FEBRUARY 2021 | WHITEPAPER

WORKFORCE &
FACILITIES
SAFETY
PLANNING FOR
COVID-19
A Guide to Health Questionnaires and
Screenings, Vaccinations & Other Safety
Considerations
 What’s
Inside

Key Components of a COVID

01
Safety Plan

02 Key Applicable Regulations

Temperature Screening
03
Considerations

04 Vaccination Tracking

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Whether your business is already open or planning to re-
open in the near future; the safety of your workforce and
facilities must be top of mind.

Business leaders have been faced with difficult decisions

when it comes to choosing to close their doors or stay open
amid the COVID-19 pandemic. However, there are still
lingering questions that business leaders are faced with:
• Are we allowed to open?
• Just because we can, does it mean we should open?
• Can we keep COVID-19 out?
• What happens if COVID-19 gets in?
• How do we protect our employees who have health
conditions which makes them susceptible to COVID-19?
• Should we track vaccinations?
Key Components of a COVID Safety Plan

While the original phase started with a business ”reopening” or ”returning to work,” the
new phase in a post-COVID workplace are the ”safety plans” on keeping the workforce
safe.

After weeks and months of trial and error, what have we learned from businesses that
have had to stay open? A strong COVID safety plan has three essential components which
are meant to achieve these three primary goals:

Keep COVID out of the workplace

Appropriate health screenings, including self-screening
conducted from home, and/or formal screening
conducted upon arrival to the workplace.

Limit the spread of COVID in the workplace

Utilize occupancy limits, continue social distancing,
proper cleaning and sanitizing, ensure masks are always
worn in the facility, personal hygiene, and similar safety
measures.

React appropriately when a customer or employee

has symptoms of COVID or a positive test
It is paramount that the proper leadership is notified of
COVID symptoms or positive tests results. Contract
tracing may be required to inform those with whom the
infected person was in contact.

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Key Components of a COVID Safety Plan

Your safety plan is only as strong as its corresponding training. All employees should be
trained and receive ongoing training to ensure customers and employees are at minimal
risk of contracting COVID-19.

As you start developing your safety plan, keep optional guidelines top of mind. Failure to
follow optional guidelines such as those provided by the Center for Disease Control and
Prevention (CDC) can create multiple layers of issues for a business.

Incorporate the following guidelines into your safety plan:

Company COVID-19 task force

All employees should be trained on the safety plan and receive ongoing
training and supervision as the plan evolves

Signed agreement for employees to comply with safety policies and

confirm full understanding

Customers should also be “trained,” which means that they should be

informed of the expectations for their behavior

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Key Applicable Regulations

Simplifying your safety planning process is key. A practical matter when drafting your
COVID-19 safety plan, is to start with state guidelines as your foundation.

Although, there are digital safety acts that do not exempt health data collection
associated with the health screening process.

It is paramount that you revisit your plan as guidelines evolve to ensure you are operating
within the most up to date applicable regulations.

Regulations to Consider:
ü Americans with Disabilities Act (ADA)
ü Equal Employment Opportunity Commission (EEOC)
ü Health Information Portability and Accountability Act
(HIPAA)
ü The Occupational Safety and Health Administration
(OSHA)
ü The FTC Act and California Consumer Privacy Act (CCPA)
ü Illinois’ Biometric Information Privacy Act (BIPA)
ü New York’s Stop Hack and Improve Electronic Data
Security Act (SHIELD Act)
ü State Data Breach Laws
ü General Data Protection Regulation (GDPR)
ü State and local laws, regulations, and executive orders
for reopening plans
ü US Centers for Disease Control (CDC)
ü Environmental Protection Agency (EPA)
ü Families First Coronavirus Response Act (FFCRA)

Best practice is to find a set of guidelines

and stick to them. Depending on your
industry, facility set-up, employee count, and
a number of other circumstances, you may
need to adhere to different guidelines as
compared to other companies.
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Temperature Screening Considerations – Manual Screening

Achieving the much-needed balance between maintaining the health privacy and
confidentiality of employee and consumer data, while ensuring the safety within the facility
is a critical consideration. Temperature screening has been found to be an effective defense
against stopping the spread of COVID-19. Deciding on how you will do this will require
several considerations while health data handling top-of-mind.

