After the Pandemic
Planning for a Better “Normal”
BY DANA STAHL
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For most of the past year, occupational and environmental health and safety professionals have been engrossed in reducing transmission of COVID-19 and implementing effective controls—challenges exacerbated by woefully insufficient supplies of personal protective equipment. The rollout of vaccines, if all goes well, will bring an end to the pandemic, but even if vaccines do not eradicate COVID-19, new treatments and pharmaceutical interventions will be developed to treat the disease. Just as a diagnosis of HIV infection has evolved since the 1980s from a death sentence to a treatable chronic condition, future treatments could render COVID-19 less infectious and deadly.
At some point, then, pandemic operations will demobilize. This article reviews guidance for emergency response planning to identify lessons that will help OEHS professionals lead their workplaces to a new, post-pandemic “normal.” For deeper discussions of emergency response planning, read the articles “The Number One Response Priority” and “The Road to Reconstitution.”
CONTINUITY PLANNING Workplaces that were not directly involved in the frontline response to COVID-19 have been operating under “continuity operations.” The phases of continuity operations are readiness and preparedness, activation, operations, and reconstitution. For each phase, organizations build continuity processes and procedures, establish goals and objectives, support the performance of essential functions, and define the steps or corrective actions that will demonstrate when normal operations may resume.
Demobilization is part of the reconstitution phase, and it must be planned. Ideally, planning for demobilization happens during the response phase of any incident, including a pandemic, after initial response efforts stabilize.
DEMOBILIZATION IN AN INCIDENT RESPONSE The U.S. Federal Emergency Management Agency’s National Incident Management System (NIMS) identifies emergency response responsibilities for all stakeholders including federal, state, and local governments; nongovernmental organizations; and private companies. NIMS provides a common language for emergency response processes and explains how personnel from different stakeholders can work together during incidents. (See the article later in this issue for a more thorough discussion of NIMS.)
In NIMS, the position of Demobilization Unit Leader is responsible for demobilization planning and implementation. The Demobilization Unit Leader begins work long before the incident response ends.
As documented on FEMA’s form ICS-221, the demobilization plan identifies resources used during the incident response and when these resources can be released. The Safety Officer—another position identified in NIMS—should review the plan and inform the Demobilization Unit Leader of any related safety issues. For example, since healthcare workers have been front and center in the COVID-19 pandemic response, they may need post-pandemic medical support (for physical and mental health, for example). Planning for such considerations needs to be part of the demobilization process.
CONTINUITY OPERATIONS FEMA recommends that workplaces develop a reconstitution plan to manage the transition from continuity operations back to normal operations. The reconstitution plan should operate as a companion or annex to an organization’s continuity plan.
When developing a continuity plan, an organization must clearly identify its operating mission, the business practices and tasks that directly support the mission, and the people who execute these tasks through performance of “essential functions.” As defined in FEMA’s Continuity Guidance Circular (PDF), FEMA identifies safety-related personnel not as essential functions but as “essential supporting activities” because they provide the support needed for essential functions to take place. Essential supporting activities are critical to operations; for example, workers who are needed for essential functions will not work if they are injured on the job or believe the safety and health risks are unacceptable. Payroll is another example of an essential supporting activity since workers will not perform essential functions if they can’t get paid.
“Important functions” are tasks that are not identified as essential functions or essential supporting activities. They are important to the long-term success of the organization, but they can be delayed during a crisis. Workers who perform important functions may be deployed to support essential functions or essential supporting activities during continuity operations—tasks for which these workers haven’t been fully trained. In the context of the COVID-19 pandemic, some workers who perform important functions may have been laid off and are no longer available to return to their old jobs once normal operations resume, which can compromise the long-term success of the organization.
Ideally, organizations developed both continuity plans and reconstitution plans prior to 2020. However, in many cases, workplaces either didn’t develop these plans or discovered that their existing plans were inadequate and needed to be revised as they were being implemented.
Opportunity still exists to develop or reevaluate reconstitution plans before the pandemic ends.
RECONSTITUTION Planning for recovery and reconstitution should start during the readiness and preparedness phase of disaster planning. The management of reconstitution planning should be assigned to a responsible individual or department. Stakeholders within the organization, including OEHS professionals, should provide input on the reconstitution plan. Expertise and coordination throughout the organization is necessary to seamlessly transfer back to normal operations.
