Thursday, March 4, 2021

Temporary Total Disability for Work injury: What will Workers’ Compensation pay?

 Work-related injury not only physical and mental pain, but any resulting disability also raises immediate questions Injured workers and family members often turn to their human resource (HR) and disability management (DM) professionals to provide guidance on workers’ compensation issues.  For the HR or DM professional with clientele in more than one jurisdiction, providing that guidance and setting expectations can be more complicated. The policy alternatives used by other jurisdictions can also inform discussions on workers’ compensation reforms. 


Virtually all workers’ compensation claims involving time away from work are subject to specific provisions for the initial phase of a claim.  For the more than 70% of nonfatal occupational injury or disease cases that involve 30 days or less away from work, the laws and policies governing Temporary Total Disability (TTD) are the only provisions that will determine their compensation for lost wages.   Canadian data is similar with more than 77% of  wage-loss claims off wage-loss benefits at 90 days [AWCBC Key Performance Measure 25.3, Canada, 2017].


[For more on the distribution of days-away-from work for work injuries, see Bureau of Labor Statistics, Table R65: Number of nonfatal occupational injuries and illnesses involving days away from work by days away from work groups and median number of days away from work by industry, (All industry, private industry data) retrieved from   https://www.bls.gov/iif/oshwc/osh/case/cd_r65_2019.htm modified Nov 4,2020]


I get a lot of questions from students and researchers on how workers’ compensation jurisdictions differ in their compensation for the initial period following an injury.  Here are the most common questions and a brief response for each.  In the accompanying slides and in some responses, I provide additional references as a starting point for understanding and comparing initial workers’ compensation.


All workers’ compensation systems pay the same rate for lost wages…right?


No.  How much workers’ compensation a worker receives depends as much on where you claim workers’ compensation as on how much you earn.  If you live in Arizona, you will be entitled to 66 2/3% of GROSS average weekly wages during the initial period of disability, often referred to as Temporary Total Disability (TTD).  In Alberta, the compensation rate is based on 90% of NET.  In the Yukon, the rate is 75% of GROSS while Iowa compensates on an 80% of SPENDABLE earnings (essentially the same as NET).  [Note:  Washington state’s compensation rate varies from 60% to 75% of gross depending on marital status and number of dependent children].


The rate of workers’ compensation stays the same for the duration of TTD in almost every jurisdiction.  In Nova Scotia, however, the initial rate increases from 75% of NET to 85% of NET at 26 weeks following the date of injury.   




Is there a waiting period in every jurisdiction?


No. In Canada, most provinces do not have a waiting period.  New Brunswick has a one-day waiting period but will be eliminating that as of July 1, 2021 leaving Nova Scotia as the only workers’ compensation jurisdiction with a waiting period (two- fifths (2/5) of normal work week). 


In the US, most states have a waiting period but just how big a waiting period varies from three (e.g., California) to seven days (e.g., Indiana).  Most jurisdictions also have a “retroactive period”, a number of days away from work after which the waiting period is reimbursed.  In New Brunswick, that retroactive period is 20 days while in California, its 14 days and in Alaska 28 days.  In a few jurisdictions, the waiting period is not reimbursed (Hawaii, for example). 


Are there any maximum compensation amounts for TTD?


Most jurisdictions have some sort of maximum on the insured earnings or the weekly benefit; the amounts vary widely. [Note:  a maximum on insured earnings creates a maximum benefit that can be expressed on a weekly basis; conversely, a weekly maximum benefit reflects an implicit maximum insurable earnings limit].  


I could find only one jurisdiction with no maximum on insured earnings:  Manitoba.  Alberta had no maximum from September 2018 until December 2020 but set an annual insurable earnings level at $98,700 for 2021; applying the 90% of NET compensation rate, that works out to a maximum weekly benefit of $1250.83. 


In the US, the average maximum weekly benefit is almost exactly $1000.  For the same year, Canada’s average maximum weekly benefit works out to a little less at $1157.50, however, that estimate excludes Manitoba (because it has no maximum).   [2019 data from US Chamber of Commerce, 2019 Analysis of Workers’ Compensation Laws; Canadian data, AWCBC webpage, “Temporary Total Disability Compensation” as of Feb 12, 2021 available at https://awcbc.org/en/summary-tables/benefits-and-rehabilitation/workers-compensation-temporary-total-disability-compensation/ ].  


Is there a minimum compensation amount for TTD?


There is no statutory or regulatory minimum amount of workers’ compensation payable for temporary total disability in most jurisdictions; the amount of compensation for all wage earners is calculated on the percentage of GROSS or NET. This is particularly hard on low wage earners in jurisdictions using GROSS as the basis of compensation. 


Taxation rates are generally “progressive”, in that higher earners are subject to a greater taxation rate than low wage earners.  At lower income levels, no income tax may be payable.  At these levels, a compensation rate of 66 2/3% or 75%  of GROSS effectively cuts spendable income by a quarter to a third.  Workers at the lowest income levels are likely to have the least reserves to make up for any shortfall.  To guard against this, jurisdictions like British Columbia include a minimum compensation provision such as the following:

Earnings between $22,300 and $27,800

If your gross annual earnings are above statutory minimum, but 90% of the average net earnings falls below the statutory minimum of $22,230.72 (or $426.34 weekly), you will receive the statutory minimum.

Earnings below minimum

If your rounded-up gross annualized earnings are below the minimum of $22,230.72 (or $426.34 weekly), you will receive 100% gross average earnings. For example, if your gross average earnings are $280 per week (equating to $14,560 annually), you will receive from us $280 for each week of wage loss.

[ WorkSafeBC, 2021 Net Compensation Table available at https://www.worksafebc.com/en/resources/claims/guides/2021-net-compensation-table?lang=en ]


Once a compensation rate is established, does it remain the same for the initial period of TTD?


