Authored by Christine Mikesell – Administrative Coordinator
Everyone knows by now that New York is slowly starting to reopen businesses across the state. If you didn’t know, then it might be time to crawl out from underneath whatever rock you’ve been living under, or at least turn on the radio every once in a while.
As manufacturing businesses look to reopen, the most important aspect will be the health and safety plan that all employers are required to put together. These plans must be in place before manufacturers can open their doors. If your doors are already open as “essential”, don’t think your business is off the hook, because there are increased measures in the guidance that you are required to implement.
Luckily for you, we here at MTEC are here to help. While we are not experts in contagious diseases or virology, we are here to help you along the way to the best of our ability in accordance with state mandates and guidance. Or, at the very least, put you in touch with someone who can help.
To that end, it is important that our colleagues and clients understand what they are getting into before diving headlong into the process. I’ll give you an overview of requirements, some things you need to watch out for, and a couple solutions you can use to mitigate problems you might come across along the way. We will also cover an additional, necessary step by the state (and some counties), that you may not have heard yet in my helpful hints. Of course, I will also be including some resource sites that you’ll need.
Let’s dig in now, shall we?
New York’s requirements for what is to be included in the plan can be placed in 5 categories (there is also an honorable mention, but more about that later). The categories are: 1) People- your customers, visitors, and employees and the areas where they congregate; 2) Places- your facility and PPE requirements; 3)Hygiene & Cleaning- cleaning plans and requirements; 4) Communication- any training, signage for employees and visitors to provide information; 5) Processes- screening, testing and tracing and requirements for such.
Our honorable mention is called “Phased” in the NYS Manufacturing Master Guidance (more on this later as well). It essentially recommends a “phase-in” when reopening and limiting the number of employees; however, unless core processes or safety demands it, businesses are required to keep occupancy to a level of 50% the building permits anyways, I didn’t want to delve too deep into this…
Now, where were we?
When talking about the “People” the state’s guidelines are talking about visitors, your workforce, and the confined places they can congregate and move through. You are going to want to look for situations where employees can’t maintain 6 ft. of distance between each other. Requiring masks in community areas, stopping bi-directional traffic in small hallways and aisles with signs, and moving workstations apart are some simple and easy techniques to handle these situations. Also, think about staggering or rotating shifts, and having staff that can work from home. Have a plan in place for managing engagement with customers and visitors to minimize contact as much as possible. Don’t overlook things like shift changes and lunch breaks!
“Places” touches on the companies’ responsibility for PPE and commonly touched items. Businesses are going to need to look at what PPE they have on hand, what they need to keep stocked, how will it be stored and cleaned, and if their employees need training to use it. They are going to want to scrutinize common objects that are used by multiple employees. You may require gloves to be worn when using community tools and have employees wipe down keypads after use.
“Hygiene & Cleaning” covers, well, cleaning and hygiene. Facilities will need to be cleaned by CDC and DOH requirements. Certain areas will need to be gone over daily; whereas others will need to be disinfected multiple times a day (for example, high traffic areas and touch points like cafeterias and time clocks, respectively). If you employ a cleaning company, check to see if they offer the additional services. A lot of cleaning business have adapted to the times and are starting to offer these types of disinfecting cleaning. Hand hygiene stations are a must, either hand washing stations or bottles of hand sanitizer placed strategically around the facility, but preferably both.
“Communication” covers what information needs to be displayed and requires companies to have a plan in place to send necessary updates to employees and visitors. For the latter, consider a dedicated webpage or email group. For the former, post signage to tell people masks are required and remind them about maintaining social distancing and proper cleaning procedures. Logs of visitors and employees on-site must be kept as well, so designate one or 2 people to be responsible for signing people in and out.
Finally, “Processes” deals the most directly with the threat and handling of COVID. It involves daily testing of staff and the procedures for tracing and disinfection [of the facility] if an employee or visitor gets sick. Daily screenings can be done on or off site and employers can utilize anything from a survey to a temperature check (as long as DOH requirements are met). A plan will need to be in place as to how the employer can trace people who may have been exposed to someone positive for COVID, as well as a plan to disinfect areas that may have been contaminated.
Some helpful hints and resources to keep in mind:
- Although your business’s health and safety plan does not need to be submitted to the state for approval, it must be on-site and available if requested by the DOH or any local safety or health authorities.
- I referenced the “Manufacturing Master Guidance” earlier. This was created by the state government and they ask that Phase 1 Manufacturers read and affirm that you are operating in accordance with health and safety requirements. You’ll find the link here: https://www.governor.ny.gov/sites/governor.ny.gov/files/atoms/files/ManufacturingMasterGuidance.pdf
- Make sure you check your local county requirements. For instance, Ulster County is requiring companies to fill out a form to certify that they have created a plan, so pay attention!
And with that ladies and gentlemen, I hope this has been informative and hopefully mildly entertaining to read. I am over my maximum word count for this article, but unfortunately there was so much information I didn’t get the chance to touch on. Please feel free to reach out to us if you have any questions. Remember that if we support each other, we will succeed!
Other helpful sites:
https://www.cdc.gov/coronavirus/2019-ncov/community/guidance-business-response.html
https://forward.ny.gov/industries-reopening-phase
For help with planning and templates:
https://mfgtec.org/nymep-back-to-work-playbook/
https://www.governor.ny.gov/sites/governor.ny.gov/files/atoms/files/NYS_BusinessReopeningSafetyPlanTemplate.pdf