On July 1st, 2021, B.C. progressed to Step 3 of the Province’s Restart Plan. Employers are no longer required to maintain a COVID-19 Safety Plan pursuant to WorkSafeBC requirements. Instead, employers can transition to developing a Communicable Disease Plan (CDP) as directed in a statement by the Provincial Health Officer.
A communicable disease is an illness caused by an infectious agent or its toxic product that can be transmitted in a workplace from person to person. Examples of communicable diseases that may circulate in a workplace include COVID-19, norovirus, and seasonal influenza.
Communicable disease prevention focuses on basic risk reduction principles to reduce the risk of workplace transmission of COVID-19 and other communicable diseases. WorkSafeBC’s Guideline G-P2-21 requires employers to establish fundamental measures with respect to communicable disease prevention at their workplaces, including appropriate handwashing and personal hygiene practices, appropriate ventilation, and staying home when sick.
Guideline G-P2-21: General Measures for Communicable Disease Prevention
Under the new WorkSafeBC Guideline, employers are required to implement the following general measures to address communicable disease prevention to the extent practicable in their workplaces, and communicate them to employees. This CDP does not need to be written, posted, or approved by WorkSafeBC. However, a CDP should be supported by policies, signage, or other materials as appropriate to the workplace and the level of risk at any given time. In particular, employers are required to:
- Implement policies to support staff who have symptoms of a communicable disease (e.g., fever or chills, coughing, diarrhea) so they can avoid being at the workplace when sick. Workers should not remain, or be permitted to remain, at the workplace if they are experiencing symptoms of a communicable disease.
- Ensure hand-hygiene and washroom facilities are readily available, stocked with appropriate supplies, and are kept clean. Employers should use policies and signage to remind workers to wash their hands regularly and to cover coughs and sneezes.
- Maintain a clean environment through routine cleaning processes that are appropriate for the employer’s industry and work practices.
- Make sure building ventilation is adequate and ventilation systems are properly maintained and functioning as designed. Employers (or the landlord as applicable) must comply with sections 4.70 through 4.80 of the Regulation related to indoor air quality. These sections of the Regulation require ventilation systems to be properly balanced, which means verifying that the system meets its design conditions for air flow, temperature, humidity, and other design parameters
- Support employees in receiving vaccinations for COVID-19 and other vaccine-preventable conditions. However, employers should consider workers who cannot be vaccinated. In rare instances, some workers may be advised by their physicians that they should not be vaccinated due to a medical condition, such as a severe allergy to parts of the vaccine. Additionally, employers should be mindful of privacy and human rights laws, and seek advice when implementing policies requiring vaccines in the workplace. For more information on issues that may arise from vaccination policies, please see our February 23, 2021 bulletin, Can Employers Mandate Employees to Be Vaccinated?
Employers are encouraged to put their CDP’s in writing or at least the policies that support the CDP, as this will contribute to the effective planning and communication of prevention measures, practices, and policies. In order to help with this transition, WorkSafeBC has published a 4-step guide and template for employers to follow.
The guide’s recommendations have been summarized below, followed by a brief overview of exposure control plan requirements for certain industries.
Understand the Risk
During a period of elevated risk, the medical health officer or provincial health officer will provide information and guidance about the risk and how employers can reduce it. An employer’s response will depend on the type of disease and the methods of transmission. Employers should monitor and follow all orders, guidance, recommendations, and notices issued by the provincial health officer that are relevant to the employer’s industry, region, or workplace.
Communicate Measures, Practices, and Policies
Employers should ensure that all employees and supervisors are knowledgeable of measures, practices, and policies for managing communicable diseases. This includes workers from other employers who enter the workplace. Importantly, employees should be provided information on policies for staying home when sick.
Monitor Your Workplace and Update Your Plan as Necessary
Employers and organizations should also continuously evaluate and update their CDP’s to reflect changing risk levels and work practices. When identifying and resolving safety issues, involve joint health and safety committees or worker health and safety representatives (or, in smaller workplaces, other workers). Organizations should use workplace inspections and ongoing supervision in the workplace to ensure measures are functioning properly, followed, and maintained.
Exposure Control Plans
In addition to these general measures, employers in certain industries should have historically been complying with additional requirements to develop and implement exposure control plans.
Under section 6.34 of the OHS Regulation and Guideline G6.34-1 “Occupational exposure”, exposure control plans are required in workplaces where there is reasonably anticipated contact with a biological agent that is designated as a hazardous substance in section 5.1.1 of the Regulation. For example, health care workers, lab workers, emergency responders, fire fighters and occupational first aid attendants, are likely to have occupational exposure.
All exposure control plan requirements and a non-exhaustive list of applicable industries can be found here.
Employers must take proactive steps to control the risks associated with communicable disease transmission through the implementation of a CDP. Organizations need to continue to comply with current PHO and WorkSafeBC guidance in determining their particular transition towards implementing CDP’s in the workplace, and then monitor future PHO and WorkSafeBC guidance in line with developments in their workplace and industry. We recommend employers develop their CDP (or at least polices that relate to it) in writing. This will aid in communicating policies to employees, especially on job sites with multiple employers, and in demonstrating WorkSafeBC compliance.