Generally, yes but there are some exceptions and provisions for review and adjustment.  The basic idea of TTD compensation is to reflect actual loss of earnings immediately following an injury.  Many jurisdictions have policy provisions to accommodate “actual loss”.  These provisions tend to help workers with irregular work schedules to receive fair compensation for the real loss of earnings resulting from a work-related injury.  Think of a health care worker working three 12-hour shifts followed by two days off; payments based on average daily or weekly earnings may not adequately compensate for earnings lost over a short period of disability. 


A more obvious issues relates to the definition of any “initial period” of TTD.  Many workers’ compensation laws provide for a review of the level of compensation at some point with eight-, ten-, or thirteen- week reviews being common. If the idea is to reflect loss, then the assumption is that losses in the first number of weeks are best reflected by examining the earnings at the time of injury and extrapolating forward.  Earnings “at the time of injury” may be defined as specifically as four pay periods prior to injury (as in Newfoundland & Labrador) or as generally as the average “that best reflects the worker’s actual loss of earnings” (Manitoba). 


As the duration of temporary disability becomes extended, that assumption may need to be revisited.  Beyond whatever review point is chosen, the compensation should reflect the longer-term earnings history and, therefore, the longer term presumed earnings loss due to injury.  Many jurisdictions have procedures for establishing long-term average earnings for the purposes of continues TTD, permanent disability, or economic-loss awards. 


How long is “Temporary”?


Workers’ compensation for Temporary Total Disability generally last for the duration of disability or to the point of maximal medical improvement.  Disability should not be confused with impairment.  Most workers return to work well before reaching maximal medical improvement.  Many can and do work with impairments.  Others may be accommodated or resume work duties with modifications or adaptive devices while still temporarily or permanently impaired.  Workers’ compensation for TTD ends when a worker has (or can) safely return to partial or full duties.  In the case of partial disability, Temporary Partial Disability (TPD) compensation may be paid.   [See graphic in accompanying slide presentation]


There are cases where temporary total disability may be prolonged.  Some jurisdictions limit the duration.  In Florida, that limit is 104 weeks while in Indiana, the limit is 500 weeks; Massachusetts has a 156 week limit and Utah has a 312 week limit.  In Canada, the duration of TTD is often limited by age.  In several provinces, TTD benefits for those over a certain age are limited, effectively limiting TTD compensation to two (or four years in Quebec) after injury.  Age 65, 68 or pre-established retirement age are also considered as possible limits to the payment of TTD. 

 


Are collateral benefits allowed?


The answer to this question varies but a general insurance principle applies.  Insurance is intended to compensate for loss.  Injured workers suffering a temporary total disability should not be compensated to greater than 100% of their lost earnings for a work-related injury.  Workers’ compensation is the  “first payer” so other insurers will want to make sure any workers’ compensation entitlement is paid first.  For this reason, most group short and long-term disability insurance plans will not allow “stacking” of benefits.  In most cases, the effective rate paid by workers’ compensation, given the tax-free status of TTD benefits, will exceed taxable group disability plans provided in whole or in part by an employer.   Certain group disability plans are completely worker funded and may not be taxable.  These plans often provide a lower benefit rate. 


There may be some integration or offset of workers’ compensation in certain cases.  Earnings paid by employers during the period of TTD (sometimes referred to as “top-ups”) may be deducted from workers’ compensation benefits.  In Manitoba, there are specific provision and limits regarding collateral benefits that may result in their full deduction from workers’ compensation entitlements. 


In general, personal or private individual disability plans and disability insurance on personal loans and mortgages are ignored by workers’ compensation but there may be provisions in these plans that take into account workers’ compensation.   Each plan should be examined on its own. 


Are unemployment insurance payments considered earnings?


Most jurisdiction ignore unemployment insurance, but a few workers’ compensation systems will include unemployment insurance (Employment Insurance or EI in Canada) in the calculation of average earnings (for example, Prince Edward Island includes employment insurance; Nova Scotia does not).  In some sectors, this income provides a regular part of earnings and is essential to maintaining a particular workforce in certain sectors.  Check each jurisdiction to be sure.


What about secondary employment?


Between four and ten percent of workers are multi-job holders, deriving income from more than one employment source.  The extent to which earnings loss from secondary employment is covered by workers’ compensation varies.  I cover this in previous blog posts.  Whether you call it secondary employment, moonlighting, or a side-gig, earnings lost due to injury may be covered in the initial stages of a claim. 


Why are the differences in TTD important?


Context matters.   Without understanding how benefits are structured and paid, it is difficult to properly assess relative costs and values of workers’ compensation or any other insurance.  For example, comparing the cost of fire insurance for you home needs to take into account more than the price; differences in the deductible provision, for example, can be a factor accounting for the premium cost differential.


Where can I get comparative data on TTD?

The features of individual workers’ compensation laws and policies are unique to each jurisdiction.  Only a direct comparison from the actual law, policy and jurisprudence can provide a detailed analysis.  That said, there are several credible research reports that provide useful summary information in a comparable format.  I’ve included a brief presentation that highlights four sources, some of which provide free public access.  Some sources may be available through member organizations or libraries. 

 

Association of Workers’ Compensation Boards of Canada, AWCBC.org,  
Workers’ Compensation – Temporary Total Disability Compensation


US Chamber of Commerce,  USCHAMBER.com, Analysis of Workers’ Compensation Laws


National Academy of Social Insurance, NASI.org, Workers’ Compensation: Benefits, Costs, and Coverage


Workers’ Compensation Research Institute, WCRInet.org, Workers’ Compensation Laws

 







Sunday, January 31, 2021

What comes after the pandemic’s peak? Six trends, three predictions and one sure thing

    The end of the COVID-19 pandemic is not here—not even close.  In many jurisdictions, second-wave peaks in new infections, hospitalizations and deaths are yet to come.  The possibility of a third wave looms as new, more infectious variants emerge.

    The workers’ compensation impacts are only just beginning to be felt.  Direct COVID-19 work-related illness, disability, and death claims are rising in number; psychological injury claims for front-line healthcare and other essential workers are also on the rise.   The disparities across jurisdictions in claim acceptance rates, timeliness, and benefits are becoming more evident.  Non COVID-19 cases are suffering delays in treatment and economic disruptions are resulting in longer periods of disability until a return to work is possible.  Longer claim durations can contribute to worse outcomes for workers and costs for employers.

