What's Next? Guidance to Help Reopen Your Business

April 28, 2020

While the COVID-19 health crisis persists, the country is starting to shift from survival mode to thinking about what’s next. As states and cities begin to lift their stay-at-home orders, questions swirl about when and how will people return to work. The new normal may be a half-speed economy with masks, wipes, testing, temporary quarantines, significant process changes and regional variations.

As the economy starts to reopen, the Centers for Disease Control and Prevention said employers should plan to respond in a flexible way to varying levels of disease transmission and be prepared to refine their business response plans as needed.

Businesses are strongly encouraged to coordinate with state and local health officials so timely and accurate information can guide appropriate responses. Local conditions will influence the decisions that public health officials make regarding community-level strategies.

While some title and settlement companies are taking a wait-and-see approach to see how their authorities will handle various phases of reopening the country, other companies are developing work-from-home plans. Meanwhile, others plan to implement a hybrid approach with employees returning to the office and others working remotely.

The CDC recommends identifying a workplace coordinator who will be responsible for COVID-19 issues and their impact at the workplace. The Occupational Safety and Health Administration (OSHA) issued COVID-19 guidance focused on the need for employers to implement engineering, administrative, and work practice controls and personal protective equipment (PPE), as well as considerations for doing so. The guide is meant for planning purposes and is not a standard or regulation.

Develop an Infectious Disease Preparedness and Response Plan

An infectious disease preparedness and response plan that can help guide protective actions against COVID-19. Employers should stay abreast of guidance from health agencies and consider how to incorporate those recommendations and resources into workplace-specific plans.

Plans should consider and address the level(s) of risk associated with various worksites and job tasks workers perform at those sites. Such considerations may include:

  • Where, how, and to what sources ofCOVD-19 might workers be exposed, including:
    • The general public, customers and coworkers
    • Sick individuals or those at particularly high risk of infection (e.g., international travelers who have visited locations with widespread sustained (ongoing) COVID-19 transmission, healthcare workers who have had unprotected exposures to people known to have or suspected of having, COVID-19).
  • Non-occupational risk factors at home and in community settings
  • Workers’ individual risk factors (e.g., older age; presence of chronic medical conditions, including immunocompromising conditions; pregnancy).
  • Controls necessary to address those risks.

Implement Basic Infection Prevention Measures

For most employers, protecting workers will depend on emphasizing basic infection prevention measures. As appropriate, all employers should implement good hygiene and infection control practices, including:

  • Promote frequent and thorough hand washing, including by providing workers, customers, and worksite visitors with a place to wash their hands. If soap and running water are not immediately available, provide alcohol-based hand rubs containing at least 60% alcohol.
  • Encourage workers to stay home if sick.
  • Encourage respiratory etiquette, including covering coughs and sneezes.
  • Provide customers and the public with tissues and trash receptacles.
  • Employers should explore whether they can establish policies and practices, such as flexible worksites (e.g., telecommuting) and flexible work hours (e.g., staggered shifts), to increase the physical distance among employees and between employees and others if state and local health authorities recommend the use of social distancing strategies.
  • Discourage workers from using other workers’ phones, desks, offices, or other work tools and equipment, when possible.
  • Maintain regular housekeeping practices, including routine cleaning and disinfecting of surfaces, equipment and other elements of the work environment. When choosing cleaning chemicals, employers should consult information on Environmental Protection Agency (EPA)-approved disinfectant labels with claims against emerging viral pathogens. Products with EPA-approved emerging viral pathogens claims are expected to be effective against SARS-CoV-2 based on data for harder to kill viruses. Follow the manufacturer’s instructions for use of all cleaning and disinfection products (e.g., concentration, application method and contact time, PPE).

Develop Policies and Procedures for Prompt Identification and Isolation of Sick People, if Appropriate

