See the latest EHS federal and state regulatory updates due to COVID-19


Never before has the “H” in “EHS” been as important as during the 2020 COVID-19 crisis response. During the past several months, this pandemic turned our lives upside down. “Social distancing” is now part of our regular vocabulary. Businesses are challenged by the uncertainty in financial markets, concerns about future growth and sustainability, and, most importantly, the health and safety of employees. Concerns from employees, shareholders, regulators, the community, and other stakeholders regarding pandemic response efforts has caused many companies to look in a single direction - to the Environmental, Health, and Safety (EHS) manager.

EHS professionals are spearheading efforts to develop the plans, processes, and tools to meet this challenge. Although they find themselves inundated with new pandemic response responsibilities, many EHS managers are also still responsible for ensuring day-to-day compliance with EHS regulations, with a limited staff that is stretched thin.

Many EHS managers are reporting limited capacity, often finding themselves trying to “drink from a firehose,” while others are using the “downtime” to focus on their company's pandemic response. Either way, EHS is leading the charge. As we have supported clients through this time, we've observed that successful pandemic EHS efforts have two elements in common: creating a thorough pandemic response plan and adapting EHS digital solutions to pandemic management.

Pandemic Response Plans

Many companies need to promote health and safety while maintaining operations. The first element of a successful response is developing a Pandemic Response Plan (hereafter referred to as “Plan”). The purpose of the Plan is to establish the basic requirements to address health concerns caused by pandemic diseases, such as COVID-19. Associated best practices for Plan preparation are outlined below.

Important Elements of an Effective Pandemic Response Plan

  • Pandemic Response Plans should be based on current, reliable information from the U.S. Centers for Disease Control and Prevention (CDC) and Occupational Safety and Health Administration (OSHA)
  • The plan should be an evergreen document that will change based on further information provided by the CDC, OSHA, and orders issued by local authorities for infectious disease control
  • Companies should also customize their plan with site-specific health, safety, or operational information and needs

Plan in Action: Pandemic Action Teams

In addition to developing plans, many organizations are formalizing a Pandemic Action Team. This cross-functional team should manage ongoing pandemic-related risks, decisions, and implementation. The Pandemic Action Team should include a representative from each key stakeholder (e.g., customer engagement, workforce, supply chain, etc.) because the team is making decisions across the entire company.

Further, the Pandemic Action Team should be led by someone within upper management, such as the CEO or COO, to provide senior leadership and who has a thorough understanding of the business operations and the ability to approve team plans and actions. The figure above provides an example overview of the team's responsibilities.

The Pandemic Action Team should focus on the following key tasks with clearly assigned roles and responsibilities:

  1. Identify pandemic-related hazards for risk assessment and control measures to protect all workers at their workplace and business activities
  2. Define process and control measures to prevent or stop the spread of infectious disease at the workplace
  3. Communicate people-related issues for the well-being of all stakeholders
  4. Assign proper resources to implement and monitor control measures
  5. Verify the effectiveness of the control measures and update/improve the process as information evolves
  6. Review the responsibilities and areas of purview, and select a team that can fill those roles or who will know the expert to call in

Strategies for Reopening Safely

As a majority of the workforce has been ordered to stay home to slow the spread of the virus, EHS professionals are continuously monitoring CDC and OSHA guidance for new or changing recommendations. With re-opening orders defined by individual states, the Pandemic Action Team (including EHS support) should be closely monitoring reopening guidance provided by the CDC as well as state and local public health authorities.

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Many EHS professionals have expressed great concerns regarding the “new normal” of increased guidelines and regulatory requirements to reopen the workplace. The complicated reopening guidelines and regulatory requirements add a level of complexity and uncertainty to reopening workplaces to employees. To identify considerations for reopening, we suggest Pandemic Action Teams reference the CDC guidance for businesses and workplaces to guide efforts to bring staff back to the workplace while protecting vulnerable employees.