    Hygiene, safety plans, and personal protective equipment issues have grown in priority for occupational safety and health inspectorates and prevention agencies.  Inspectors themselves are working in difficult times and with unfamiliar risks.  Keeping themselves safe while ensuring protections are in place for workers and others in the workplace is a markedly changed objective in the altered reality of 2021. For industry and labour services providing OH&S education and promotion, COVID-19-specific messaging is one challenge; reaching intended audiences without seminars and conferences is another.

    The COVID-19 pandemic is behind some emerging workplace trends that will impact the workplace for years to come.  No one knows for sure where these trends will lead; some predictions are possible based on past experiences and current trajectories.  One thing’s for sure, this is not the last time something like the COVID-19 pandemic will impact our workplaces.


Six Trends

1.       Working from home is now mainstream… for some:  The proportion of workers working from home some or all of the time has increased and will continue to be a significant segment of the workforce. During the pandemic, garages and attics have become office spaces and dining room tables commandeered as workstations.  Many workers who once lived close to the office to avoid the long daily commute have opted for the larger residential spaces offered in the suburbs and rural areas and are commuting less often to the corporate. Workplaces have adapted but the new arrangements may test traditional boundaries for occupational safety and health and workers’ compensation.  How much say, if any, should an employer have over ergonomics, ventilation, or safety of a home office?  Is the commute from the home office to the corporate office a work journey? What protocols do you need to investigate work injuries and workers’ compensation claims in the home workplace? The questions are growing as the work-from home trend continues.

2.       Impermanent workplaces and shared workspaces are increasing: “The Workplace” used to be synonymous with a specific location under the control of the employer.  There were always exceptions; truck drivers take their workplace with them and field technicians have workplaces in every site they visit.  We used to joke that the local coffee shop was the “corporate office” for many small companies.  I know of firms that have no corporate offices at all; they work virtually most of the time and rent office spaces or hotel rooms as needed.  Fully equipped office spaces complete with highspeed internet, secure teleconference services, boardrooms and even coffee service are available by the hour, day, or week as needed.  Individually incorporated professionals such as massage therapists and psychologists share independently run office space and even some support staff.  Virtual, asynchronous or simultaneous use of workspaces blur the lines of accountability and even liability.  Who has responsibility of health and safety issues?  Will there be an increase in third party claim considerations?  The reconceptualization of the workplace will continue and become a more significant concern.

3.       Mask-wearing is becoming a social norm…in most of the world:  As someone who [used to] spend a lot of time in airports, on airplanes and traveling on public transit, I was somewhat used to seeing a few face masks on my fellow travelers and in lecture or seminar audiences. There was not a lot of science about the efficacy of mask wearing as a means of infection control but that has changed.  For the coronavirus that causes COVID-19, the scientific evidence is now conclusive:  masks are effective in preventing the spread of this disease, more so in protecting others than the wearer but with some protection for the wearer.  That trend towards normalizing mask-wearing in public spaces and private workplaces will continue.  When this pandemic wanes, daily mask wearing will be more common and more accepted.  Should mask wearing become mandatory in certain workplaces or situations?  Should masks be an employer-supplied piece of PPE?  What mask standards should apply to which workplaces?  

4.       Work environments are being built, rebuilt, and retrofitted with infection control in mind [not top of mind, but in mind]:  Those plexiglass barriers you see everywhere are not all temporary.  Ventilation systems with advanced virus and bacteria killing technology are not just a passing fad.  Lighting systems with safe UV frequencies may not be commonplace but are being retrofitted in some places and designed in new builds.  Even the hastily installed take-out windows in many restaurants are likely to persist.  New HVAC and air conditioning systems that kill bacteria and destroy viruses are now in the marketplace.  The hastily installed barriers on some production lines are likely to persist and there is a good chance that the next iteration of design will integrate these and other new features to protect workers and others in the workplace.  Will improvements in the built environment be enough?  Will there be standards that create an even playing field or will this trend fade under cost pressures?

5.       “Burnout”, mental injury, stress—real consequences of the pandemic—are taking an increasing toll:  For decades, workers’ compensation has been slow to accept any aspect of work as causative of mental injury or illness.  With the high toll of mental exhaustion, breakdown and even suicide among caregivers, the underlying work-related causes are impossible to ignore.  Healthcare workers are the most obvious victims, but others suffer mental injuries including depression, mental exhaustion, and post-traumatic stress disorder (PTSD).  Workers’ compensation legislators and policymakers are adapting.  While some are doing so by exception, executive order, or limited presumptions, others are applying existing policies, setting new procedures that will persist and apply more broadly. What will the policy landscape look like after the pandemic passes?  Will the growing acceptance of mental injury translate into greater numbers of claims?  Will the responsibilities employers have for prevention of mental injury change or become more prominent? 

6.       Disruptions/distortions in labour markets and the economy continue:  When the pandemic began, the distorted market for PPE, nasal swabs and even toilet paper quickly dominated news coverage.  Supply chains took time to adjust.  Manufacturers shifted from making car parts to respirators and from distilling vodka to producing hand sanitizer. The shift toward online commerce and home delivery exploded during the pandemic, accelerating a trend in play before the pandemic. Storefronts on main streets are shuttered but massive distribution centres are burgeoning.  Nothing happens instantly and the lag-time resulted in shortages—including shortages of trained and qualified people.  Knowing what is needed in terms of labour is far different from having the people and skills available.  Medical professionals from nurses to respiratory technicians were already in short supply in many areas and still are just as demand for these skills rose.  Shortages of qualified personnel are making the decision between staffing COVID-19 testing programs, contract-tracing operations or vaccination centres a real challenge.  Which should be the priority?  How will workers’ compensation deal with the distortions caused by overtime, bonuses and incentives in the COVID-19 period.  Will disability or earnings-loss policies–already a difficult area—have to change to adequately reflect loss in case of injury or illness?  How will those suffering long-term physical or psychological effects of this pandemic be identified, supported and accommodated in a shifting and uncertain labour market be accommodated?


