This post is the seventh in an ongoing series on pandemic preparedness and response planning. It builds on the previous post, Pandemic Preparedness and Response Planning – Workplace/Hazard Controls. If you haven’t already read that, take a few minutes to do so before diving into this post.
In the last post we addressed response strategies and the hierarchy of controls that can be implemented during a pandemic to help contain an outbreak and reduce the threat of spread at a facility. This post will dive deeper into specific policies and procedures (some of which have been identified in the previous six posts) that should be developed and how employers can help ensure proper implementation through employee training, exercises and drills. Effective written policies and procedures, and employee implementation training are critical to the success of all facility pandemic preparedness and response plans.
Policy and Procedure Development
Every post in this series has discussed the need for various written policies and procedures designed to maximize, to the extent practicable, a facility’s ability to respond effectively in response to a threatened or actual pandemic. In this post, we describe common written policies and procedures contained in many plans in the order discussed in the first post in this series:
Preparedness/pre-emergency—Written procedures and policies
- Pandemic/epidemic monitoring and plan implementation – Describes the ways a facility monitors the development of global pandemics and local epidemics, and at what stages the facility plan is triggered and different steps are activated.
- Risk Identification – Sets forth the process a facility uses to identify the potential risks to people, the business, infrastructure, and real and personal property associated with the specific threats of a global pandemic or local epidemic.
- Risk Assessment – Sets forth the methodology for assessing the identified potential risks that could be faced during a pandemic. The procedure will typically include a discussion of the subjective assessment criteria and how the criteria should be applied.
- Risk Characterization – Sets forth a ranking system to prioritize the most serious risks to people, the business, etc. Specific procedures typically include identifying essential and non-essential roles and characterizing risks to each job function and the business.
- Risk Management – Includes individual procedures to mitigate/manage the risks, starting with the highest priorities.
- Roles and Responsibilities – Identifies all key roles and responsibilities for every position within a facility/institution.
- PPE and Resource Procurement – Procedures for ensuring an adequate inventory of PPE and other essential resources are on-hand, with a procurement process to ensure adequate additional supplies will be obtainable once the pandemic arrives.
- Specific agreements with emergency service providers and other key partners.
- Communications procedures – There are likely several different communication procedures depending on the information being communicated (e.g., positive COVID-19 test to health officials or contact tracing, internal return to work notice, etc.). E ach procedure will identify who communicates, how (email, social media, press release, etc.), the audience, and the content.
- Travel policy and employee/student/researcher tracking – Identifies how a facility keeps track of where its people are, if and when to retrieve them, and if and when to quarantine in the country where they are located.
- Health and wellness, medical resources, testing, etc.
Emergency Response
- Plan Implementation/Activation – Describes in detail who activates the plan, the steps the facility will take depending on the phase and severity of the pandemic, locations being impacted, threat to human health and safety, business operations, etc.
- Communications – Internal and external communications, communication procedures and methods, and messaging. This is always evolving during the different phases depending on what happens when and where and government restrictions that must be adhered to.
- Infection control – Procedures for enhanced personal hygiene, social distancing, infection and health monitoring, staggering shifts, occupancy limitations, and transportation methods.
- Infection Avoidance – Facility shut-down, isolation, quarantine, administrative and engineering controls.
Infection testing, contact tracing, reporting. - Emergency medical and support services, housing, transportation, employee accommodations.
- Business continuity and safe continuation or shutdown of operations as the situation dictates.
Incident Termination/Resumption of Activities
- Return to Work/School Playbook – The RTW or RTS is a comprehensive manual as to how and in what phases facilities will opening and returning to normal operations. This is likely to commence while the pandemic is still on-going, but based on a variety of factors (stage of pandemic, economics, etc.) some level of return is deemed necessary, appropriate and/or safe.
- Start-up operations.
- Enhanced precautions to avoid or minimize threat of second wave.
- Critique of effectiveness of plan, procedures and policies.
- Plan revisions and updates based on critique.
It is not unusual for there to be several dozen written procedures and protocols in a pandemic planning and response plan. Each should be clear, concise, and actionable, but allow for adjustment to circumstances. Because the response sections of pandemic preparedness and response plans are likely to be implemented on an extremely infrequent basis, some components that may prove unnecessary and there may be gaps if unidentified risks are revealed.