The reconstitution plan can be activated when an incident occurs or soon after it concludes. Regardless of the timing, the logistics of reconstitution should be considered in conjunction with all continuity operations.
It may not be possible for all operations to return to normal at the same time due to a lack of personnel or an inability to obtain supplies or return to facilities. Certain work groups, such as maintenance operations or information technology, are needed to support return-to-work strategies, and restrictions on resources may limit how quickly normal operations can resume. When important functions return, they need to be integrated into operations. OEHS professionals need to participate at each step to ensure that procedures needed to bring workers back safely are followed.
Records management may have been less than optimal during continuity operations. During reconstitution, the emphasis needs to be on collecting and properly retaining the records generated during continuity operations. Records management is of particular concern to OEHS professionals who oversee records for training and medical monitoring. Other necessary records are those related to regulatory requirements for personal protective equipment, including hazard evaluation and PPE selection; respirators, including medical evaluations and fit tests; and safety data sheets.
Once continuity operations conclude and reconstitution is complete, the personnel involved should participate in a debrief to review what went well and what can be improved. An after-action report (AAR) should be prepared to formalize this review, and a corrective action plan should be developed to improve the continuity plan and prepare for future incidents.
AFTER THE PANDEMIC: WHAT TO EXPECT Although essential workers have continued to work throughout the pandemic, much work has been suspended or reduced. For many organizations, only essential functions have been performed while incorporating social distancing and other infection control methods. As conditions improve and workers return to normal practices, infection control measures may become less stringent and essential work may revert to non-emergent conditions. Due to these changes, the workplaces OEHS professionals return to will not necessarily be the same as the ones we suddenly left in March 2020. However, we can take the lessons learned from the pandemic to ensure better workplaces in the future, and OEHS professionals should be prepared to take advantage of this opportunity to promote safety improvements.
Remote Work In the U.S., the emergence of the pandemic in March 2020 forced most office workers into telework. Managers and supervisors learned that efficiencies could be maintained even when employees worked remotely. Employees learned that they could work efficiently and maintain a greater work-life balance. Traffic conditions improved and vehicle emissions were reduced. Remote work is unlikely to go away once the pandemic is over.
The workplaces OEHS professionals return to will not necessarily be the same as the ones we suddenly left in March 2020.
In the office setting, OEHS professionals can ensure that ergonomics is considered in workstation design. This is less likely to happen in a home office, and it should not be assumed that remote workstations are ergonomically benign. An OSHA directive from February 2000 indicates that the agency does not expect employers to inspect home offices, but injuries must be recorded on the employer’s OSHA 300 log and are likely to be compensable. As employees set up their home workstations, OEHS professionals should encourage good ergonomic practices through training, the development of fact sheets, and virtual consultations.
Workers who are not based in offices may find remote work beneficial as well. For example, a carpenter might work on small projects in a home-based shop. OSHA does expect employers to inspect this kind of work performed at home, especially if it involves hazardous equipment or chemicals. If an employer allows this type of work to be performed at home, OEHS professionals should expect to play a greater role in ensuring workplace safety standards are met.
Increased Importance of Health and Wellness We’ve all been told to stay home when we are sick to prevent the spread of seasonal cold and flu viruses. Nonetheless, workplace policies often send a counter-message. Attendance policies may penalize employees who use too much sick time, and absenteeism may negatively impact a performance review.
Our experience with COVID-19 teaches us that it really is important to stay home when sick. Workplaces must send a consistent message on this topic by adopting policies that support workers who take sick leave and not penalizing them for doing so. Providing sufficient paid sick leave is a necessity. OEHS professionals can advocate for workplace policies that support this message.
Of course, staffing plans must support work processes despite absenteeism when workers call in sick. Insufficient staffing results in increased workloads for those who do report to work and may encourage workers to take shortcuts and bypass safety measures. Increasing staffing levels may be difficult in the post-pandemic economic environment; employers may need to accept lower output when viral infections increase within a community. Employers must prioritize essential functions during these times.