Three Predictions

1.       “Immunity passports” will be a common requirement… for a while:  If you are of a certain age, immunization travel documents like these may be familiar.  Commercial airline staff and merchant mariners had to have them; other travelers were advised to carry.  These were essential for entry into certain countries.  Proof of immunization will be a requirement again just as proof of a negative COVID-19 test is now a requirement for many air travelers. “Immunity passports” may be formally discouraged by certain governments, considered by others, and debated in journals.  Regardless of governmental views or what you call them, functional immunity passports will be required in many workplaces. Whether they take the form of a printed book, electronic record, or wallet card, workplaces are going to have a need to know who has been vaccinated and who might be at elevated risk if they are not.  There will be questions about an employer’s right to require vaccinations or a workers’ right to refuse vaccination.  Workers and other persons (such as passengers seeking to board a cruise ship) will be required to present evidence of their immunity either by vaccination or another means.  In the ramp up to universal vaccination, there will be challenges.  If a single vaccination series provides long-term immunity, if the virus does not mutate too quickly, or if the virus is extinguished for lack of susceptible individuals, the need for immunity passports will vanish… but those are a lot of ifs. 


2.       Presenteeism will persist…with risks:  For years, efforts to reduce absenteeism in the workplace have focused on the outcome with little differentiation in strategy for disease.  The laudable goal of an early and safe return to work following an injury blended with the idea that anyone with any reason for being absent should make the effort to return to work as soon as possible.  The systems in place to penalize absenteeism and reward or applaud staying at work do not differentiate well between injury and illness due to infectious diseases.  The resulting presenteeism in the COVID-19 case is the source of many workplace outbreaks, particularly in congregate settings (prisons, care homes) and production lines (poultry and meat processing plants). The general duty of employers to protect workers from illness has not been well understood, promoted or enforced. The nexus between work and illness is often obscured in the case of disease but that is changing.  DNA sequencing and contact tracing make the “work-relatedness” of infection clear in many instances.  COVID-19 has taught us the need for a different strategy when it comes to workplace disease.  Presenteeism will continue but its drivers and circumstances will get closer review.  It may not mean universal paid sick leave but the incentives and penalties regarding illness in many workplaces will have to be re-examined and managed differently.

3.       Disaster Management, Business Continuity, Contingency and Succession Planning will be ascendent … for a while:  There are lessons to be learned from this pandemic. Will we learn them?  There is a good chance we will, but a strong likelihood the lessons learned will fade.  It will take time and research dollars to parse knowledge from the COVID-19 experience, but it will also take organization will translate that knowledge into plans and actions.  That will happen… in some organizations… for a while.  For a time, business continuity planning will be in the ascendency.  Stockpiles of PPE will be replenished and kept up to date; responsibility and accountability will be assigned at a high level; plans, policies and procedures for various outbreaks and pandemics will be developed and revised; and outbreak and pandemic scenarios will be incorporated into contingency plans…until they are not.  One lesson we learned from this pandemic is that despite the warnings in environmental scans and the near misses of H1H1, SARS, and other diseases, any heightened awareness wanes.  Costs rise, responsibility fragments, budgets get cut.  Disaster management and business continuity planning priorities get diluted and marginalized to job description lines just before “other related duties”. I don’t see that changing in the longer term.


One sure thing

    This is not the last pandemic.  This pandemic is not “the big one”. 

    Do not confuse statements like “this is a once in a hundred-year event” with the idea that a pandemic happens just once in a century.  We may be a day, a month, or a year away from the emergence of another, even more infectious disease, and an even more devastating pandemic.  Will we be ready for the next pandemic if it is as infectious as measles and as deadly to children as COVID-19 has been to the elderly?

    COVID-19 exposed our lack of preparedness.  Our failings are not due to a lack of imagination.  Every corporate planning exercise I was involved in over the last few decades listed the risk and even assessed the impact. Unfortunately, the immediacy of other threats often narrow leadership focus and divert organizational resources. Expertise is lost in the name of streamlining, budgets tightened, and stockpiles depleted or aged out of usefulness. 

    The human and economic costs of this pandemic are consequences of our past failures to consistently invest in science, plan for pandemics, and expend resources in preparation for what we know is coming.  

    Another pandemic is inevitable. Being ready for one is a choice.  Hopefully, a choice workplaces are willing to make.  

Tuesday, December 1, 2020

Are work-related COVID-19 cases fully reported, counted and paid by workers’ compensation?

 

COVID-19 has been infecting, disabling, and even killing workers in the course of their employment.  Healthcare workers, first responders, cleaners, grocery clerks and other essential workers are put at elevated risk of COVID-19 infection because of their work.  Despite precautions and COVID-19 safety plans, work-related COVID-19 infection are a significant proportion of the overall infection count… and may be under-represented for a variety of reasons.





Many workers contracting COVID-19

Public health agencies investigate the likely source of infection as part of their contact tracing efforts to stop the chain of transmission and contain the COVID-19 virus.  In British Columbia, for the period September 13 to October 26, workplace settings accounted for more than 10% of COVID-19 local case/cluster settings. [Derived from BC CDC, COVID-19: Monthly Update November 12, 2020, Slide 9 https://news.gov.bc.ca/files/COVID19_Monthly_Update_Nov_2020.pdf]


In a recent report, the British Columbia Centre for Disease Control states:


1 in 10 individuals who had COVID-19 identified as a health-care worker


[BC CDC, COVID-19: Monthly Update November 12, 2020, Slide 10  Https://news.gov.bc.ca/files/COVID19_Monthly_Update_Nov_2020.pdf]


