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In last week’s blog found here, we summarized the key takeaways from Virginia’s Temporary Emergency Standard effective July 27, 2020. The standard requires Virginia employers with employees with “very high,” “high,” and “medium” (with at least 11 employees) exposure risk to COVID-19, to develop and implement a written Infectious Disease Preparedness and Response Plan by September 27, 2020. With that deadline quickly approaching, we have summarized the standard’s requirements for Virginia employers when developing their Infectious Disease Preparedness Plan.

The plan must:

  1. Identify the name(s) or title(s) of those responsible for administering the plan. The person must be involved in plan design and implementation and knowledgeable in infection control principles and practices as they apply to the employer’s covered facility, service or operation.
  2. Address the level(s) of COVID-19 disease risk associated with the employer’s various worksites and job tasks performed at those sites. The risk assessment must take into account such factors as employee contact with people known or suspected to be infected with COVID-19 (like those who’ve travelled to places with known high levels of COVID-19 cases or healthcare workers) and employees’ individual risk factors (to the extent permissible by laws such as HIPPA). The plan must address, “Engineering, administrative, work practice, and personal protective equipment controls necessary to address those risks.” Also required are contingency plans for situations that may arise out of a disease outbreak such as increased employee absenteeism, the need for PPE and how to conduct business operations with a significantly reduced staff.
  3. Identify basic infection prevention measures implemented in the workplace. Some include frequent and thorough handwashing, routine cleaning and disinfecting of surfaces and equipment and establishing procedures for educating and protecting visitors to the workplace.
  4. Include procedures for identifying and isolating employees with known or suspected cases of COVID-19. Isolation must be away from workplace. Procedures must also be established for employees to report when they are experiencing symptoms of COVID-19.
  5. Address how infectious disease preparedness and response is handled with those outside the business who may enter the workplace such as clients and vendors.
  6. Identify the “mandatory and non-mandatory recommendations in any CDC guidelines or Commonwealth of Virginia guidance documents with which the employer is complying in lieu of the standard.” Importantly, employers that comply with CDC guidelines to reduce the risk of COVID-19 in the workplace that are equivalent or greater to those in the standard will be considered in compliance with the standard.
  7. Ensure compliance with all mandated requirements in any Virginia executive order related to the pandemic.

Takeaway For Virginia Employers

It will be challenging for employers to have the mandated Infectious Disease Preparedness Plan in place by September 27th given the level of detail required of the plan. Smart HR has partnered with an employment law firm to provide Smart HR clients access to a toolkit via an online portal for a small fee to assist them with putting the plan in place. If you are interested in obtaining the toolkit, please call us on 703.952.3177 or complete the contact us form found here www.smarthrinc.com/contact/.