OHS Conditions for Business Resumption Planning

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Introduction

This document provides the minimum strategic level Occupational Health and Safety (OHS) Conditions for Business Resumption Planning (BRP) that all L1s shall consider in the development of their BRPs.  These conditions will then need to be promulgated down the Chain of Command (CoC) to the local levels where the actual frontline tactical risk mitigations and preventive measures will be developed by the employer in consultation with the Workplace Health and Safety Committees (WHSC)/Health and Safety (H&S) representatives.

These conditions will need to be considered in the local planning efforts for resumption of business activities including both the reintegration of the workplace and the increased use of remote work by Defence Team (DT) members.  All of these conditions must be fully satisfied, or approved risk mitigations, after consultation with the WHSC/H&S Representatives as may be required, put in place prior to an organization resuming its business activities.

The conditions in this document are separated into different OHS aspects listed below and are general enough to apply to all potential work and workplace situations at a strategic level since the detailed mitigation measures (Standard Operating Procedures, Tactics, Training and Procedures, etc.) must be developed locally based on the specific nature of each task, workplace and environment where they will be conducted.

Background

Managers, supervisors, WHSCs, H&S Representatives and OHS Advisors will need to work together to plan for the healthy and safe resumption of business activities and the reintegration of the DT into the workplace.

The General Safety Program (GSP) is based on the Canada Labour Code, Part II and its accompanying Regulations.  The Program clearly establishes the requirement to first identify hazards in the workplace and then eliminate or control them.  This applies to the risk of COVID-19 in the workplace as we consider how to return to a more normal work posture.

This is an OHS undertaking which will require full engagement by both the employer and employee elements of the DT at all levels.  The foundation to address this challenge exists through the GSP Committee structure including Workplace Health and Safety Committees and a well-established “Internal Responsibility System” for the employer and employees to consider OHS issues.  Additional information can be found in the General Safety Program Volume 1, Policy and Program Manual, Chapter 3, Safety Councils and Committees. [PDF - 231KB] (Link accessible only on the National Defence network)

The current Force Health Protection practices that have been put in place, help to minimize the risks associated with COVID-19.  To ensure we continue to limit the risks, we need to acknowledge that it will not be “business as usual” when we begin to resume operations/services/activities in the workplace.  We have a requirement to look at options to support and accommodate personnel with special situations returning during this COVID-19 pandemic.

As with any hazard, mitigating the risk is achieved through a combination of preventive measures ranging from elimination of the hazard, reduction of the hazard (including engineering controls), administrative procedures and the provision and proper use of personal protective equipment (PPE).  Clearly, with COVID-19, we are currently not in a position to totally eliminate the hazard but we can reduce the risk of the hazard to personnel.  DND/CAF has already implemented a number of recommended control measures issued by CF Health Services Group and the Public Health Agency of Canada (PHAC) such as Public Health Measures (PHMs) (minimizing the number of employees in the workplace, physical distancing, increasing cleaning routines, hand washing, respiratory etiquette/discipline) and use of PPE.

Every workplace is unique and organizations, in consultation with their local WHSCs/H&S Representatives, must consider a variety of preventive measures in finding the best approach for operationalizing a healthy and safe business resumption plan for their workforce.  Discussions related to COVID-19 hazard prevention strategies for the returning workforce are an essential part of business resumption planning.  These discussions shall focus on the development and implementation of local occupational health and safety measures that have employer and employee concurrence as part of the respective business resumption plans.

The conditions identified below will complement the PHAC/FHP and medical considerations also promulgated as part of BRP directives.  These conditions must be read in conjunction with each other to ensure there are no conflicting directions. 

Application of the Hierarchy of Hazard Controls

According to OHS policy and legislation, the fundamental method for protecting workers is through the application of the hierarchy of controls.  The levels of control range from the highest levels considered most effective at reducing the risk of exposure (i.e., elimination and substitution) to the lowest or last level of control between the worker and the hazard (i.e., PPE).  The application of the hierarchy of controls is a recognized approach to containment of hazards and is fundamental to an occupational health and safety framework.  An understanding of the strengths and limitations of each of the controls enables organizations to determine how the work environment (e.g., infrastructure, equipment, processes and practices) increases or decreases a worker’s risk of infection from exposure to a pathogen within the work setting.  Collaboration between local FHP, OHS and Real Property Operations (RP Ops) communities supports the comprehensive evaluation and implementation of measures to reduce the risk of workers’ exposure to pathogens.