While not all those identifying as healthcare workers may have contracted the disease because of work, there is no question that essential workers are at elevated risk.  The number of claims received from healthcare workers  alone is about 70% of what the public health data of COVID-19 test-positive healthcare worker count suggests. [ Based on WorkSafeBC COVID claims data by industry as of November 11, 2020 as numerator and BC CDC, COVID-19: Monthly Update November 12, 2020, Slide 10 https://news.gov.bc.ca/files/COVID19_Monthly_Update_Nov_2020.pdf  as denominator]


In another recent report, the CBC contacted all provincial workers’ compensation boards in Canada to determine the number of workers’ compensation claims from workers for work-related COVID-19. As of mid-November, 26,107 claims had been submitted and 20,140 claims allowed so far this year.  Given that Canada reported 335,000 cases of COVID-19 over that same period, just under 8% of all reported COVID-19 cases resulted in a workers’ compensation claim.  [CBC, Workplace compensation claims reflect toll COVID-19 has taken on Canada's workers, November 23, 2020 https://www.cbc.ca/news/canada/covid-compensation-wsib-wcb-workers-1.5810305]


Workers’ compensation claims for COVID-19 lag public health data

It takes time to consider and determine the “work-relatedness” of a workers’ compensation claim.  Although nearly 80% of claims reported have already been allowed, the ultimate acceptance rate may well be higher. 


Timing is not the only complication.  In some cases, a claim may be submitted but with no costs for income loss, medical or other expenses received. Depending on the jurisdiction, such a case might or might not be considered “reportable” to the workers’ compensation or occupational health and safety agency.  That said, the employer or the worker may want to file a claim because of the uncertain consequences of a COVID-19 infection even if there is no interruption in earnings, no medical expenses, and no resulting permanent disability so there is no further action required.  This sort of situation is captured in claim statistics detail from WorkSafeBC:

 

Eligibility Decision by WorkSafeBC to November 11, 2020

Allowed                                506

Disallowed                           733 

No adjudication required   49                                  

Pending                               197

Rejected                                  4                         

Suspended                         100                 

Total                                 1,589

                                                       


As evident in these data, not all reported workers’ compensation claims are accepted.  Many may be disallowed (determined not to be work-related, for example) and some rejected (not a “worker” as defined by the legislation, for example).  Even in jurisdictions with presumptions for some categories of essential workers, there may be evidence to rebut the presumption.   


Even if all new COVID-19 exposures were to magically end tomorrow, the number of workers’ compensation cases filed and accepted may continue to rise for years to come.  Workers have time to file claims and contested cases may subsequently be allowed on review or appeal.  In some cases, consideration is delayed while medical records and tests are obtained.  This means that the eventual claim counts and costs related to COVID-19 occurring in 2020 may not be fully known for many years to come. It also means that current proportions like those noted here understate the ultimate level of workplace COVID-19 impacts.


Workers’ Compensation for COVID-19 infection are being allowed

When this pandemic began, many questioned if workers’ compensation agencies would accept any COVID-19 infections injury or disease claims as work-related.  From data being reported in Canada, the US and Australia, a substantial proportion of COVID-19 worker’s compensation claims are being accepted.


In Quebec, where almost all workers are covered by workers’ compensation, submitted claims represent 10% of the provinces 133k reported cases of COVID-19; nearly 90% of claims submitted so far have been allowed in that province.  Ontario, where about 70% of the working population is covered by workers’ compensation shows about 7% of cases are represented in the submitted claim category with a 76% allow rate to date.


Alberta Workers’ Compensation Board reports 3,209 COVID-19 claims received, 2,164 accepted, 646 rejected and 399 are either pending or under review. Interestingly, most claims were from the manufacturing sector, related to meat processing plants in that province. Claims received would be just under 6% of reported COVID-19 cases in Alberta. Nicole Stillger, “Over 3,200 COVID-19 claims made to Workers’ Compensation Board of Alberta since March, Global News, posted November 29, 2020, https://globalnews.ca/news/7491453/alberta-workers-compensation-board-covid-19/


Washington State experienced 80,465 confirmed cases of COVID-19 by September 14, 2020.  https://www.seattletimes.com/seattle-news/health/coronavirus-daily-news-updates-september-15-what-to-know-today-about-covid-19-in-the-seattle-area-washington-state-and-the-world/.  The state’s safety and health research agency report 3836 submitted claims (with an 83% allow rate) and 3488 claims as a result of quarantine coverage covered in that state by the same date.  [See https://lni.wa.gov/safety-health/safety-research/files/2020/64_20_2020_wcCOVID_Nov.pdf ]. The claims submitted represent nearly 5% of the total COVID-19 cases reported in the state over that time frame.


SafeWork Australia reported that by July 31, 2020 533 workers’ compensation claims had been lodged with jurisdictional authorities (about 3% of all COVID-19 cases reported in Australia).  Up to that date, nearly half had been accepted (253) and a substantial number pending (185).  It should be noted, however, that claim counts reported in this context include mental health and testing or isolation circumstances and not just test-positive work-related claims.  https://www.safeworkaustralia.gov.au/sites/default/files/2020-11/COVID-19%20Infographic%20-%20Worker%27s%20Comp%20Claims%2031%20July.pdf


Work-related COVID-19 infection is higher than workers’ compensation accepted claims

The work-related incidence of COVID-19 may be much higher.  Not all workers are covered by workers’ compensation.  Others may be covered but unaware of their right to workers’ compensation.  Still others may be directly or indirectly discouraged from filing a workers’ compensation claim. 


The proportion of workers contracting COVID-19 in the course of their employment may also vary with the nature of their work.  Prison guards, food processing plant workers and long-term care aids are among the most likely to have the disease passed to them because of the close congregation of workers and of workers to others in frequent close contact.  This is particularly likely when the virus is spreading in the community. If the virus is in the community, chances are someone (worker, visitor or other person) will become infected and introduce the virus into the workplace.  Fraser Health recently published an excellent example in this poster:

 




How many workers’ compensation claims arose from this real-life example?  I asked the workers’ compensation authority that question and was told they were not privy to the information used by Fraser Health to develop the example.  The lack of data sharing between health authorities and workers’ compensation insurers may contribute to the under-representation of work-related COVID-19 cases in statistics.  I’m not saying that public health should adjudicate workers’ compensation claims.  What I am saying is that the public health determination that a COVID-19 test-positive case likely occurred at work is important evidence that should be available to those adjudicating workers’ compensation claims. 