For example, the CDC Resuming Business Toolkit is designed to assist employers in slowing the spread of COVID-19 and lowering the impact in their workplace when reintegrating employees into business settings. The Toolkit includes useful materials such as: a restart readiness checklist to help make returning to work and resuming business operations as safe and healthy as possible for employers, employees, and the public; a worker protection tool for employers to identify protective measures for workers when interacting with each other and the public; and returning to work infographic to remind employees how to protect themselves and others from COVID-19 and address their potential concerns about returning to the workplace.

Digital Solutions for Pandemic Management

With many employees forced to work remotely, digital solutions have become critical for continued job performance in nearly every industry. Companies are looking to digital solutions that were once used only for simple record-keeping to now provide ongoing monitoring for established EHS compliance requirements, as well as fulfilling new requirements for pandemic control measures.

EHS managers and professionals are displaying creativity and problem-solving skills as they systematically adapt their EHS Management Information Solutions (MIS) tools to meet the velocity and volume of data management demanded by the pandemic response recommendations.

What once was designed to provide organizations with the digital tools to enable EHS business processes is now being extended and adapted to address pandemic response needs.

Unfortunately, companies without EHS software for compliance requirements face a real challenge to manage existing and new responsibilities of the EHS team. Many are finding that now is the time for a systematic evaluation of their need for the next-generation business solution.

These implemented EHS software solutions have been a lynchpin in the successful pandemic response of many companies. These tools enable critical return-to-work processes by facilitating the collection of vital response data, sharing results transparently, and communicating effectively across all organizational levels, thus giving the workforce clear insight into how the EHS managers are ensuring a safe workplace, building trust, and driving engagement across the company. Comprehensive live dashboards can provide a real-time view of what is happening across the workforce.

In response to the pandemic crisis, many commercial EHS software providers quickly adapted their traditional EHS capabilities to address key challenges such as:

  • Return to work screening
  • Exposure and infection reporting
  • Workplace sanitization inspections
  • Job hazard analysis/PPE
  • Work at home ergonomics

EHS software providers are offering some of these pandemic response solutions at reduced introductory rates, and some a free trial version. Choosing the right tool for your facility is a big decision with many factors.

Seeking experience from experts who understand your facility's needs (beyond the pandemic) as well as the technology options available is invaluable. When selecting a program, it's important to identify and implement a solution that achieves stated objectives, is deployed on time and within budget, and has a high utilization rate.

How Pandemic Response Efforts are Supported by Digital Solutions

Managing risk to allow for an orderly, safe, and efficient return to work is a priority for many organizations. Timelines for phases, regulations, requirements, and data are constantly changing, which can make these new regulations overwhelming. Nonetheless, organizations must figure a way to systemically capture, track, and report on the health status of employees, contractors, and visitors.

Digital solutions have been used to specifically support pandemic response efforts. We will examine a selection of successful examples where a robust information management system has benefitted companies during this time.

Return to Work Employee and Visitor Screening

As part of their occupational health applications, EHS software platforms already offer rapidly deployable solutions that were designed to track various on-the-job health-related issues and are easily adaptable to assist companies in the Return to Work screening process.

For data collection, electronic questionnaires can help ensure compliance with regulatory guidelines while making it easier for employees, contractors, and visitors to complete them. Based on answers received, automatic forms can be generated for review and for confirming whether a worker can be cleared to work or should be flagged for secondary review or quarantine.

These questionnaires can be submitted via a mobile app to allow for a no-contact, no-risk evaluation, and EHS managers at a facility can be alerted to potential health concerns for individuals entering the site and can ensure actions consistent with the company's Return to Work policies.

Exposure and Infection Reporting

For some organizations, tracking employee exposure and infection within the workforce can be critical to maintaining operations during a pandemic. In addition to enabling Return to Work questionnaires, EHS software applications can be configured to help enforce periodic health check assessments by automating employee responses.