  • Prompt identification and isolation of potentially infectious individuals is a critical step in protecting workers, customers, visitors, and others at a worksite.
  • Employers should inform and encourage employees to self-monitor for signs and symptoms of COVID-19 if they suspect possible exposure.
  • Employers should develop policies and procedures for employees to report when they are sick or experiencing symptoms of COVID-19.
  • Where appropriate, employers should develop policies and procedures for immediately isolating people who have signs and/or symptoms of COVID-19, and train workers to implement them. Move potentially infectious people to a location away from workers, customers, and other visitors.
  • Although most worksites do not have specific isolation rooms, designated areas with closable doors may serve as isolation rooms until potentially sick people can be removed from the worksite.
  • Take steps to limit spread of the respiratory secretions of a person who may have COVID-19. Provide a face mask, if feasible and available, and ask the person to wear it, if tolerated. Note: A face mask (also called a surgical mask, procedure mask, or other similar terms) on a patient or other sick person should not be confused with PPE for a worker; the mask acts to contain potentially infectious respiratory secretions at the source (i.e., the person’s nose and mouth).
  • If possible, isolate people suspected of having COVID-19 separately from those with confirmed cases of the virus to prevent further transmission—particularly in worksites where medical screening, triage, or healthcare activities occur, using either permanent (e.g., wall/different room) or temporary barrier (e.g., plastic sheeting).
  • Restrict the number of personnel entering isolation areas.
  • Protect workers in close contact with (i.e., within six feet of) a sick person or who have prolonged/repeated contact with such persons by using additional engineering and administrative controls, safe work practices and PPE.
  • Workers whose activities involve close or prolonged/ repeated contact with sick people are addressed further in later sections covering workplaces classified at medium and very high or high exposure risk.

Develop, Implement, and Communicate about Workplace Flexibilities and Protections

  • Actively encourage sick employees to stay home.
  • Ensure that sick leave policies are flexible and consistent with public health guidance and that employees are aware of these policies.
  • Talk with companies that provide your business with contract or temporary employees about the importance of sick employees staying home and encourage them to develop non-punitive leave policies.
  • Do not require a healthcare provider’s note for employees who are sick with acute respiratory illness to validate their illness or to return to work, as healthcare provider offices and medical facilities may be extremely busy and not able to provide such documentation in a timely way.
  • Maintain flexible policies that permit employees to stay home to care for a sick family member. Employers should be aware that more employees may need to stay at home to care for sick children or other sick family members than is usual.
  • Recognize that workers with ill family members may need to stay home to care for them. See CDC’s Interim Guidance for Preventing the Spread of COVID-19 in Homes and Residential Communities: www.cdc.gov/coronavirus/2019-ncov/hcp/guidance-prevent-spread.html.
  • Be aware of workers’ concerns about pay, leave, safety, health and other issues that may arise during infectious disease outbreaks. Provide adequate, usable and appropriate training, education and informational material about business-essential job functions and worker health and safety, including proper hygiene practices and the use of any workplace controls (including PPE). Informed workers who feel safe at work are less likely to be unnecessarily absent.
  • Work with insurance companies (e.g., those providing employee health benefits) and state and local health agencies to provide information to workers and customers about medical care in the event of a COVID-19 outbreak.

Implement Workplace Controls

  • Engineering controls: In workplaces where they are appropriate, these types of controls reduce exposure to hazards without relying on worker behavior and can be the most cost-effective solution to implement. Engineering controls forCOVID-19 include:
    • Installing high-efficiency air filters.
    • Increasing ventilation rates in the work environment.
    • Installing physical barriers, such as clear plastic sneeze guards.
  • Administrative controls: These require action by the worker or employer. Typically, administrative controls are changes in work policy or procedures to reduce or minimize exposure to a hazard. Examples of administrative controls include:
    • Encouraging sick workers to stay at home.
    • Minimizing contact among workers, clients and customers by replacing face-to-face meetings with virtual communications and implementing telework if feasible.
    • Establishing alternating days or extra shifts that reduce the total number of employees in a facility at a given time, allowing them to maintain distance from one another while maintaining a full onsite work week.
    • Discontinuing nonessential travel to locations with ongoing COVID-19 outbreaks. Regularly check CDC travel warning levels at: cdc.gov/coronavirus/2019-ncov/travelers.
    • Developing emergency communications plans, including a forum for answering workers’ concerns and internet-based communications, if feasible.
    • Providing workers with up-to-date education and training on COVID-19 risk factors and protective behaviors (e.g., cough etiquette and care of PPE).
    • Training workers who need to use protecting clothing and equipment how to put it on, use/wear it, and take it off correctly, including in the context of their current and potential duties. Training material should be easy to understand and available in the appropriate language and literacy level for all workers.
  • Safe work practices: These administrative controls include procedures for safe and proper work used to reduce the duration, frequency or intensity of exposure to a hazard. Examples of safe work practices for COVID-19 include:
  • Providing resources and a work environment that promotes personal hygiene. For example, provide tissues, no-touch trash cans, hand soap, alcohol-based hand rubs containing at least 60 percent alcohol, disinfectants and disposable towels for workers to clean their work surfaces.
  • Requiring regular hand washing or using of alcohol-based hand rubs. Workers should always wash hands when they are visibly soiled and after removing any PPE.
  • Post handwashing signs in restrooms.


Contact ALTA at 202-296-3671 or [email protected].