As New York begins the process of reopening the economy, a key industry in the second phase is office based work. But what will that look like in the era of social distancing? New York State announced guidelines for how offices should operate. These rules apply to professional services, nonprofit, technology, and administrative support. The guidelines include both mandatory steps as well as recommended best practices.
Requirements are below:
- In Phase II, limit the total number of occupants at any given time to no more than 50% of the maximum occupancy for a practical area as set by the certificate of occupancy.
- A distance of at least 6 ft. must be maintained amongst all individuals at all times, unless the safety of the core activity requires a shorter distance.
- Any time workers or visitors must come within 6 ft. of another person, acceptable face coverings must be worn (ensuring that mouth and nose are covered). Individuals must be prepared to don a face covering if another person unexpectedly comes within 6 ft.
- Prohibit the use of tightly confined spaces (e.g. elevators, vehicles) by more than one individual at a time, unless all individuals are wearing face coverings. If occupied by more than one person, keep occupancy under 50% of maximum capacity.
- Post social distancing markers using tape or signs that denote 6 ft. of spacing in commonly used and other applicable areas on the site (e.g. clock in/out stations, health screening stations).
- Limit in-person gatherings as much as possible and use tele- or video-conferencing whenever possible. Essential in-person gatherings (e.g. meetings) should be held in open, well-ventilated spaces with appropriate social distancing among participants.
- Shared workstations (e.g. “hot-desks”) must be cleaned and disinfected between users.
- Reduce interpersonal contact and congregation through various methods (e.g. adjusting workplace hours, limiting the in-person presence to necessary staff, shifting design, reducing the on-site workforce, staggering arrival/departure times to reduce congestion in lobbies/elevators).
- Non-essential common areas (e.g. gyms, pools, game rooms) must remain closed.
- Employers in New York must provide employees with an acceptable face covering at no cost to the employee/contractors and have an adequate supply of coverings in case of replacement.
- Acceptable face coverings include but are not limited to cloth (e.g. homemade sewn, quick cut, bandana) and surgical masks unless the nature of the work requires stricter PPE (e.g. N95 respirator, face shield).
- Face coverings must be cleaned or replaced after use or when damaged or soiled, may not be shared, and should be properly stored or discarded.
- Train workers on how to don, doff, clean and discard PPE (training should be extended to contractors if the building managers/owners supply contractors with PPE)
- Must advise workers and visitors to wear face coverings in common areas including elevators, lobbies, and when traveling around the office.
- Limit the sharing of objects (e.g. tools, laptops, notebooks) and discourage touching of shared surfaces; or, when in contact with shared objects or frequently touched areas, wear gloves (trade-appropriate or medical); or, sanitize or wash hands before and after contact.
Cleaning and Hygiene
- Adhere to hygiene and sanitation requirements from the Centers for Disease Control and Prevention (CDC) and Department of Health (DOH) and maintain cleaning logs on-site that document date, time, and scope of cleaning.
- Provide and maintain hand hygiene stations for personnel, including handwashing with soap, water, and paper towels, as well as an alcohol-based hand sanitizer containing 60% or more alcohol for areas where handwashing is not feasible.
- Provide and encourage employees in New York to use cleaning/ disinfecting supplies before and after the use of shared and frequently touched surfaces, followed by hand hygiene.
- Ensure that equipment is regularly cleaned and disinfected using registered disinfectants, including at least as often as employees and contractors change workstations.
- Cleaning and disinfecting of the site, shared surfaces, and other areas, as well as equipment and tools, should be performed using the Department of Environmental Conservation (DEC) products identified by the Environmental Protection Agency (EPA) as effective against COVID-19.
- Regularly clean and disinfect the site and more frequently clean and disinfect high-risk areas used by many individuals and for frequently touched surfaces.
- Rigorous cleaning and disinfection must occur at least after each shift, daily, or more frequently as needed.
- Regularly clean and disinfect the location or facility and conduct more frequent cleaning and disinfection for high-risk areas used by many individuals (e.g. restrooms) and for frequently touched surfaces.
- Provide cleaning and disinfection of exposed areas if an individual is confirmed to have COVID-19, with such cleaning and disinfection to include, at a minimum, all heavy transit areas and high-touch surfaces (e.g. elevators, lobbies, building entrances, badge scanners, restrooms handrails, door handles).
- Prohibit shared food and beverages (e.g. buffet-style meals).
- Affirm you have reviewed and understand the state-issued industry guidelines, and that you will implement them.
- Post signage throughout the site to remind personnel to adhere to proper hygiene, social distancing rules, appropriate use of PPE, and cleaning and disinfecting protocols.
- Train all personnel on new protocols and frequently communicate safety guidelines.
- Establish a communication plan for employees, visitors, and clients with a consistent means to provide updated information.
- Provide building managers/owners a list of essential visitors expected to enter the building.
- Maintain a continuous log of every person, including workers and visitors, who may have close contact with other individuals at the worksite or area; excluding deliveries that are performed with appropriate PPE or through contactless means.
- If a worker tests positive for COVID-19, the employer must immediately notify state and local health departments and cooperate with contact tracing efforts, including notification of potential contacts, such as workers or visitors who had close contact with the individual, while maintaining confidentiality required by state and federal law and regulations.
- Conspicuously post safety plans on-site.
- Employees in New York who are sick should stay home or return home if they become ill at work
- Implements mandatory health screening assessment (e.g. questionnaire, temperature check) before employees begin work each day and for essential visitors, asking about (1) COVID-19 symptoms in past 14 days, (2) positive COVID-19 test in past 14 days, and/or (3) close contact with confirmed or suspected COVID-19 case in past 14 days. Responses must be reviewed and documented daily.
- If a person has COVID-19 symptoms and either test positive for COVID-19 or did not receive a test, the individual may only return after completing at least 14 days of self-quarantine.
- If a person does not have COVID-19 symptoms but tests positive for COVID-19, the individual may only return after completing at least 14 days of self-quarantine.
- If a person has had close contact with a person with COVID-19 for a prolonged period of time and is symptomatic, the individual should follow the above protocol for a positive case.
- If a person has had close contact with a person with COVID-19 for a prolonged period of time and is not symptomatic, the individual must complete a 14-day self-quarantine.
- Coordinate with building managers in New York to facilitate screening. Tenants are responsible for screening their own employees and visitors unless responsible parties and building management have agreed to an alternate arrangement to ensure screening is in effect.
- On-site screeners should be trained by employer-identified individuals familiar with CDC, DOH, and OSHA protocols and wear appropriate PPE, including at a minimum, a face covering.
- Identify a point-of-contact as the party for workers and visitors to inform if they later are experiencing COVID-19 related symptoms, as noted in the questionnaire.
- Have a plan for cleaning, disinfection, and contact tracing in the event of a positive case.
Businesses of all types in New York should be aware of these rules and figure out how such guidelines could be adjusted for your industry.