Creating Your Infectious Disease Preparedness and Response Plan

The Occupational Safety and Health Administration has recently recommended that all businesses have an updated Infectious Disease Preparedness and Response Plan in place.

However, if an Infectious Disease Preparedness and Response Plan is new to you and your small business, you’re probably wondering where to start. What should be included will vary business to business (and region to region). There might be certain parameters in your state that you’ll need to follow, and remember that any Infectious Disease Preparedness and Response Plan should be a “living document” that’s regularly revisited and updated. There shouldn’t be anything in this plan that surprises management. But let’s go back for a second:

• What exactly is an Infectious Disease Preparedness and Response Plan?
• What’s the basic framework?
• Why haven’t you heard of it before?

COVID-19 has made a lot of businesses reevaluate just how capable they are of handling infectious diseases (or not, in most cases) in the workplace. Being prepared is key in the midst of a pandemic, especially for small businesses reopening or trying to stay open while also protecting their employees. Maybe you’ve created new sick leave policies, instituted a work-from-home approach, or are implanting temperature checks daily.

All of these can and should be in an Infectious Disease Preparedness and Response Plan. However, understanding the most prevalent diseases are also critical to shaping your plan, and right now that’s COVID-19.

Being prepared is key in the midst of a pandemic, especially for small businesses reopening or trying to stay open while also protecting their employees.

Start with the basics

Make sure you’re only using authoritative resources about COVID-19 to write your Infectious Disease Preparedness and Response Plan. The Centers for Disease Control and Prevention is rightly the foundational resource to use, and you’ll find many suggestions for what to include in an Infectious Disease Preparedness and Response Plan on their website. The Society for Human Resource Management is another option with helpful guides.

One of the first items you want to address in your Infectious Disease Preparedness and Response Plan is how to communicate to your employees during a pandemic. Encourage them to only glean outside information from established resources like those listed above. This is part of the information sharing process, and an Infectious Disease Preparedness and Response Plan will give your employees detailed information on the current sick leave policy (which you may have already updated). The Infectious Disease Preparedness and Response Plan is where your employees will find a capped number of sick days, for example.

Updating policies

It makes sense to update policies at this time, perhaps temporarily, but make sure any changes still abide by the Family and Medical Leave Act and any state or local regulations. A common situation lately is that employers want their workers to self-quarantine if they’ve potentially been exposed to COVID-19, but what if that’s most of your workforce? Can you cap how many employees take time off?

That depends on the paid sick leave laws of your state, so there’s research and a balancing act to writing an Infectious Disease Preparedness and Response Plan that helps protect your employees without breaking any laws.

It’s also prudent to pay attention to any changes or language in an Infectious Disease Preparedness and Response Plan that might suggest discrimination based on a workers’ origin. This is where working with an HR expert is critical, because this isn’t always binary. Are you able to make a worker self-quarantine if, for example, they have recently returned from caring for family in another country that has many cases of COVID-19? You don’t want the language you use to suggest that your decision is based on racial or faith-based discrimination.

If you’re making changes, they need to be very clear. The best way to do this is, again, with an HR expert.

Making sure everyone understands your business’s sick leave policies might require a major communication effort (depending on the size of your business in some regard). If you’re making changes, they need to be very clear. The best way to do this is, again, with an HR expert.

Work-from-home changes

If you’re drafting an Infectious Disease Preparedness and Response Plan and you have work-from-home policies, you should include them in it. Some businesses are adopting work-from-home policies for the first time while others are expanding old policies.

You’ll also want to think about exempt and nonexempt statuses of employees and how that might affect working from home.

Travel is another factor when writing or updating your Infectious Disease Preparedness and Response Plan. If it’s common for your employees to undertake business travel, that might need to be stopped or modified. Some businesses have found that they’re reevaluating just how beneficial business travel is to their company, especially on an international level.

If you’re changing your travel policies, these need to be reviewed and all employees need to be aware of modifications and the risks of travel. “Travel” can also include hyperlocal travel such as an employee who regularly goes to the company’s P.O. Box or makes deliveries. However, you’ll want to be clear that the Infectious Disease Preparedness and Response Plan does not dictate an employee’s personal travel choices.

Creating and sustaining a healthy workplace

Drafting an Infectious Disease Preparedness and Response Plan is likely due to COVID-19 at this time, but it’s an important document to have in place for any infectious disease — including the flu. It’s all part of creating and maintaining a workplace that’s healthy.

A comprehensive written plan with critical steps to take in order to minimize the risk of spreading infectious diseases should be always available to all employees. You’ll want to include an Exposure Control Plan that includes narrative about how you — the employer — are taking care of employee risks. This might include new rules on:

• Personal protective equipment
• Social distancing best practices
• Hand washing regulations

The administrative controls you’re making to minimize the spread of disease should be included in detail. Staggering shifts, working from home, how often to wipe down shared equipment and with what are all common inclusions. When an Infectious Disease Preparedness and Response Plan is comprehensive and routinely updated, you’re protecting your employees — and, in turn, your business.

There’s another benefit to having an Infectious Disease Preparedness and Response Plan in place. If you are ever contacted by OSHA or local authorities to see if you’re prepared for COVID-19 outbreaks, the Infectious Disease Preparedness and Response Plan is your proof.

Drafting an Infectious Disease Preparedness and Response Plan is likely due to COVID-19 at this time, but it’s an important document to have in place for any infectious disease — including the flu.

What you might want to include

As you outline your Infectious Disease Preparedness and Response Plan, make sure it’s customized to your unique business and region. Basics like staying at home if you feel sick, stopping shared work tools when possible, disinfecting the workplace, and having hand sanitizer readily available are all very common to include. However, you can go much further.

Some companies are installing high-efficiency air filters, and if you do, make sure that’s listed in your Infectious Disease Preparedness and Response Plan. Maybe you’re expanding the ventilation rates and are putting up barriers like sneeze guards. Perhaps your company is in the position to now offer curbside pickup or a drive-through.

Are you swapping out in-person meetings with virtual ones? Stopping any non-essential employee travel? Putting new emergency communication policies in place? Adding in COVID-19 specific training for employees? All of these will help keep your workers safe and will need to be detailed in an Infectious Disease Preparedness and Response Plan.

If this sounds overwhelming, you’re not alone. Working with HR experts gives you peace of mind knowing every detail is properly addressed so you can focus on helping your business thrive.