Pandemic Preparedness & Response Planning – Assessing Risks to Enhance Decision-Making

This post is the fourth in an ongoing series on pandemic preparedness and response planning. It builds on the previous post, Pandemic Preparedness and Response Planning – Introduction Sections. If you haven’t already read that, take a few minutes to do so before diving into this post.

The last post described pandemic phases as defined by the WHO; pandemic intervals as described by the CDC; and how pandemic risks are monitored, tracked, and responded to at the highest levels of government. We also provided an example format for a facility pandemic preparedness and response plan and described the introduction section. This post will discuss the next two preparedness sections of a facility plan:

  • Introduction
  • Risk Identification
  • Risk Management
  • Roles and Responsibilities
  • Administrative Controls
  • Engineering 
  • PPE and Emergency Response Equipment
  • Drills/Exercises
  • Employee Training
  • Coordination with Outside Entities 
  • Business Operations/Continuity Planning
  • CommunicationPlan Activation

While an individual facility cannot have a significant impact at the macro planning or response levels, it is very important for facilities and institutions to monitor the information coming from the CDC and WHO. As pandemic phases and interval levels progress during a pandemic, aspects of a facility plan need to be implemented accordingly and often with very short lead time 

Risk Identification

COVID-19 has highlighted many risks a facility can face when a pandemic hits the U.S. (e.g., mass closings, stay at home orders, overwhelming of healthcare systems). While many of these risks cannot be controlled at the facility level, identifying likely risks and how those will impact your facility, preparing for how to mitigate adverse impacts, and memorializing the facility’s response to the risks can significantly reduce the severity of the adverse impacts and avoid some of the chaos that results from trying to react in real time. 

The effectiveness of an individual facility’s or organization’s response actions will depend on how well the facility has identified and prepared for the various risks they are expected to face if a pandemic occurs. Common examples of pandemic risks that should be considered for evaluation and potentially prepared for in a facility pandemic preparedness and response plan include, but are certainly not limited to:

  • Employee health and safety
    • Exposure minimization, containment, tracking, testing
    • Employee mental health
    • PPE needs and availability
    • Critical resources (food, housing, ability to work from home, finances)
  • Business operations
    • Employee risk classifications
    • Travel reductions/restrictions
    • Remote work options
    • Communication – internal and external
    • Information technology/information systems/cyber security
    • Essential v. non-essential work/employees
    • Work staff reductions/accessibility
    • Supply chain disruptions
    • Access to financial resources
    • Impact on clients and future economic prospects
    • Facility security during extended shut-down
    • Safe resumption of operations during and after pandemic moves from acceleration to deceleration to preparation
    • Compliance with applicable environmental, health and safety rules

Risk Management 

Many things will be completely out of the control of an individual facility or organization, such as government lock down orders, travel restrictions, classification of what constitutes an “essential business,” and who are designated as “essential” employees. These decisions will be determined by federal, state, and in some cases local governments, though organizations may be able to argue for the “essentialness” of their business or specific employee job classifications. For example, a facility can argue that custodial workers are essential to controlling the spread of a virus in areas where persons are known to have been infected, yet custodians have not been deemed essential by a regulatory body. Nevertheless, many of the risks identified above can be planned for in a manner that minimizes adverse impact to some extent. 

Examples of risk management tasks, procedures, and planning topics often include: 

  • Monitoring and assessing CDC, WHO, state and local government pandemic advisories
  • Developing a facility-specific pandemic preparedness and response plan
  • Establishing a pandemic preparedness and response committee and pandemic preparedness and response working groups (discussed in detail in the next post) to address different components of a pandemic (e.g., employee health and safety, PPE procurement, communication/information dissemination, etc.) 
  • Developing standard operating procedures (e.g., chain of command, employee risk classifications; decontamination of infected areas; social distancing; donning, doffing, and disposing of PPE, etc.)
  • Employee training 
  • Developing alternative work delivery systems (e.g., work at home, alternative shifts, social distancing, etc.)
  • Ensuring IT systems are sufficient to support operations during stay-at-home orders and employee remote access
  • Ensuring essential medical supplies and PPE inventories are maintained and employees can access them
  • Ensuring adequate supply and availability of essential resources (e.g., food, fuel, paper products, etc.)
  • Ensuring redundancies in supply chain
  • Developing administrative and engineering controls to protect employees and others
  • Activating unplanned/immediate shut-down
  • Start-up after extended unplanned shutdown

Most pandemic preparedness and response plans will address all these topics in a manner that protects the specific facility or institution developing the plan. Accordingly, while plan outlines and tables of contents may look similar, the substantive contents will differ depending on the type of facility, risks, and other factors. In the next post we will take a deeper dive into the different roles and responsibilities that are key to an effective plan and critical teams that should be in place to support effective decision-making. 


Adam Steinman National Practice Leader Environmental Compliance

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