COVID-19 Safety Plan
The Re-Opening Ontario Act, 2020 requires that the following workplaces have a safety plan if they are located in communities in the Protect (yellow), Restrict (orange) or Control (red) zone:
- Restaurants, bars, and food or drink establishments
- Sports and recreational fitness facilities
- Meeting and event spaces
- Shopping malls
- Personal care services
- Casinos, bingo halls, and other gaming establishments
- Performing arts facilities
All businesses that are open during Lockdown (grey) zone are required to have a safety plan. Fines can result from not having a safety plan prepared, posted and available for inspectors to view.
In addition, Instructions issued by Hamilton’s Medical Officer of Health require all retail and workplaces located in the City of Hamilton to have a safety plan during the Control (red) zone.
Elements of safety plans
Active screening involves making sure every employee and customer is asked a series of questions about COVID-19 symptoms, travel or exposure to COVID-19 cases. If someone has one or more COVID-19 symptoms or exposure to a COVID-19 case, they should not be permitted to work (if an employee) or come into your business (if a customer, supplier or contractor). A number of workplace outbreaks in Hamilton have been the result of employees with mild symptoms continuing to work.
Infection prevention and control (IPAC) measures
Steps to prevent the spread of COVID-19 infections include wearing masks, physical distancing, hand hygiene and respiratory etiquette – coughing or sneezing into tissues or your sleeve. These steps are important because active screening will not identify:
- individuals with asymptomatic COVID-19 infections, i.e. people who are infectious but who have no symptoms of infection
- individuals with pre-symptomatic COVID-19 infections, i.e. people who are infectious for two or three days before they develop COVID-19 symptoms
Cleaning and Disinfection
The most likely route of COVID-19 transmission is from person-to-person spread of infected respiratory droplets when people are close together, but contaminated surfaces may also spread the virus. Therefore, frequent cleaning and disinfecting commonly touched surfaces with an approved disinfectant is an important infection control measure.
Developing a safety plan
It is possible that someone in your workplace will contract COVID-19. Hamilton Public Health Services (HPHS) can support you and provide resources to help respond to such a situation.
Resources required to develop a safety plan are provided by the Ministry of Health. Six questions in the safety plan are outlined below to help with development of your plan:
- How will you ensure all workers know how and are able to keep themselves safe from exposure to COVID-19?
- How will you screen for COVID-19?
- How will you control the risk of transmission in your workplace?
- What will you do if there is a potential case of, or suspected exposure to, COVID-19 at your workplace?
- How will you manage any new risks caused by changes to the way you operate your business?
- How will you make sure your plan is working?
Keeping employees safe from exposure
|Factors to consider for keeping employees and customers safe from exposure||Action|
|Screening: active screening is mandatory for all workplaces||
Screen all individuals daily prior to entering workplace using one of the tools below:
|Employee education: training on procedures||
Educate employees on what to if they feel unsafe at work and support available:
|Workplace policies||Develop policies to support employees to stay home when unwell or if they are required to self-isolate due to COVID infection or as a close contact. Ensure employees are aware of policies and have access to them.|
|Know the law: sector-specific requirements, regulations and by-laws|
|Mental health supports||Remind employees about mental health supports|
Communicate clearly and often with employees, including:
Screening for COVID-19
Screen all individuals (workers, volunteers, suppliers and contractors) daily prior to entering the workplace. Screening may be done in-person, online or verbally.
- Ministry of Health online COVID-19 self-assessment tool
- City of Hamilton screening tool
- Ministry of Health screening tool for workplaces
- Your own tool (note: it must contain all of the questions from the Ministry screening tool for workplaces, current edition).
Workplaces must be able to demonstrate that they have implemented a screening system and that it is working as intended. An inspector will need to be able to determine compliance with the law. Workplaces can consider various ways of demonstrating that they are compliant with the screening requirements, including keeping a record of individuals who were screened.
Organizations and businesses required to screen patrons must use or ask questions similar to those found in Hamilton’s COVID-19 screening tool. Customers who do not pass screening should be advised that they cannot enter and advised to self-isolate and get tested. Records of screening do not need to be maintained.
To support safe screening:
- points of entry into the business/organization should be limited
- the use and layout of space should allow for 2 metres to be maintained during screening
- a physical barrier or appropriate personal protective equipment should be used if physical distancing cannot be maintained
- Encourage customers to use alcohol-based hand rub/sanitizer before entering the premise
In addition to active screening a sign should be posted at the entrance reminding employees, clients or customers not to enter the workplace if they have COVID-19 symptoms. For retail establishments with only one employee who are unable to actively screen, the COVID-19 screening tool must be posted on the entrance of the establishment.
Temperature checks are neither required nor recommended.
In your safety plan, you should also include:
- Where and how is the screening tool accessed and completed?
- If online, where is it sent? Who verifies that it has been completed and that the employee is safe to enter the workplace?
- If it is paper-based, where is it completed? Who reviews it and authorizes entrance to the workplace? Where and how are these results stored?
- If active screening is completed with verbal questions, where and who completes this? Where and how is the information stored?
Example of sample response for safety plan for screening: All individuals entering the workplace will be screened daily. The workplace will create an online template with the same questions from the Screening Tool for Workplaces. Our Human Resources department is responsible for checking that the questions on our platform continue to match those from the Screening Tool for Workplaces every week. Employees will be required to complete daily screening before attending work. An email will automatically be sent to a supervisor with screening results (and if screening has not been completed) to determine work suitability. The supervisor is responsible for ensuring that no member of their team enters the workplace unscreened. Employees also sign an attestation form that they will complete daily self-screening and will follow the results of the screening tool as a condition of their continued employment at our company. Results are stored in a password protected database.
