OVERVIEW AND RESPONSIBILITIES
This COVID-19 Safety Plan has been established for MEP Business Counsel (the “Firm”) and its personnel (“Employees”) in accordance with the current Order of the Provincial Health Officer (Workplace COVID-19 Safety Plans) dated May 14, 2020 and also the guidelines set forth by WorkSafe BC as at the date hereof.
We are excited to support the gradual, safe return of normal operations at our offices. The following COVID-19 Safety Plan outlines the policies, guidelines and procedures we have put into place to reduce the risk of COVID-19 transmission. This is a work-in-progress and will be continually assessed and updated to reflect changes in policy and practice as we move forward. We recognize that resuming working at our offices in the absence of a vaccination for COVID-19 is all about assessing and managing risk. We are committed to incorporating best practices and adopting the highest standards of workplace safety to ensure we can continue to be a productive, successful business and a collaborative, effective workplace.
Employers, Employees and the building owner all have a responsibility to prevent exposure to COVID-19 in the workplace.
Employers are responsible for the health and safety of their workers, and all other workers at their workplace. They are responsible for completing and posting the COVID-19 Safety Plan and to train and educate everyone at the workplace of the contents of that plan. Employers are also responsible for having a system in place to identify the hazards of COVID-19, control the risk, and monitor the effectiveness of the controls.
Employees are responsible for taking reasonable care to protect their own health and safety and the health and safety of other people at the workplace. In the context of COVID-19, this means employees are responsible for their own personal self-care, which includes frequent hand washing and staying home when sick. Employees are also responsible for reporting unsafe conditions to their employer, and following the procedures put in place by the employer to control the risks associated with COVID-19.
The Owner of the building is responsible for coordinating health and safety at a workplace where workers of two or more employers are working at the same time. This includes doing everything that can reasonably be done to establish and maintain a system or process to ensure compliance with WorkSafeBC laws and regulations generally, including ensuring an effective system to control the risks associated with COVID-19.
ASSESSING THE WORKPLACE
- The Firm currently consists of 22 total people: 11 lawyers, 4 paralegals, and 7 Support/Administrative staff. A health and safety committee has been established.
- The Firm’s office is located centrally downtown Vancouver in the Royal Centre building which consists of several other business spaces. Access to the Firm’s office space on the 17th floor is by way of elevators and stairs. We currently occupy ¾ of the floor space on the 17th floor and another tenant occupies ¼ of the floor space in a separated office space (“co-tenant”). We share the elevator bank and 2 interior washrooms with the co-tenant.
- The Firm has identified areas where employees may potentially gather or be in close proximity: elevator bank, elevators, washrooms (shared with co-tenant and sometimes public), reception area, collaboration area, kitchen, meeting rooms, hallways, interior offices and copy stations.
- The Firm has identified job tasks and processes where employees may be close to one another and/or members of the public: reception area (accepting deliveries and greeting clients), meeting rooms (meeting with colleagues or clients), copy/fax stations, hallways, and other common areas in the building.
- The Firm has identified the tools, machinery, and equipment that workers routinely share while working: postage machine, copy, printing, scanning equipment, minute books, files and paperwork, kitchen items.
- The Firm has identified surfaces that people touch often: door handles (front door and washroom), elevator buttons, touch pad for printing equipment, areas in kitchen such as fridge, microwave, counter, toaster oven, coffee machine, files and paperwork, minute books.
This section describes some of the key safety measures the Firm will be implementing to reduce the risk of contagion.
