (where it applies) is the most obvious solution. According to Opening Up America Again, vulnerable populations include all elderly people, as well as "individuals with serious underlying health conditions, including high blood pressure, chronic lung disease, diabetes, obesity, asthma, and those whose immune system is compromised, such as by chemotherapy for cancer and other conditions requiring such therapy."

Many companies have announced that they are allowing all employees to continue remote work indefinitely, and to only return to the office premises when they feel compelled to do so.

Of course, not every job can be done with just a laptop and an internet connection. If you employ workers who must be onsite, you'll need a plan for vulnerable employees who cannot come back to work. You might assume no one in your workforce is a vulnerable person, but in addition to employing someone with an invisible illness or disability, you may well have a staff member who lives with a high-risk person.

If you ask your employees about their health, you must stay within the law and not overstep any boundaries. The U.S. Equal Employment Opportunity Commission breaks down the boundaries set by the ADA, the Rehabilitation Act and other EEO laws here. It may also be worthwhile to consult your business's attorney on how to communicate and roll out your reasonable accommodation plan to your affected employees.

Your communications to staff regarding pandemic accommodations should include not only information for vulnerable populations but also general policies on sick leave and PTO during this challenging time. Most businesses are creating coronavirus sick leave policies that allow employees to stay home for two weeks at a time if they are at all ill. That way, workers don't come to work sick in an effort to preserve their accrued sick leave or PTO. You should also establish how you expect employees to relay their symptoms to their managers and have a plan for the managers should they need to make a quick staff replacement.  

COVID-19 return-to-work plans by industry

Many states, such as Connecticut and Texas, as well as independent business organizations like the American Industrial Hygiene Association have issued industry-specific guidelines for reopening businesses in a COVID-19 world. Here are some key takeaways for small business owners, based on industry, as well as links to helpful resources with more detailed descriptions of to-do lists, action items and reopening strategies. We recommend consulting multiple sources of information for reference as you create your own COVID-19 return-to-work plan.

Gyms, fitness centers and outdoor sports

Common guidelines for gym owners include operating at half occupancy by blocking off half of all machinery, limiting the number of patrons working out at a time, providing PPE to workers and having patrons bring their own towels. AIHA has a free guidance document for gyms and fitness centers, as do several states, including Arizona, Idaho and Tennessee. There are also COVID-19 guidance documents from the CDC for park administrators and managers of public swimming pools and aquatic centers.

Hair salons, aesthetician services and barber shops

Along with operating at half capacity, there are several recommended strategies for operating a hair salon, spa or barber shop. This free guidance from the Connecticut state government is particularly detailed, including recommendations for close-up tasks like beard trims and facials. AIHA has a guide just for hair and nail salons, as does the state of Colorado.

Industrial and construction businesses

Many construction companies and essential industrial outfits are already operating, but there are industry guides available for those that are just now reopening. The CDC guidance for manufacturers is comprehensive and potentially useful for any small business owner in the industrial sector. This guide from AIHA is an essential read for construction-related businesses, and this guide on in-home service providers may be of interest as well.

Offices

There is ample CDC guidance for reopening offices while maintaining public health, but all official recommendations state that every staff member who can work remotely should continue to do so throughout all the reopening phases. If your business's essential onsite workers are returning to the office, this CDC guide for small businesses and this AIHA guide for general office settings are helpful.

Restaurants

Disease control is always a concern for restaurants, but doubly so now, which is perhaps why there is more guidance for food service than for any other industry. The Food and Drug Administration published this checklist for food safety, and the National Restaurant Association's comprehensive guide is also worth reading. There are also state-specific resources, like the excellent guides for California and Nebraska.

Retailers

This succinct guidance from OSHA for retail workers offers insight into what you need to provide for your workers. If you're a member of the National Retail Federation, you can access its support portal that's recommended by the U.S. Chamber of Commerce. In case you're not an NRF member, this retail guide from AIHA is excellent.

When should my business reopen?

CDC guidance indicates that reopening the economy, in the U.S. and elsewhere, will be a long, gradual process, potentially laced with minor setbacks and readjustments. It's key to cultivate an attitude of flexibility from the top down and to prioritize your employees' health. As to when you should bring employees back to work, that's a matter of what's approved in your local area, how fleshed out your pandemic operation measures are, and what you and your staff are willing to do.

If you have a comprehensive plan for sanitizing and social distancing in your workplace, providing paid sick leave for employees with illness, offering remote work options where available, and serving clients safely, you're doing just about all you can do to prepare for a successful reopening.

Mona Bushnell
Mona Bushnell,
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