Infection Control Throughout the pandemic, OEHS professionals have played an important role in evaluating ventilation systems, disinfection practices, and other workplace controls. Media reports and public health messages have increased public awareness of how aerosols and droplets spread, the importance of ventilation in indoor settings, and even which MERV filtration ratings are appropriate. Workers who return to buildings in the aftermath of COVID-19 will be better educated on ventilation practices. OEHS professionals should be prepared to answer questions and provide clear information as workers return.
Workplaces that remained open during the pandemic should have intensified their cleaning and disinfection practices. When the pandemic ends, and as building occupancies increase, these practices will likely need to continue if only to ease workers’ concerns. Workplaces may need to hire more janitorial and custodial staff or contract with additional service providers. Regardless, there should be an increased demand for this work, and OEHS professionals should be prepared to support new workers in this field, especially workers whose first language is not English. Training methodology may need to be adapted and classes offered in different languages to meet the needs of these workers.
Cleaning chemicals and disinfectants must be evaluated for effectiveness and safety and incorporated into hazard communication programs. The expansion of janitorial and building maintenance programs presents an opportunity to move toward safer, greener chemicals if OEHS professionals advocate for these improvements during demobilization planning.
Web-Based Meetings and Training Many of us had a crash course in web-based meetings this past year. As the pandemic marched on, our comfort level with web-based meetings increased. Now that we’ve learned that meetings can be effectively held online, the necessity of meeting in person may diminish once the pandemic ends. The resulting decrease in both long-distance travel and travel between worksites may result in greater efficiency and a further reduction in vehicle emissions.
Much of the training we perform as OEHS professionals can be moved online, which will benefit employees working across multiple locations. Training platforms on Zoom and WebEx allow two-way interaction between students and the instructor, and between employees who perform similar jobs at different locations. Travel and time efficiencies may allow for greater attendance at training sessions because they are less disruptive to work schedules.
OEHS professionals should become familiar with the tools used in web-based meeting platforms and develop their skills for conducting effective training using this media. For tips on how to conduct training online, read “Training in a Pandemic” in the February 2021 Synergist.
MAKING IT HAPPEN Our return to normal operations once the pandemic ends is an opportunity to evaluate what we can improve. Do we want our workplaces to function as they did before, or can we do better? For years we have sought increased work-life balance, wellness, better time management, and sustainability. The pandemic taught us that these goals are attainable. We should strive to build a new normal that is better than what we had before—but planning is necessary to achieve it.
Many of the positive workplace changes that resulted from adaptation to the COVID-19 pandemic will be here to stay after the pandemic is over. Efforts to ensure employee safety and health during pandemic operations are likely to have far-reaching benefits. Achieving a better normal takes planning, and workplace organizations that plan well can integrate workplace improvements into their reconstitution process in a manner that ensures long-term success. OEHS professionals who understand this process have the opportunity to realize enduring benefits to their health and safety programs.
DANA STAHL, CIH, is safety and health manager for the Seattle Public Library and the author of Health and Safety in Emergency Management and Response.
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New Framework on Continuity Planning
In January, AIHA released the latest of its Technical Frameworks, “Role of the OEHS Professional in Continuity Planning.” A Framework is a publication that defines the core knowledge and skills required by an individual for effective performance in a specific practice or expertise. The new Framework on continuity planning identifies the skills needed to perform risk assessments, analyze business processes, identify risk mitigation options, build continuity plans, and other tasks. Download the Framework from AIHA's website (PDF).
RESOURCES
AIHA: “Role of the OEHS Professional in Continuity Planning” (PDF, January 2021).
Federal Emergency Management Agency: “Continuity Guidance Circular” (PDF).
Federal Emergency Management Agency: “Demobilization Check-Out (ICS 221)” (PDF).
Federal Emergency Management Agency: “National Incident Management System.”
OSHA: OSHA Instruction, Home-Based Worksites (February 2000).
The Synergist: “The Number One Response Priority: Responsibilities for OEHS Professionals in an Incident Command System, Part 2” (June/July 2019).
The Synergist: “The Road to Reconstitution: Responsibilities for OEHS Professionals in an Incident Command System” (December 2017).
The Synergist:Training in a Pandemic: A Guide to Designing and Delivering Learning Events” (February 2021).