Elimination and Substitution - Elimination and substitution are considered to be the most effective means in the hierarchy of controls; these are often not feasible or possible to implement in regards to infectious diseases in workplace settings during a pandemic situation due to the very nature of the hazard.  The hazard can neither be eliminated from the environment nor be substituted by a lesser hazard.

Engineering and Systems Control Measures - Engineering control measures reduce the risk of exposure to a pathogen or infected source hazard by implementing methods of isolation.  Engineering controls reduce or eliminate exposure by isolating the hazard from the employee and by physically directing actions to reduce the opportunity for human error.  Examples include barriers at the interface between the possible source of infection and the workers in the workplace and pedestrian traffic control barriers.

Administrative Control Measures - Administrative controls are measures to reduce the risk of transmission of infections to workers through the implementation of policies, procedures, training and education.  Effective administrative control measures to prevent the transmission of infection require the support of leadership in the work organization, in consultation with the employer and employees through the WHSCs or H&S Representative, to provide the necessary organizational procedures, resources, education and training to effectively apply the controls, and the commitment of workers and other persons granted access to comply with their application.  Examples of administrative controls include active screening, mandatory and frequent hand washing and restricted visitor policies.

Personal Protective Equipment (PPE) - Although the use of PPE controls are the most visible in the hierarchy of controls, PPE controls is the last tier in the hierarchy and should not be relied on as a stand-alone primary prevention program.  The PPE tier refers to the availability, support and appropriate use of physical barriers between the workers and an infectious agent/infected source to minimize exposure and prevent transmission.  Examples of PPE barriers include gloves, gowns, facial protection and/or eye protection.  The organization plays a critical role in ensuring workers have access to appropriate PPE for the task to be performed and the necessary education and training to ensure competency on the appropriate selection, use, care and disposal of PPE to prevent exposure to infection.

The OHS aspects and individual conditions identified below all fall into one of the above categories of controls.  Due to the nature of the hazard that COVID-19 poses and, as stated above, the inability to currently eliminate it as a hazard in the environment, the use of engineering and administrative controls will be most effective.  As you will see, the majority of the conditions below are considered administrative controls with only a few of them being engineering controls or PPE controls. 

OHS Aspects

Workplace Health and Safety Committee/Health and Safety Representative Participation

General approach – The diversity of functions associated with DND/CAF operations, training and support activities requires skilful and continuous review of Occupational Health and Safety efforts at all organizational levels and at the workplace.  To assist with these functions, multiple types and levels of safety councils and committees, including local WHSCs or H&S Representatives, have been established.  DND/CAF WHSCs are established to help the employer in the reduction of hazardous occurrences and thereby conserving resources, more specifically the protection of workers in this era of COVID-19. 

Safety councils and committees, including WHSCs or H&S Representatives, are either a legislated requirement of the Canada Labour Code Part II or a policy requirement of A-GG-040-001/AG-001, General Safety Program, Vol. 1, Chapter 3, Safety Councils and Committees. [PDF - 231KB] (Link accessible only on the National Defence network) Additionally, Chapter 2, Responsibilities [PDF - 226KB] (Link accessible only on the National Defence network) provides a complete list of duties for all stakeholders in the workplace.

Roles – Safety councils and committees, especially WHSCs or H&S Representatives, have a key role to play in the resolution of occupational health and safety complaints and refusals to work in cases of danger in the workplace.  They have to dispose of complaints related to COVID-19 through the Internal Complaint Resolution Process (ICRP) when they are not resolved at the supervisor level.  If the ICRP is not successful in resolving the complaints the refusal to work process, where applicable, can be used to address the issue and the WHSC or H&S Rep have a role to play if no resolution is found at the supervisor’s level.