Considering the following will help drive the answer to how you plan to
temperature/health screen:

ü Staffing requirements – Will you hire clinicians to screen employees for elevated
temperature?
ü Training and supervisory overhead – How much of a time commitment will this be and
who will be responsible for the training?
ü Temperature and questionnaire answers recorded on paper – Ensure data is protected
throughout the day and safely conveyed to Human Resources or your COVID-19 task
force and disposed properly
ü Technical equipment used for screening (tablets, laptop, etc.,) and consider guidance on
sanitizing
ü Manual screening may be slower than automated screening – May lead to congregating
employees/guests in tight locations
ü More space and facility adjustments may be required

• Location set-up
• Notice to individuals
• Internal policy
Temperature • Results log
Screening • A reasonable plan for action for individuals with
fever and for refusal to participate
Considerations • Communication systems for self-reporting illness
& cooperation notifications
• Hotline for anonymous concerns or complaints

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Temperature Screening Considerations – Automated Screening

A technical/automated approach to temperature checks and screening can be very effective

in ensuring the security of user data, as well as corporate compliance with privacy
regulations such as the CCPA and GDPR.

Leveraging technology to capture temperature data, kiosks or wall-mounted terminals can

be configured to use employee ID or badge to pseudo anonymize the information. This
information should be encrypted in transit so all data can be stored in the company’s HR
system on a secure cloud environment.

Technical/Automated Screening Considerations:

ü Security/control of collected data

ü Streamlined workflows – automatically route results to appropriate departments and/or
stakeholders
ü Vendor selection risk – source from reputable vendors, fulsome vetting and vendor risk
assessments
ü Automatically update to state, federal and international guidelines
ü Faster screening times
ü Integrations with HR and access control

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Vaccination Guidelines & Tracking

As COVID-19 technology and vaccines quickly evolve, its paramount to keep these changes
top of mind in your COVID-19 safety plans. According to the Occupational Safety and Health
Administration (OSHA), it requires that employers provide each of their employees with a place
of employment that is free from recognized hazards.

This requirement could give rise to vaccination requirements in the

workplace. As with collecting temperature data, tracking an
employee’s vaccination status is data that must be protected as well.

Regarding vaccination mandates, the Equal Employment Opportunity

Commission (EEOC) issued guidance in December 2020 stating,
“Employers can generally require that employees receive the COVID-
19 vaccine to enter their workplaces but may need to provide
reasonable accommodations for individuals with medical conditions
or religious beliefs that preclude them from being vaccinated.”

Additionally, other state occupational safety and health agencies

could require vaccinations in the future. The best practice is to stay
privy to these updates and requirements to keep policies and
procedures up-to-date to ensure a safe working environment.

In creating a policy for tracking vaccinations:

ü Create a clear and written policy
ü Distribute the policy to all employees
ü Explain the reason you are tracking vaccinations
ü Provide a clear contact point for questions about the policy

• Notice to individuals
• Internal policy
• Results log
Vaccination • A reasonable plan of action for individuals with
Tracking with vaccination exemptions
• Communication systems for tracking an
Considerations employee’s vaccination status
• Hotline for anonymous concerns or complaints

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Health-Check Management powered by Truyo

Stopping the spread of COVID-19 in the workplace should be the top priority for HR,
Operations, and the Executive team at companies with in-person employees. This can be a
complicated and confusing endeavor and should be met with careful planning and execution.

Health-Check Management powered by Truyo offers an intelligent platform designed for you
to receive real-time insights into the health and wellness of your employees.

ü Set-up simple or in-depth questionnaires pertaining to the physical and mental health of
your employees
ü Stay ahead of health trends within your organization and quickly address them if needed
ü Build intelligent reports based on health data analytics
ü Easily integrate with existing HR systems and employee wellness applications
ü Receive vaccination status and COVID-19 test result data from your employees

Customizable Options

No matter how your workforce model is setup: work-from

home, in-office/facility, or a combination of both, it’s
important to understand health-related information
as you make important operational decisions and
create your COVID-19 safety plan.

Learn more:
healthcheckmanagement.com

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THANK YOU!
For more information:
healthcheckmanagement.com