As a result, high-risk employees who have come in contact with known infected people can be directed to self-isolate for a period of time, identified for more frequent monitoring, or directed to receive testing. Additionally, employees that have been in contact with infected parties or have themselves been infected can use a proactive event-reporting application to document the infection, identify other at-risk parties, and capture/track various controls.

EHS software solutions, typically extensions of Incident Management solutions, can allow companies to record a pandemic exposure event confidentially, in compliance with Health Information Patient Privacy Act (HIPPA) and General Data Protection Regulation (GDPR) requirements. While maintaining the privacy of individuals, exposures can be tracked for employees, contractors, and visitors, allowing companies to report on exposure status, quarantine, test results, and return to work dates.

For positive or potentially positive employees, companies may want to engage in contact tracing to determine who has been in contact with the employee. Utilizing EHS software can help identify potentially exposed employees based on job duties if contact tracing is not available. Based on data from HR systems, EHS applications can help organizations identify possible contacts of a positive or potentially positive employee.

Data linked to positive or potentially positive employees and the identified potentially contacted employees can help identify patterns related to the spread and transmission rates, which can be further used to control the spread of contagious viruses in the workplace. In addition, those people in contact with positive or potentially positive employees can be automatically enrolled in a monitoring program for assessment with automated questionnaires and notifications.

Workplace Sanitization Inspections

Regular inspections of workplaces, equipment, and processes are important to ensure companies are meeting safety, environmental, and regulatory obligations. Companies can utilize inspections to document workplace sanitization practices to help control the spread of a pandemic.

While the inspection process has historically been complicated, inefficient, and often documented on paper or spreadsheets, EHS software applications allow for a consistent approach to inspections across multiple sites and locations.

Electronic inspections can increase the efficiency of an organization's inspections through automation and standardization and are often available for use on a mobile device. These inspections can help organizations ensure that sanitization is being conducted consistently and quickly identify any gaps in sanitization practices.

Job Hazard Analysis/PPE

Effective job safety analysis and accident prevention depend upon good data analysis. Obtaining data from multiple sources can make timely and systematic review more difficult, especially during a pandemic where regulations and procedures may change on a daily basis.

Job Hazard Analysis (JHA) software applications allow for quality data collection and analysis, facilitate assessment of risk levels, communicate hazards and controls, and prioritize risk reduction efforts across the organization. A user can identify hazards present to individual job tasks, especially in non-routine jobs, non-routine environments, and non-routine working situations common during a pandemic. Next, a user can record the necessary controls such as procedures and PPE.

This process will help promote awareness of hazards associated with routine and non-routine job tasks and environments, ensuring that contractors and employees are always informed of the risks.

Work at Home Ergonomics

As employees are more regularly working from home, utilizing computer-use awareness tools can encourage healthier work behaviors and help prevent musculoskeletal injuries. Ergonomic applications can be installed on employee's computers to help reduce repetitive strain exposure and minimize working conditions that could lead to repetitive strain injuries by promoting stretch breaks, healthy behavior reminders, and personalized guides to safer computer use.

Ergonomic solutions can help prevent discomfort associated with computer use. Examples include suggesting breaks when they are needed the most, optimizing the use of equipment like monitors and height-adjustable desks, teaching principles of safer computer work through training and behavioral reminders, and providing analytics to help identify where a person can reduce risk.

EHS Scope is Growing and EHS Professionals Will Meet the Challenge

EHS professionals have been tasked with a set of ongoing challenges as they have had to manage the demands of a global pandemic. Strategic planning in the approach of how to manage changing policies and regulations has brought new tools to light and allowed for creative solutions to be developed to help solve these new problems. Moving forward, these efforts should be considered a proof-of-concept that can grow and change with an organization as we all work to adapt to a long-term Pandemic Response protocol. Companies need to make decisions to invest in tools that can help care for employees while maintaining accurate records and data.

For a consultation to discuss Pandemic Response Plans or how EHS Digital Solutions can help manage your COVID-19 response, please contact the authors or call 800.229.6655.