Conditions – The following conditions with respect to WHSCs/H&S Representatives shall be implemented by all organizations prior to and following resumption of business activities:

  1. Roles and Responsibilities – organizations shall ensure that committee members and representatives are well versed on the refusal to work and ICRP processes in addition to their overall roles and responsibilities;
  2. Meetings – safety committee meetings shall be held as mandated by policy or legislation in the safest manner possible;
  3. Participation – safety committees and representatives shall participate in all OHS aspects related to COVID-19 such as inquiries, investigations, complaints, refusals, in the implementation and monitoring of hazard prevention activities, as well as COVID-19 hazard assessments;
  4. Consultation – the WHSC or Rep shall be consulted on the resumption of business activities and reintegration of the workplace to ensure all OHS requirements put forward by the DM/CDS and respective L1s’ BRPs are monitored to ensure compliance; and
  5. Information/Communications – the CoC shall ensure that adequate COVID-19 related information required to enable safety committees and H&S representatives to fulfill their roles is maintained and provided to them through any means.

Access Control

Access Control is typically a security control measure used to keep DND/CAF workplaces free of security threats and to protect DT members and DND/CAF information from those threats.  It is also a key element in helping prevent the introduction and transmission of the COVID-19 virus in the DND/CAF workplace.  This being said, a balance needs to be found between security requirements and infection prevention and control requirements.

Conditions – The following conditions with respect to Access Control shall be implemented by all organizations prior to and following resumption of business activities:

  1. organizations shall ensure only authorized persons are granted access to the workplace including developing strict visitor protocols;
  2. organizations shall ensure a mechanism is in place to advise all non-DT persons granted access to the workplace of the DND/CAF COVID-19 PHMs and PPE requirements and expectations for compliance.  This notification must be documented;
  3. organizations shall determine if logs for tracking access to higher COVID-19 hazard areas in the workplace (gyms, cafeterias, meeting rooms, etc.) are required and if so, will implement a system to capture and store the data for potential contact tracing use.

Infrastructure and Sanitation

References:

  1. ADM(IE)/ Real Property Operations (Link accessible only on the National Defence network)
  2. Public Services and Procurement Canada (PSPC), Real Property Services Workplace Resumption Guide, Apr 2020
  3. GOC website Cleaning and disinfecting public spaces (COVID-19) 
  4. PSPC Property Management Direction for Coronavirus Disease 2019 (COVID-19), 3 Apr 2020
  5. Annex M to DFHP Advisory 6636-80: Interim Disinfection Guidelines for Novel Coronavirus (Covid-19) in the Workplace

Context - Resumption of workplace operations in a persistent COVID-19 environment may require infrastructure and property maintenance adjustments.  Reduced occupancy, adaptations in personnel use of buildings and other infrastructure changes to respect physical distancing and cleaning protocols may require changes in infrastructure configurations and maintenance routines.  Organizations must also be prepared for cases where personnel in the workplace have tested positive for COVID-19, display symptoms of COVID-19 or have been in close contact with someone who is suspected of having contracted COVID-19, including enhanced cleaning protocols. 

RP Ops is responsible for the management of DND/CAF buildings and infrastructure IAW reference A.  RP Ops works with PSPC Real Property Services on federal facilities occupied by DND/CAF personnel and will apply COVID-19 property servicing guidelines consistent with reference B to D.  Director Force Health Protection (DFHP) is the primary reference source for CAF Occupational Health standards, including sanitation standards, involving infectious agents and organisms and appropriate disinfection methods and equipment.  In general, DFHP align their practices with standards promulgated by the PHAC and will reference them where appropriate.  As a result, building and relevant infrastructure disinfection and sanitation standards and guidelines related to COVID-19 will closely refer to either DFHP or PHAC sources as appropriate.  This includes the provision of building and other infrastructure cleanliness management services by DND employees or through PSPC as either standalone contracts or Standing Offer Agreements.

