COVID-19 Return to Work Guidelines: Safety and Risk Considerations

Posted in: Commercial Insurance, COVID-19

This blog is the final installment in a three-part series addressing return to work considerations discussed in a recent PSA webinar. In part one, we covered COVID-19 testing and managing sick employees, and in part two, we discussed HR considerations for getting employees back to the workplace and granting accommodations. In this post, we focus on different safety considerations – including 6 goals to keep in mind, 15 topics to cover, and 6 risk and safety management controls to apply – to help create a safe environment for your employees when returning to work.

6 Goals When Drafting Your Written Return to Work Plan 

It’s critical that any safety measure you take regarding this COVID-19 crisis is documented in writing. From an OSHA and attorney standpoint, if it’s not in writing, it never happened. Here are the key goals to keep in mind when developing your written plan:

  1. Determine time frames. If everything is working well with remote working or a reduced workforce, ask yourself if you need to rush to physically reopen and potentially expose employees. I recommend that if you can’t pick a date for returning to work at this point, that you provide a “no earlier” date to employees, so they have time to prepare and reduce their stress.
  2. Stress commitment to employee and client safety. In my experience, employees are definitely concerned about coming back to work, and they may not be sharing these concerns with you. A written plan reassures your staff that you’re considering all risks and taking proactive action to protect them.
  3. Demonstrate that you have thought about the major issues. Don’t worry about writing the perfect plan, because you will need to adjust it as the pandemic evolves. Just show employees that you are carefully considering the potential issues in your strategy.
  4. Proactively address the most likely questions. Brainstorm what questions your employees may have and address them before releasing a return to work plan to reduce employee anxiety.
  5. Be a unified front. Management should be in complete agreement with the plan. Deviations will cause confusion, stress, safety concerns, and potential discrimination claims.
  6. Be ready for a second wave. Review what worked well and what didn’t from your initial response to the COVID-19 crisis. Make changes based on your conclusions and be ready for a potential second wave.

15 Key Topics to Cover in Your Return to Work Plan

This is a high-level list of all key areas you should focus on when drafting your return to work plan. For more details to help create a framework for your written plan, download this free resource.

  1. Guidance
  2. Training
  3. Staggered start
  4. Employee screening
  5. Personal Protective Equipment (PPE)
  6. Cleaning
  7. Shared items
  8. Social distancing
  9. Limited interaction
  10. Mass gatherings
  11. Client interaction and travel
  12. Visitors and tenants
  13. Sick employees
  14. Communication
  15. Flexibility

Hierarchy of Controls 

As you are considering the different key areas for workplace safety, leverage the hierarchy of controls—a risk management thought process, for every decision you make in your return to work plan. It’s a system of controls that allows you to identify the most effective way to control a hazard that moves from most effective to least effective.

  1. The most effective control is eliminating the exposure to a hazard. You can accomplish this by having your employees continue to work from home, avoiding public places, holding virtual meetings, etc.
  2. If you can’t eliminate the hazard, move to substitution. Replace the hazard with something less hazardous. While there might not be a substitution for COVID-19, this control is still highly effective in many other situations to manage risk.
  3. If you can’t eliminate or substitute the risk, move to engineering controls. Isolate the person from the hazard by taking actions such as erecting plexiglass barriers and using approved cleaners and disinfectants proven to eliminate the virus.
  4. If you can’t engineer the risks away, use administrative controls to change the way people work—social distancing, hand washing, and floor markingswithin your establishment.
  5. If the above step cannot be done, provide personal protective equipment (PPE), such as masks and gloves.
  6. With COVID-19, you also need to consider community protective equipment for visitors coming into your building.

Make sure you don’t unintentionally create additional hazards when you are implementing any of these controls to eliminate or reduce the COVID-19 risks. For example, make sure any barriers you install are secure and aren’t going to fall over or create a trip and fall hazard. I am also noticing people leaving long mask strings (if not using elastic ear loops) hanging down their face and neck. Be careful of the types of face coverings you allow for employees working around equipment and machinery in order to avoid potential accidents.

A final thought—be aware of COVID-19 blindness. What do I mean by that? If you focus solely on COVID-19, your overall workplace safety procedures can suffer. Make sure you don’t ignore other serious or fatal injury exposures to your employees like fleet safety, fall protection, electrical safety, fire and evacuation safety, etc.

PSA is here to support our clients as we all strive to return to work. If you have questions about creating a written return to work plan that addresses all of the key areas for your industry, feel free to contact me at Also, don’t forget to leverage our COVID-19 Business Resources for relevant updates and educational materials regarding the pandemic.