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Human Resource professionals have suddenly experienced a job transformation into Risk Management. They are often leading (or a central part of a strategic cross-functional team) initiative to ensure customer and employee safety while following jurisdictional protocols associated with re-opening. This task is becoming increasingly complicated by new COVID hot spots. Add to that a potentially more significant second wave in the fall, there are even more considerations that should be taken into account and planned for now. 

What happens if you are unable to keep employees and customers safe? What if 40% of your workforce is out sick at the same time? Can business operations continue? In addition, the lawsuits have already begun. Any customer can claim negligence of any corporation for failing to provide evidence of adequate enforcement of their return to work policy and local, state, or federal guidelines. Compounding this risk, shareholders have been shown to be not far behind in seeking protections from the fallout of this negligence. Paper visitor logs and employee temperature records won’t cut it - a sound enterprise risk management strategy and documentation that protocols were followed is required. 

The 6 categories below are essential elements to developing a business continuity and employee safety plan: both the near term and accounting for continued business disruptions coming:

Risk Assessment: Each company needs to consider its unique circumstances through a risk assessment to determine possible impacts of a 2nd wave of the virus. Identifying and assessing risks to the organization from different root-cause perspectives is the 1st step toward building a risk mitigation plan. Mobilize a cross-functional team of experts, with the mission of identifying all vulnerabilities. Pose these questions:

  • What happens if a large proportion (say, 40%) of the company’s staff are out sick at the same time?
  • Where are all our suppliers located? Where are their suppliers located? And which ones are critical?
  • What new distancing strategies does the company need to implement to ensure on-site protection?
  • What procedures are necessary to minimize litigation risk should an employee or customer fall ill?

Identify all control measures that the organization has put in place to manage and mitigate the risk of the virus. It must include information about who will monitor these control activities, and how, to ensure that stakeholders are following specified policies at all locations. Publish the details to demonstrate that you take the health of your workers, customers and broader community seriously.

Jurisdiction Requirement Tracking: With jurisdiction requirements changing in a fluid manner as states experience setbacks, it is critical to maintain a library of guidelines to help you comply with federal, state, city and agency jurisdictional requirements. These requirements must also be incorporated into your own internal policy and facility considerations. Commercially reasonable mitigation and monitoring and company policy templates are also needed to help you keep your employees, customers and vendors safe while maintaining evidence of your compliance in each of the jurisdictions you operate in.

Employee Wellbeing and Incident Management: If customers and employees are returning to physical office and branch locations, implement and sustain your employee screening plans for both physical and mental health. Consider policies that address childcare, underlying conditions, relocation tax reporting or simply fear of return without violating discrimination, privacy, tax or employment laws. It is also important to automate the process. Leverage an encrypted webform to collect employee COVID positive test information with routing rules and workflows. This will ensure compliance with privacy laws on Personally Identifiable Information (PII), Personal Health Information (PHI) and General Data Protection Regulation (GDPR) requirements.

Alternate Workplace and Resource Allocation: If you are not returning to physical locations immediately and you are considering shift work, flex work or remaining fully remote, building the infrastructure for operating in your chosen model is critical. Remember to stay flexible; plan ahead for risks associated with the 2nd wave and the potential need to pivot to another model due to increased infections. Develop a process to manage real-time resource reallocation needs due to sickness outages and positive test results. It will be crucial to automate cross-department and cross-facility approvals. Be sure to coordinate shift work, flexible work arrangements, new employee onboarding and training and redeployment of employees.

Incident Reporting and Entry Log Requirements: Paper or emailed incident reporting and entry logs will not cover you from being found guilty of negligence should you be accused of not sufficiently protecting employees or customers. Software can be leveraged to schedule reservation times online before on-site visits. This will allow you to limit vendor and customer interaction to maintain social distancing. It will also establish a clear customer agreement with your safety policies.  You can also leverage software to collect entry log requirements for when contact tracing needs to be conducted.

Physical Workplace Procedures and Incident Reporting: Finally, once workplace safety procedures are developed and rolled out, it is critical to set up a process to collect evidence that they are being conducted equally and at all locations. This may include taking records of daily workplace sanitation, employee attestations of workplace policies, evidence of social distancing being followed, inventory management and distribution of Personal Protection Equipment (PPE).

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Steven is a recognized thought leader in risk management, CEO and Founder of LogicManager, and author of the RIMS Risk Maturity Model. Minsky’s prescient leadership guided his customers to success through the 2007 recession, the associated TARP bailouts as well as the H1N1 pandemic of 2009.

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