Cleaning and Disinfection Standards - Reference E contains the primary and common cleaning and disinfection standard to be used in DND.  It is consistent with PSPC guidance as is contained in reference B.  The current COVID-19 cleaning standard involves cleaning common areas twice daily with recognized cleaning and disinfection products.  More detailed breakdown of sanitary and disinfection standards applied across DND/CAF are contained in reference F.  In the event of suspected or confirmed cases of COVID-19 enhanced cleaning protocols shall be requested either through the PSPC’s 24/7 National Service Call Centre (NSCC) at 1-800-463-1850 (mostly in the NCR) or through the appropriate RP Ops Detachment work order process (mostly in the regions).  Local RP Ops detachments are to be advised of all cases where enhanced cleaning actions are required.

Initial Real Property Inspections Prior To Resumption - After initial phases of COVID-19 response are completed, Real Property management must prepare buildings and infrastructure for a gradual resumption of business activities, occupation and use of facilities.  Immediate OHS considerations shall include air quality, potable water quality, sanitary and effective storm system operations and general infrastructure hygiene including waste and sanitation facilities and systems, dust, and pest infestations.

COVID-19 Related Infrastructure Adaptations - As organizations reconvene there may be requests and recommendations for infrastructure adaptations due to the COVID-19 threat.  This can include the reconfiguration of workplaces, the installation of barriers, the installation of dispensers (sanitary wipes, disinfection gels) and the erection of temporary walls. Typically, requests for infrastructure adaptations are processed through RP Ops or local Facility Managers who have established administrative processes and prioritization mechanisms.

Fire Protection Life Safety (FPLS) Program – An effective FPLS program must continue to exist even under COVID-19 restrictions.  Equipment operation, training and emergency response scenarios must all be adapted to recognize COVID-19 realities.

Conditions – The following conditions with respect to Infrastructure and Sanitation shall be implemented by all organizations prior to and following resumption of business activities:

  1. the organization shall ensure that cleaning arrangements that meet PSPC/DFHP standards are in place;
    l’organisation doit s’assurer que des protocoles de nettoyage renforcés sont en place pour les cas où une personne qui a été déclarée positive à la COVID-19, ou qui est soupçonnée d’être infectée, a été sur les lieux de travail;
  2. the organization shall ensure that enhanced cleaning protocols are in place to address situations where a person confirmed with or suspected of COVID-19 infection has been in the workplace;
  3. the organization shall develop and promulgate SOPs, TTPs, etc. dealing with the use of common tools and equipment and their sanitation if applicable;
  4. the organization shall develop responsibilities and protocols with respect to common area cleanliness and disinfection, communicating them to all personnel and posting them where appropriate in the workplace;
  5. the organization shall ensure that pre-resumption and steady state facility/infrastructure inspections are conducted recognizing the potential impacts of COVID-19 related vacancy and occupancy effects;
  6. the organization shall communicate urgent COVID-19 related infrastructure Work Order processes to managers and supervisors; and
  7. the organization shall review and update FPLS Plans to consider COVID-19 conditions.

Adherence to Public Health Measures (PHMs) and PPE Guidelines

PHMs are the most important control interventions that currently exist to reduce and delay workplace and community transmission of SARS-CoV-2 (COVID-19).  PHMs refer to a number non-medical interventions, used in combination, such as physical distancing (maintaining 2m distance from others), good hand hygiene, and avoiding touching one’s eyes, nose and mouth with unwashed hands.  PPE is used to protect personnel when all other hazard control measures fail to reduce the risk of injury/illness to acceptable levels.  In a high risk COVID-19 environment this could include Respiratory Protection Equipment (RPE), face shields, eye protection, gowns and gloves.