1. FIRST LEVEL OF PROTECTION – ELIMINATION
The Firm is:
- During the initial and gradual “phase back” period, establishing a “Working in Office” schedule which reflects occupancy limit currently set at no more than 12 employees on any given day in the office and selected from different practice groups to avoid close proximity. This limit may be modified as the Firm continues to increase its safety protocols and pursuant to guidance from the applicable authorities. When not in the office, the Firm will support other employees to continue to work remotely from home as has been the case for the past several weeks;
- Implementing a shared calendar system that employees should access and check before going to the office to confirm the maximum allowable number of people scheduled has not been exceeded for that day;
- Until further notice, keeping all Firm office entrances closed to the public and only permitting access to Firm employees via card access. Non-employees of the Firm (i.e., clients, family or friends) should not be attending the office during this time, other than building security and cleaning staff or unless pre-approved by management,
- In the event a client needs to attend the office during this initial phase back period, it should occur only as is truly necessary (for example, to drop off or sign documents in person, general meetings should not be taken) and in keeping with the stated protocols set out in this Safety Plan,
- Any visitor to the office will be expected to follow all protocols in this Safety Plan and will be required to sign in at reception.
- Adjusting employee workstations (where practical) to allow more safe physical distance between employees;
- Implementing practices to help minimize employees taking public transit during peak rush hours such as: (A) reimbursing employees who regularly take public transit for expenses up to $120 per month to apply to alternate methods of commuting (i.e., cabs, Uber, Evo memberships, subsidizing parking costs), (B) permitting certain employees to work during non-peak hours (i.e., 6am-2pm or 10am-6pm, or weekends) to avoid higher volume of people on public transit and in building elevators, and (C) allowing some employees to work shorter “in-office” hours and part time at home. Specific issues regarding such public transit should be discussed with the Office Manager to assess the best option in your case;
- Initiating contactless delivery at a designated area outside of the office main entrance for couriers and deliveries;
- Implementing procedure for shared washroom with co-tenant on floor to ensure 1 person at a time in washrooms (using “vacant/occupied” signs); and
- Continuing to provide virtual meeting options (i.e., maintaining zoom licenses and purchasing webcams) for both internal and client based meetings.
2. SECOND LEVEL OF PROTECTION – ENGINEERING CONTROLS
The Firm is:
- Sourcing plexi-glass “sneeze” shields which may be used in certain areas around the office, such as the Reception Desk, to add additional protection where sufficient physical distancing is not possible;
- Hiring janitorial services to conduct routine and ongoing deep cleaning and disinfectant services;
- Making readily available Contactless Hand Sanitizer dispensers dispersed throughout the office for easy accessibility. Individual employees also provided with personal hand sanitizer bottles for workstations, in addition to other PPE items note further below;
- Posting signage at main entrance of the office indicating that no person (including employees) is permitted to enter the office suite if they are exhibiting any COVID-like symptoms;
- Indicate markings on floor as reminders of 6 foot social distancing (i.e., reception area, in front of LAA desks, washroom entrance, etc.);
- Re-arranging furniture around the office Reception area and instituting courier and mail delivery acceptance area in elevator bank outside of main office doors;
- Re-arranging open Collaboration Area and instituting guidelines as to number of people permitted in meeting rooms;
- Making readily available various cleaning and disinfectant supplies in high contact areas throughout the office. Employees should be cleaning high contact points after use.