Example of sample response for safety plan for screening: Our door remains locked with a sign that informs employees and customers to text reception or use the buzzer on the left-hand side of the door when they arrive. Employees and customers will be screened verbally prior to entering the workplace by (enter name of job title/individual responsible for screening) using the provincial list of COVID-19 symptoms. Our front door also displays a poster reminding individuals not feeling well not to enter. Results will be documented by the person screening on the same paper where contact tracing information is kept. This information will be stored securely for 30 days in a locked filing cabinet after which time it will be shredded. Individuals who fail the screening will not be permitted in the workplace.
Controlling the risk of COVID-19 transmission in the workplace
Physical distancing and barriers
All individuals should have 2 metres (6 feet) between themselves and others.
When it is not possible to have employees physically distant from co-workers, customers and others, consider using barriers for separation.
To lower the risk of COVID-19 spread in the workplace:
- Offer telecommuting or work from home options for employees.
- Develop options for clients to interact with employees where it is not crowded or use online options.
- Restrict the number of individuals allowed into the workplace to allow for physical distancing and adequate flow of movement.
- Reduce the number of individuals in elevators and stairwells at any given time.
- Rearrange furniture to ensure that employees are spaced far enough apart.
- Stagger start and end times and schedule different break times to reduce people gathering together at the same time.
- Promote contactless payment and delivery/pick-up options.
- Develop policies that restrict the amount of time individuals can remain in a particular space (e.g., retail customers are asked to limit the amount of time that they browse to x minutes)
PPE & source control masking
- Ensure clients, customers and visitors are reminded of the requirement to wear a face covering in enclosed public places.
- Post face-covering requirements in a visible spot within the establishment.
- Follow PPE requirements as per sector-specific guidance and the Re-opening Ontario Act, 2020 for your establishment.
- Display posters promoting hygiene practices, handwashing and respiratory etiquette strategically in the workplace.
- Where soap and water are not available, supply hand sanitizer and remind customers and staff to wash/sanitize hands frequently.
- Regularly clean and disinfect high-touch surfaces such as point of sale transaction equipment, elevator buttons, keyboards, mouse, phones, desks, computers, door knobs, light switches, seating areas, lunch tables, kitchens, and washrooms.
- Use cleaners and disinfectants that are effective against COVID-19. Use brands with a Drug Identification Number (DIN) that are approved by Health Canada.
- Enclosed and crowded spaces increase the risk of COVID-19 transmission. Ensure that air-handling (HVAC) systems are maintained according to the manufacturer’s instructions and meet industry guidelines and standards.
- The Ontario Ministry also recommends considering:
- Portable air cleaners
- Opening windows and doors where possible
- Ventilation and air exchange after regular business hours
- Use of outdoor space when possible for meetings, breaks, and client interactions such as curbside pick-up
Management of a potential case or exposure
- Take the following steps for managing a potential case or exposure of COVID-19 in the workplace:
- Direct individual feeling unwell to stay home or go home, self-isolate and book an appointment to get tested for COVDI-19
- If the workplace has a designated isolation area, ask the individual to use this space if they are waiting to be picked up. Ideally the isolation area should have a door and provide a safe space for someone to wait without exposing others.
- Clean and disinfect areas where the individual with COVID-19 symptoms was located and any surfaces they may have touched as soon as possible. Follow public health advice for enhanced cleaning and disinfection measures to reduce the risk of spread in the setting.
- Call Hamilton Public Health Services at (905) 974-9848, option 4 for further guidance/advice as required.
If there has been a confirmed case of COVID-19 in the workplace
- Call Hamilton Public Health Services at (905) 974-9848 for direction and support.
- Employees in close contact (less than 2 metres away from another individual, especially for a prolonged period of time) with the case, have had potential exposure and will need to self-isolate.
- Keep a list of names and contact information for each person in your workplace who had or may have had contact with the individual who tested positive. This list should be available if requested by public health. You must keep this information for at least 30 days. Store it privately and securely (e.g., in a locked cabinet or password protected database) before destroying in a safe manner, e.g. shredding.
- Communicate clearly and often with your other employees while keeping the personal health information of the employee with COVID-19 confidential. In a small workplace, others may know who this employee is, however as an employer you must do everything you can to safeguard the personal health information of your employees. A sample communication can be found online (under “Common questions about COVID-19 exposure and outbreaks”).
- Report to the Ministry of Labour, Training and Skills Development within 4 calendar days and Workplace Safety and Insurance Board (WSIB) within 3 calendar days if you were advised that one of your employees has tested positive due to an exposure at the workplace. For more information contact the Ministry of Labour, Training and Skills Development: Employment Standards Information Centre at 1-800-531-5551 or the Workplace Safety and Insurance Board at (416)344-1000 or 1-800-387-0750.
- Employees can return to work 10 days after the start of their symptoms or, if they didn’t have symptoms, since the date of their test, as long as they no longer have fever and symptoms are improving or resolved. Other employees who were close contacts (regardless if they test positive or negative for COVID-19) may only return to work after the 14 day self-isolation period. You should not require a repeat test or physician note as a condition of return.
Managing new business risks from COVID-19
Each workplace will need to determine risks and challenges that may arise as a result of COVID-19. Examples of some common risks are below.
|Common risk examples||Risk mitigation strategy examples|
|Increased employee absences as a result of COVID-19 infection, self-isolate requirements or to care for others in their family who have COVID-19.||
|Employee supports for stress and job transitions||
Financial strain due the pandemic and ability to supply necessary PPE and personnel needed for increased safety requirements.
|Working remotely: ergonomics and internet connectivity||
Management of a potential case or exposure
|Document to review||Frequency of review||By whom|
|Operations (day-to-day management of establishment)|
|Communications to employees & patrons|
|Contact tracing process / record of patrons including data storage and destruction|
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