Conditions – The following conditions with respect to Adherence to PHMs shall be implemented by all organizations prior to and following resumption of business activities:

  1. organizations shall ensure that appropriate communication, training, physical modifications and procedures are in place in the workplace to fully conform to the PHMs outlined in the DM/CDS Joint Directive – DND/CAF COVID-19 Public Health Measures and Personal Protection, and its Annex A;

  2. where it is identified that Non-Medical Masks (NMMs) are required to be worn by personnel as a PHM, the organization shall:
    1. ensure that arrangements are in place to secure adequate quantities of NMMs for all personnel requiring them; and
    2. ensure all personnel are trained on the proper use, care, maintenance and disposal of the NMMs;
  3. organizations shall ensure a workplace risk assessment has been completed prior to resumption of business activities and reintegration of the workplace, the purpose of which is to identify COVID-19 hazards specific to their workplace and facilitate development of tailored strategies to mitigate those hazards; and

  4. where the hazards identified cannot be mitigated to acceptable levels using engineering and administrative controls and it has been determined that PPE is required, organizations shall:
    1. ensure that arrangements are in place to secure adequate quantities of appropriate PPE for all personnel requiring it; and
    2. ensure all personnel are trained on the proper use, care, maintenance and disposal of the PPE.

Health Screening and Response

The CoC has an obligation to maintain a healthy and safe workplace for its personnel which includes keeping it free of COVID-19 related hazards.  As such, various policies and control measures have been put in place during the CAF/DND’s response to the COVID-19 threat during Phase 3 of Op LASER.  Consistent with the DM/CDS Joint Directive – DND/CAF COVID-19 Public Health Measures and Personal Protection, members of the Defence Team will not report for duty if they have symptoms of COVID-19.

Conditions – The following conditions with respect to Health Screening and Response shall be implemented by all organizations prior to and following resumption of business activities:

  1. organizations shall ensure that all persons granted access to the workplace undertake  appropriately screening protocols prior to entering the workplace.  Options include self-screening apps, signage at entry points and use of dedicated screeners; and
  2. organizations shall develop SOPs to address the relevant issues (such as cleaning, risk reduction, absence from work, communication) arising from the following scenarios:
    1. DT member/person granted access develops symptoms of COVID-19 while in the workplace;
    2. a DT member/person granted access develops symptoms of COVID-19 away from work within 48 hours of being in the workplace; and
    3. a DT member/person granted access declares a legitimate potential exposure to a known or probable COVID-19-positive individual prior to re-entering the workplace.

Promotion, Motivation and Training

Key elements of OHS programs are promotion, motivation and training.  These elements promote OHS throughout the organization and provide motivation for good OHS habits.  This motivational effort can vary from a mere reminder for most personnel to the need for a major attitudinal and behaviour change on the part of others.  The latter is especially of concern in the present COVID-19 environment where adoption of effective PHMs will rely on important behavioural changes by the majority of DT members.

OHS must be emphasized and reemphasized throughout the various stages of every individual's career.  For organizations it is a continuing but necessary challenge which will require some investment of their time.  OHS promotion and motivation activities can be advanced through a variety of methods.  For example, special emphasis on training and education will subsequently promote the desired OHS attitudes and behaviours while ensuring a well-oriented workforce.  In addition, OHS Communiqués, signage and posters create interest and foster healthy and safe working attitudes.

OHS training can take many forms and is mandated by policy and legislation for many aspects of OHS programs.  It is the organization’s responsibility to ensure that all DT members are adequately trained on their OHS roles and responsibilities as well as all hazards and the mitigation and prevention measures implemented to control them.  This is no different for hazards related to COVID-19.

Conditions – The following conditions with respect to Promotion, Motivation and Training shall be implemented by all organizations prior to and following resumption of business activities:

  1. organizations shall develop and implement an OHS promotion and motivation plan specific to COVID-19 hazards in their workplace and the mitigation and prevention measures to control them (using centrally provided or locally created materials);
  2. organizations shall ensure that all DT members complete the “COVID-19 Awareness Course” on the DLN; and
  3. organizations shall develop and deliver a workplace specific COVID-19 Orientation Briefing to all DT members.

Remote Work Hazards

The COVID-19 pandemic has altered the way we do business at present and for the foreseeable future.  It is presumed that going forward the number of people working remotely will be higher than our pre-COVID-19 and current response posture.  DND/CAF needs to support those who work remotely by being mindful of their health and safety from both a physical stand point and a mental health perspective.  Additional information can be found on the Defence Team COVID-19 – Working remotely webpage.