Direct COVID-19 infections are only one category of workers’ compensation claim

COVID-19 case counts should not be considered as the only work-related consequence of this pandemic.  I’ve spoken with workers in health care; many are stressed to near the breaking point.  Work-related psychological injuries are occurring now and are likely to be a growing feature of future workers’ compensation claims experience.


Some essential workers are exhausted.  With staff shortages, many are being called to work double shifts, longer hours, and expanded duties.  Even the simple comforts families could offer the severely ill and dying must now be offered by workers… and that, too, takes a toll. 


Photos of chapped and swollen faces from long hours wearing N-95 masks are common.  Healthcare workers have spoken of hands breaking down from repeated washing and sanitization.  Images of medical staff in despair and reports of suicides from their ranks are a growing concern. Dermatitis, depressive reaction and PTSD may not be direct consequences of COVID-19 but they are real injuries; if work-related, then workers and their families should be compensated.


Except for the Australian data, I could not find current statistics on the incidence or prevalence of psychological or mental health claims for workers’ compensation related to COVID-19.


Final comments

A few jurisdictions such as WorkSafeBC are reporting statistical data for COVID-19 cases.  Jurisdiction such as Washington State that cover quarantine for some occupations are reporting these data separately but are clearly tracking cases in this regard.  It is not clear which jurisdictions are comprehensively collecting and reporting data on workers’ compensation COVID-19 claims, claim types, claim status, or costs.


What is not being reported in most jurisdictions are the indirect COVID-19 cases.  We are barely 8 months into the COVID-19 pandemic declared by the World Health Organization on March 11, 2020.  PTSD has a “delayed specification” of six months, so, formal assessment and diagnosis can’t happen in real time.  It will be years before we know the human and financial costs of COVID-19 in the workplace.  Reporting on cases of PTSD related to COVID-19 is just one example of the sort of data that needs to be collected, tracked,  and made available as soon as possible.   


This is not just about money and who should pay for work-related case.  Timely workers’ compensation data is necessary for prevention, targeting interventions and making workplaces safer right now and in years to come.


If we are to ever understand the real human and financial costs of this pandemic, we need to be identifying and tracking cases now.  We need to understand any disparities between the work-related COVID-19 cases identified by public health and the cases reported to occupational safety and health or workers’ compensation authorities.  This is not a trivial task; however, it is essential if we are fully acknowledge these costs, learn from this pandemic… and prepare for the next one. 

Saturday, November 14, 2020

What keeps workers safe from COVID-19?

 

Workplaces address  COVID-19 infection risks by highlighting the hazards and implementing a hierarchy of controls.   Observing the strategies and tactics workplaces are actually using  can provide valuable insights and examples.





Science informs workplace safety and health.  Proven measures in the fight against COVID-19 include: physical distancing,

  • frequent hand washing,
  • not touching your face,
  • wearing a mask,
  • avoiding crowds, and
  • sticking to your immediate “bubble”.


The point of these measures is to keep concentrations of virus out of your airways where the disease takes hold.  


Everyone wants this COVID-19 infection threat to go away.   Until this hazard is eliminated, employers are required (by occupational safety and health authorities, public health orders, and the moral imperative) to protect workers and other persons in the workplace.  In the context of the COVID-19 pandemic, that means active measures to eliminate the workplace hazard or mitigate exposure and infection risk.


The Common Objective

Workplaces share a common objective in this pandemic: 

Prevent workers from contracting COVID-19 virus. 


Workers and other persons in the workplace are at increased risk when they occupy the same workspace, are in close proximity to others, or have contact with contaminated surfaces. 


“Close proximity” is a general term and not the same as the “close contact” term used by public health officials.  Just because you have been in close proximity to others does not make you a “close contact”.


Health Canada, for example, defines close contact for COVID-19 this way:

Close contact: Breathing in someone's respiratory droplets after they cough, sneeze, laugh or sing. [see Health Canada, Coronavirus disease (COVID-19): Prevention and risk] 

For contact-tracing purposes, the CDC uses the following definition of close contacts:

Someone who was within 6 feet of an infected person for a cumulative total of 15 minutes or more over a 24-hour period starting from 2 days before illness onset (or, for asymptomatic patients, 2 days prior to test specimen collection) until the time the patient is isolated. [See CDC, Contact Tracing Plan, Appendix A]


Close-proximity encounters may not meet the formal definition of “Close-contact” but being near enough to someone to potentially breath in their respiratory droplets does create a pathway for transmission.  Interrupting those transmission pathways is the priority. 


From research, experience, and incident investigations, we know this virus is most often transferred person-to-person by respiratory droplets (generated when we speak, sneeze, cough, sing, shout, laugh or talk); surface-to-person transfer of the virus occurs to a lesser degree and effectively controlled with sanitation and hygiene. Reported contact-tracing results have focused on person-to-person chains of transmission as the most common pathway.  Most workplace COVID-19 safety plan strategies and tactics are focused on this priority.   

 

Common Strategies

Workplaces are following eight main observed strategies:

       Keep workers FAR from hazard

       Distance workers and others from each other

       Reduce potential viral presence in workspace

       Eliminate close spatial contact

       Stop droplet exposure risk (non-medical settings)

       Stop droplet and viral particle transmission (medical and similar settings)

       Control close-proximity encounters

       Actively limit chains of transmission


This is not an exhaustive list and few organizations rely on just one strategy.  That said, each strategy has its own rationale, and each workplace develops or selects tactics that work best for that workplace. 


Observing the tactics—and how well they are implemented—illustrates what can be done to minimize workplace risks amid this pandemic. 