3. THIRD LEVEL OF PROTECTION – ADMINISTRATIVE CONTROLS
The Firm is:
- Requiring all employees to acknowledge, by signing the form in Schedule A
MEP employee confirmation) that they have read, understood and agreed to Firm’s Safety Plan and related procedures, prior to returning to the office;
- The Firm has purchased contactless thermometers for employee use. At this time, we will not require employees to check and report their individual temperatures each time before entering into the office – however employees (or any others entering the premises) may be asked, where circumstances exist that suggest the employee may be sick, by management to conduct a self-check and report any above “normal” readings (above 6°C) to the Office Manager;
- Ensuring employees are aware not to come to work if they feel sick with any potentially infectious diseases;
- Employees will be asked if they or household members are at higher risk of COVID infection and special measures may be adapted for such employees;
- To the extent practical, limiting employees work in their designated work stations/offices only. Cleaning supplies will be available in the office for employees to disinfect their work area, in addition to the nightly cleaning service for the office suite and regularly schedule disinfecting protocol through the day for shared high contact areas;
- Advising all employees must wash their hands with soap and water upon entry into the office at the main kitchen sink. The Firm will encourage and remind all employees to exercise good hand hygiene by washing and disinfecting hands regularly throughout the day;
- Appointing key personnel to monitor office cleaning supplies and disinfect high contact points in the office at least twice a day, who will wear masks and disposables gloves during the cleaning process;
- Adopting the “no-shoulder rule” that no employees should be passing each other in the hallways “shoulder to shoulder”. If you see someone approaching down the hall, one person must stop, backup and clear the path for the other to pass (can resort to rock, paper, scissors to decide who goes first!);
- Instituting single-occupancy for washrooms – we have coordinated with our co-tenant and will adopt use of “vacant / occupied” signs at the door;
- Working in accordance with building guidelines (as may be adopted or amended) and complying with 4 person max capacity in an elevator;
- Restricting areas of gathering by relocating furniture and appropriate signage indicating occupancy limits at any given time in accordance with social distancing guidelines (i.e. copy stations, kitchen, meeting rooms):
- Kitchen will be limited to a 1 person max capacity solely to access the Fridge, Microwave, Coffee Station and Sink at any given time. Employees not permitted to eat their lunch in the kitchen;
- Employees are encouraged to eat their lunch at their designated workstation or outside in safe, distanced area;
- Restricting open communal food in office, unless items are individually wrapped in sealed packaging (no timbits, donuts, cookies, etc.).
4. FOURTH LEVEL OF PROTECTION – PERSONAL PROTECTIVE EQUIPMENT
The Firm is:
- Providing single-use disposable medical masks for use at the office (please do not take home for personal / family use). Cloth or single-use disposable medical masks are
(A) strongly encouraged to be used generally in the open communal office space areas and when travelling down elevators, and
(B) must be used if in meetings with 2 or more MEP employees in a single room (i.e., boardroom or office) where sufficient social distancing cannot be met at all times during the meeting (distance of 2 meters/ 6ft), and
(C) must be used by any employee who may have a higher risk factor;
- Providing use of disposable gloves for employees in high contact areas should they choose to wear them (i.e., copy stations);
- Instituting new requirements for interactions at the Reception area:
- Abide by marked social distancing markers;
- Access to disposable gloves and disposable medical masks at all times, given this area is a higher interaction point with external vendors and couriers;
- If a physical signature is required for receiving a delivery or process service, the employee must wear a mask and gloves and immediately disinfect the received incoming item upon receipt, followed by sanitizing their hands. Once the item is delivered internally, hands should be washed with soap at the kitchen sink immediately. No shared pens.
COMMUNICATIONS AND TRAINING
- Each of the Managing Partner, Office Manager and Senior Employment Counsel are well versed in the relevant policies and guidelines and will maintain open lines of communication and training to ensure compliance.
- Employees have received all relevant policies, including the Firm’s existing policies relating to staying home when sick.
- Management has been in regular contact with employees to address concerns and questions and will continue to do so via email, phone and in person.
- Clear signage has been posted throughout the workplace, including restrictions on entry, occupancy limits, spacing reminders, and effective hygiene practices.
- The Firm welcomes open communication and feedback from everyone at the Firm to discuss any questions or issues with the policies being implemented.
- Any revisions to the Safety Plan or related policies will be promptly communicated to the employees both verbally and via email, as well as published in the document management system.
ONGOING MONITORING IN THE WORKPLACE
- The Firm will continue to monitor risks in the Workplace (including those in the Building generally) and any issues with implementation of the policies noted herein.
- The Firm may make changes to its policies and procedures as needed (in its sole discretion) and promptly notify employees of any changes.
- Any Employee related health and safety concerns should be brought to the attention of the Office Manager for further discussion