Conditions – The following conditions with respect to Remote Work Hazards shall be implemented by all organizations prior to and following resumption of business activities:

  1. the organization shall identify and assess potential OHS hazards related to personnel that are working remotely; and
  2. the organization shall provide personnel working remotely with information, training, materials and/or equipment commensurate with the hazards identified in order to mitigate the risk of injury/illness and reduce the likelihood of hazardous occurrences.

Psychological Health and Safety

The outbreak of COVID-19 has resulted in a high degree of uncertainty and disruption to the lives of members of the DT, and it is not unusual for them to feel a heightened degree of anxiety and worry about the potential impact on themselves and their families.  As we continue to navigate through this uncertain time, DT members can access a variety of resources and information to help maintain and improve their mental health and overall personal well-being.

Conditions – The following conditions with respect to Psychological Health and Safety shall be implemented by all organizations prior to and following resumption of business activities:

  1. managers and supervisors must periodically monitor and assess the psychological health and safety of their employees, both working in the physical workplace and those working remotely;
  2. they must communicate on a regular basis and remain aware and responsive to the changing needs of their employees identifying and implementing prevention measures to mitigate any mental health risks; and
  3. employees must be made aware of the support and resources that are available to aid them with their mental health, especially in the COVID-19 environment (Defence Team COVID-19 – Mental Health).

OHS Resources

The CoC of all organizations will need to rely heavily on the professionalism and expertise of the OHS resources at their disposal throughout the business resumption and workplace reintegration process.  These resources are finite and limited within DND/CAF and form a cadre of subject matter experts/advisors uniquely qualified to support the CoC in dealing with OHS matters.  Resumption of business activities and the reintegration of the workplace is a complex and evolving OHS challenge requiring knowledgeable personnel to advise the CoC.  OHS Resources would include advisors from FHP, OHS and WHSC communities.

Conditions – The following conditions with respect to OHS Resources shall be implemented by all organizations prior to and following resumption of business activities:

  1. organizations shall ensure that adequate OHS resources are available at all levels of the CoC to advise on OHS matters related to resumption of business activities and reintegration of the workplace in a persistent COVID-19 environment;
  2. organizations shall ensure OHS resources reintegrate the workplace as a priority and shall provide them with the necessary tools for them to conduct their business; and
  3. organizations shall ensure that local OHS resources are consulted on all BRP efforts in order to assist the organization in satisfying the OHS Conditions for BRP by advising them on the mitigation and prevention measures required in the workplace.

Reporting Requirements

General Approach - As a matter of transparency and enhanced reassurance, an OHS Conditions for BRP reporting requirement has been developed.  This reporting requirement will provide DND/CAF senior leadership with visibility on the state of readiness of all L1 organizations for resumption of business activities and reintegration of the workplace.  It will identify which conditions have been fully satisfied, remain to be satisfied or where mitigating measures are being put in place when conditions cannot be fully satisfied.  These reports will be valuable corporate records of the OHS prevention measures implemented to protect DT members from the hazards of COVID-19 in the workplace and can serve as proof of Due Diligence if required.

Conditions – The following conditions with respect to Reporting Requirements shall be implemented by all organizations prior to and following resumption of business activities:

  1. organizations shall report their readiness to resume business activities and reintegrate the workplace through the CoC to their respective L1s confirming the status of each condition identified herein (fully satisfied, not satisfied and mitigated) using the reporting tool at Appendix 1; and
  2. organizations shall immediately report any change of a condition from “fully satisfied” to “not satisfied” or “mitigated” through the CoC to their respective L1s indicating their ability to maintain their business activities and reintegration of the workforce.

Conclusion

This document has provided the minimum strategic level OHS Conditions for BRP that L1s shall consider in developing their BRPs.  The ability of DND/CAF to resume its business activities and reintegrate its workforce depends on the successful implementation of mitigation measures and prevention activities that will satisfy the above conditions by local organizations.  Efforts expended in ensuring these conditions are satisfied will contribute greatly towards creating a healthy and safe work environment for all DT members when business activities resume.  It also serves as an important measure to reassure DT members that they can be confident that their health and safety is being protected.

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