Manufacturing Work Resumed under Executive Order 2020-77
Governor Whitmer issued Executive Order 2020-77 to extend the duration of the stay-at-home order until May 28, 2020; however, the Executive Order does allow previously suspended manufacturing activities to resume on May 11, 2020, subject to certain minimum safety requirements. This blog describes these safety requirements that manufacturers must follow as to resume business.
Similar to other in-person businesses, operations, and government agencies who are permitted to operate under the current stay-at-home order, manufacturers must provide non-medical grade face coverings to their workers, and comply with the following minimum guidelines:
- Develop a COVID-19 response plan consistent with OSHA guidance. The plan must be available at the business headquarters or the worksite.
- Limit the number of in-person workers to those strictly necessary to perform the work.
- Encourage working remotely when possible.
- Practice social distancing by encouraging in-person workers and patrons to stay at least six feet from one another.
- If six feet of separation cannot be consistently maintained between in-person workers and other individuals in the workplace, masks must be worn, and face shields must be considered.
- Increase standards for cleaning and disinfecting the workplace.
- Adopt cleaning protocol in the event a worker is diagnosed with COVID-19.
- Prevent workers from entering the workplace if they display respiratory symptoms or have had contact with a person diagnosed with COVID-19.
- Adopt CDC recommendations for social distancing and other mitigation measures.
Additionally, manufacturing businesses must also meet these safety requirements outlined in Section 11(k) of the Executive Order:
- Conduct a daily entry screening, including a questionnaire regarding symptoms and potential exposure to people at risk of contracting COVID-19. Also conduct a temperature screening using no-touch thermometers as soon as such thermometers can be obtained.
- Prepare dedicated entry points to facilitate daily screening.
- Suspend non-essential in-person visits to the workplace, including tours.
- Train workers on the following COVID-19 topics:
- Methods of transmission,
- Distance travelled and duration of viability when the virus travels through air,
- Duration of viability on surfaces,
- Notification protocol when a worker presents symptoms, or suspects or confirms a positive diagnosis,
- Preventative measures and response plan consistent with OSHA guidance,
- Rules to prevent exposure and spread of the virus, and
- Proper use of personal protective equipment.
- Reduce congestion in business cafeterias, lobbies, waiting rooms, lines, and other common spaces by closing buffets, require individuals to sit or stand at least six feet apart, offering boxed food, and reducing cash payments.
- Adjust shift schedules to reduce the number of workers in the facility at the same time.
- Stagger start times and mealtimes.
- Separate workstations and cafeteria tables with physical barriers when practicable.
- Minimize personal contact when materials are delivered to the facility.
- Limit the sharing of tools and equipment where possible.
- Frequently disinfect high-touch surfaces, including tools, machinery, and vehicles.
- Discontinue use of hand dryers and ensure sufficient hand washing/sanitization stations.
- Maintain a central log of workers who are symptomatic or have tested positive for COVID-19 and notify plant leaders and potentially exposed individuals of positive cases in the facility.
- Encourage workers to self-report as soon as possible after developing symptoms.
- If a positive case of COVID-19 has been identified in the facility, notify potentially exposed individuals and send them home.
- Shut down areas of the facility for cleaning and disinfecting if a worker displays symptoms of COVID-19.
Manufacturing businesses will need to designate necessary workers to perform start-up activities required to comply with these safety measures. Although manufacturing may resume on May 11, 2020, it can only do so after these safety measures are enacted.
Prepared on May 11, 2020 by HaasCaywood PC