Key Considerations for Your COVID-19 Safety Plan: FACS Update #2


The COVID-19 pandemic is in full swing, and even with the current emergency public health measures to reduce the spread of the virus, it is expected to be of concern for an extended period of time. Organizations must prepare for the near-term impacts, but also for a “new normal” of how to include protecting their people and stakeholders while continuing to conduct business with this threat.

The environmental health and medical experts at FACS and Cogency have been continuously reviewing the latest data and providing guidance to clients as they develop infection prevention plans to address immediate challenges and to prepare for various scenarios that could play out in the coming weeks and months. What follows are some key considerations and issues that emerge when developing and implementing an infection prevention plan for COVID-19.

  1. Your Team. Representation on the team, either directly or through outside partners, is recommended to address health & safety, medical, risk assessment and management, legal, human resources and operational issues. Coordination between the infection prevention team and the team managing business continuity is also recommended, as the issues are intertwined.
  1. Information Management. There has been conflicting information about COVID-19 in the news media, social media, public health entities, and scientific sources. The team will need to sort through the noise to keep abreast of what is real and what may be misleading. This is not only for the benefit of the team to support informed decision-making, but also to know what stakeholders may be hearing and feel concern about. Primary information sources include the established public health infrastructure: World Health Organization (WHO), U.S. Centers for Disease Control (CDC), state and local (e.g., county) public health departments, as well as federal and state OSHA.
  1. Tiered Action Plan. Making the plan dynamic, with the ability to ratchet controls up or down depending on circumstances on the ground (e.g., general prevention, community spread, emergency orders, incident response for on-site case or case exposure).
  1. Work Modification. Evaluate if and how work operations must be modified to control exposures (e.g., social distancing, working from home, process changes, task prioritization, engineered exposure controls, use of protective equipment, halting non-essential activities).
  1. Cleaning/Disinfection. Follow written protocols addressing best practices including what to clean, where to clean, when to clean, how to clean, who cleans, what products to use, and what protective equipment to wear. Reinforce protocols with employee training, as well as monitoring and documentation of cleaning efforts. Consider the availability of supplies and equipment in the face of increased demand.
  1. Personal Hygiene & Protection. Follow written protocols addressing how and when to clean under different circumstances, along with common do’s and don’ts. Use and maintain personal protective equipment per manufacturers recommendations. Continually educate to create habits of new behaviors (e.g., hand washing, social distancing).
  1. Case/Incident Response. Assess situations where a known case exists or people have been exposed (e.g., where did they go, what did they do, who did they interact with). Then prepare a site-specific response action plan addressing cleaning/disinfection as well as risk communication and medical screening/monitoring of impacted persons.
  1. Medical Screening. Identify and evaluate risk factors associated with the spread of disease and determine if medical screening is needed or necessary. Evaluate regulatory requirements, credentials, training and safety considerations for persons conducting the screening or collecting and reviewing the medical information. Consider legal implications of documenting any medical data. Incorporate review of screening programs by medical professionals.
  1. Extended Building Closure. Potential negative environmental health impacts associated with opening buildings that have been shut down for an extended time (e.g., water quality, ventilation, moisture/mold concerns, food and chemical expirations) should be considered and addressed as needed.
  1. Training, Education, & Risk Communication. Consider providing training to support implementation of infection prevention plans and to manage employee and stakeholder concerns. Hold recurrent townhall Q&A meetings. Ensure those communicating are able to respond to misleading or false information. Provide education regarding personal infection control practices, as poor practices at home can lead to impacts to other people and organizations.

We hope these considerations can help you and your organization put in place a plan to support the safety of your people and stakeholders during this challenging time. We will continue to provide updates with information and experiences we feel may help. Please contact us if you have any questions or if our experts can be of assistance in managing your response.


Ben Kollmeyer, MPH, CIH                             Hung Cheung, MD, MPH, FACOEM
Chief Science Officer                                      President, Cogency Medical