Strategy 1:  Keep workers FAR from hazard

If you live alone on an island, you have no direct risk of exposure to the virus.  Life is generally not like that; however, creating islands or “bubbles” that keep occupants far from the virus is a valid strategy that has been implemented with some success.


Work-from-home policies are now commonplace.  Working and living in your own bubble far away from potential sources of infection works well.  The recent National Hockey League (NHL) and National Basketball Association (NBA) playoffs demonstrated that large bubbles can also work.  On a smaller scale, the Villanova Nursing home is a great illustration of how bubbles in the healthcare sector.


The Vilanova nursing home - How workers and staff avoided the first wave

As the first wave of the virus swept across Europe, a nursing home in France locked down.  Over the next 47 days, 29 of the staff of 50 stayed with the residents day and night, sleeping on mattresses on the floor.  Other staff who came from the outside to assist were kept separate from the sequestered staff and residents; they also wore PPE.  In the beginning, residents were confined to their rooms while staff did a deep clean of the facility.  After that, the staff and residents mixed freely, maintaining morale and the mental health of all concerned.  [See The Associated Press, “How a nursing home in France stopped coronavirus from killing elderly in its care”, May 04, 2020 available at https://www.cbc.ca/news/world/france-vilanova-nursing-home-1.5554296 ]


Broken Bubbles:  The Melbourne Outbreak

Bubbles can work both ways:  to keep uninfected people in and to keep infected people from contacting others. Victoria, Australia is currently experiencing a second wave centred in and around Melbourne, the state’s largest city.  Beginning in May 2020, foreign visitors were required to quarantine in specific hotels for two weeks.  The mandatory quarantine was enforced by contracted private security guards.  The bubble in this case was for quarantined individuals. Within weeks, COVID-19 had spread in these locations among guests and the staff and guards charged with maintaining the quarantine.  Gene sequencing of the virus that has now spread widely in the state traces the origin back to the quarantine hotels.  The exact exposures that resulted in infection have not been formally reported but lack of training, lack of PPE, inadequate hygiene, breaches in protocols have been mentioned as probable contributing factors.  The premier of the state cited the sharing of a lighter among security guards and certain “carpooling” arrangements as examples that contributed to the outbreak, although more fundamental issues such as work insecurity and lack of clear lines of responsibility likely contributed.  [See   Ben Schneiders, “How hotel quarantine let COVID-19 out of the bag in Victoria,” The Age, July 3, 2020 at https://www.theage.com.au/national/victoria/how-hotel-quarantine-let-covid-19-out-of-the-bag-in-victoria-20200703-p558og.html]. 


[Note:  Australia clamped down hard on this outbreak.  As of this writing, no or very few positive COVID-19 tests are being recorded]


Like all the strategies for keeping workers safe, success is dependent on how well the supporting tactics are implemented and maintained. Maintaining bubbles is hard.  Staying home or working from home is hard.  Necessities such as groceries and medical attention may be sought remotely; realistically, most of us need to physically leave our homes for many purposes. Each time the bubble is breached, the risk of infection goes up.  That applies to everyone in the bubble.  Keeping bubbles small makes them more manageable but each time anyone in the bubble interacts outside the bubble, everyone in the bubble has increased risk.


Working-from-home policies do not fully insulate employers from workers’ compensation liability.  Work-related risks may still exist for every worker carrying out work, including COVID-19 infection risks and other risks associated with working from home, (e.g., workers’ compensation claim  by a worker who was injured while carrying personally acquired office furniture upstairs at home for employer approved work-from-home setup was allowed [State of New York Supreme Court, Appellate Division, Third Judicial Department,  530530, October 22, 2020].  Each time I open the door to sign for a courier delivery or leave my home to get work supplies, I am also opening the door to an interaction that carries risk.


Strategy 2:  Distance workers and others from each other

Keeping workers far from the virus is not a practical strategy for many workplaces.  Despite voluntary and ordered closures in many communities, enterprises deemed “essential” have remained open. Fire fighters, healthcare workers and police officers are universally accepted as essential. In my community, the list of essential businesses includes local hardware, drug, and grocery stores.  Many non-essential businesses including construction and retail have continued to operate during the pandemic (albeit with some restrictions). 


The main strategy implemented to keep workers safe in these environments are designed to distance staff and patrons.  In the local hardware store, the counters were widened overnight with improvised plywood sheets to ensure patrons and service staff had a six-foot or two-meter distance between them.  Monitors were in place at the grocery store to ensure capacity never exceeded the allowed set number.  Tape on sidewalks and markers on floors guided customers to maintain distances.  Directional arrows ensured aisles would not become congested (at least not with people facing each other and forced to pass within the required distance). 


Capacity limits may be mandated by public health.  Many restaurants and retail spaces are small and capacity limits are needed to allow for spacing between staff and patrons. 


Again, this strategy and associated tactics require active monitoring to be effective.  Coupled with other strategies and tactics, the risk of infection can be reduced.  The more space between workplace participants, the greater the protective effect.


Strategy 3:  Reduce potential virus presence in the workspace

Even with distancing methods in place, staff and other persons in the workplace may still be infected with Covid-19 and shedding the virus (often unknowingly while asymptomatic or pre-symptomatic). One observed tactic now in many workplaces is the presence (or increased presence) of sanitation stations.  At one roadside construction site, I saw a sink had been installed to a fire hydrant so workers could wash with soap and water more readily.  Several retailers have put hand-sanitizing stations throughout their stores.  The number of staff performing spot cleaning and sanitation duties is observably higher than ever.  In several large retailers, frequent public address system announcements to staff direct them to specific tasks like sanitizing their workstations or breaking to wash their hands.


The added costs of these measures are minor compared to the costs of lockdowns.  When outbreaks do occur, “deep cleaning” and sanitation of the workplace are implemented to further reduce the potential for any further infection even if surfaces were not the obvious or immediately identified source of infection.  In our community, the few incidents observed have resulted in short closures and a resumption of activities within a day. 


Visible signs of increased sanitation efforts and well stocked sanitation stations for customers certainly increases my willingness to visit certain businesses during the pandemic. That said, this strategy focuses on things, not people; it only works with other preventative efforts including distancing. 


Strategy 4:  Eliminate close spatial contact

Wider counters and capacity control tactics can distance workers from others in the workplace but much of service, sales and administration involves in-person contact.  A key strategy is to reduce the close spatial “pinch points” and hand-offs that are often required.  Home delivery and curbside pickup are common tactics that has been implemented to eliminate spatial contact.  Orders are placed online or over the phone and payment pre-arranged; patrons arrive and pick up orders already at or orders are delivered to the curb or doorstep. Restaurants, office supply houses, and petfood stores are among the stores in my neighborhood who have implemented these tactics. 


Our local library has implemented another similar tactic: choreography.  each patron approaches an outside window and holds their library card to the glass; a staff member scans the barcode from inside the library, retrieves the books and DVDs requested online.  Next, the patron steps back and the staff member places the order outside the door on a table then returns inside, allowing the patron to then come forward to retrieve the items being loaned.  This dance may be inefficient in terms of time but completely effective in eliminating close spatial contact. By the way, the staff member (wearing mask and face shield and sitting behind plexiglass) manning the door also asks each patron wanting to enter the library a set of COVID-19 questions, ensures mask use, and directs hand sanitization upon entry to the library.     


Eliminating close spatial contact works well for transactional operations.  When UPS recently delivered our new tablet, they skipped the signature requirement in order to eliminate the close spatial contact needed to sign the electronic delivery tracker.   Process design changes like these are likely to continue.  There may be some loss of service opportunities, queuing issues and time efficiencies of in-person close spatial contacts as a result of these tactics.


Strategy 5: Stop droplet exposure risk (non-medical settings)

The Covid-19 virus is primarily spread in respiratory droplets.  Well-fitting, non-surgical masks covering mouth and nose have been proven to reduce droplet transmission from the wearer and there is some evidence that they limit droplets from being inhaled by the wearer.  [see, “Scientific Brief: Community Use of Cloth Masks to Control the Spread of SARS-CoV-2”, CDC, Updated Nov. 10, 2020].


Facial shields prevent droplet splashes or projections from a cough or sneeze from reaching the wearer’s face (eyes, nose and mouth in particular).  Plexiglass and suspended plastic shields have a similar effect, and their height and width add distance between the point of droplet generation and possible exposure.  This does not remove the risk entirely. 


We know indoor spaces and spaces with poor ventilation allow droplets to travel further and remain afloat in the air longer than in outdoor spaces.  Increasing the ventilation by opening a window or changing external air mix in HVAC systems may be options (although more costly particularly in the winter season).  The US Environmental Protection Agency notes:


By themselves, portable air cleaners and HVAC filters are not enough to protect people from the virus that causes COVID-19. When used along with other best practices recommended by CDC and others, filtration can be part of a plan to protect people indoors. [see Air Cleaners, HVAC Filters, and Coronavirus (COVID-19), EPA webpage]

 

Tactics that rely on physical barriers degrade communications often required between workers or workers and others in the workplace.  In my community, I have seen both customers and employees bypass the barrier and work around the edge to speak with each other, thus defeating the purpose of the barrier.   


Again, this strategy does not work on its own.  Sanitation of barriers, capacity limits, and other measures are important. 


Strategy 6: Stop droplet and particle exposure risk (medical and similar settings)

Testing for Covid-19, transporting patients with the virus, and caring for them in hospitals and intensive care units are obvious examples of situations with elevated risk of infection.  In an environment with high potential for viral infection, more protections are needed.  Nurses, respiratory technicians, physicians, cleaners, and care aides put themselves in these high hazard environments every day. 


In a sea of known COVID-19 virus, stopping droplets and particles is hard.  The PPE, safe work procedures, supervision and training are among the most effective safeguards, barriers and defenses for keeping healthcare workers safe.  It is not just an N95 mask or a facial shield that achieves the objective; protection is achieved by multiple layers.  Each layer of protection has value but is not perfect. James Reason’s classic “Swiss Cheese” model provides an accessible, memorable metaphor for understanding how multiple layers work.  Active and latent defects occur in every barrier, but the multiple layers reduce the probability of these gaps aligning in such a way as to allow the virus to infect the worker. 


Just because there is a pandemic doesn’t mean that the rest of life stops.  People need blood tests, dental work, physiotherapy, and a range of medical and similar services that can only be given in close-contact care.  The risk in each situation must be assessed.  In many cases, several items of PPE may be required.  Achieving a safe work situation requires more than the provision of PPE.  The right PPE, supervision, training and safe work procedures are essential in these medical and similar workplaces.


The CDC includes consideration of increased ventilation and filtration in its guidelines for healthcare:

Optimize air-handling systems (ensuring appropriate directionality, filtration, exchange rate, proper installation, and up to date maintenance)....Consider the addition of portable solutions (e.g., portable HEPA filtration units) to augment air quality in areas when permanent air-handling systems are not a feasible option.

[Interim Infection Prevention and Control Recommendations for Healthcare Personnel During the Coronavirus Disease 2019 (COVID-19) Pandemic, CDC Updated July 15, 2020].


This strategy, like the others, has its limits.  It cannot stop workers from being exposed outside the work environment.  Reported cases of workers infecting each other in breakrooms and social events among their peers illustrate some of these risks. 

 

Strategy 7: Control close-proximity encounters

Close-proximity encounters with customers and co-workers are often unavoidable.  Passing people in a corridor, cooperating in a lift of a heavy object, or handing a receipt to customer involves close- proximity interactions.   Most such interactions are fleeting; risk increases with increased duration and closer positioning. 


Despite rules, procedures, and efforts to prevent them, close-proximity situations arise.  This is particularly true in manufacturing, construction, fabrication, personal services, and processing tasks where multiple workers must work closely for periods of time. 


After considering and implementing PPE and procedures, some companies are implementing technologies to help lessen the number and duration of close-proximity contacts.  Proximity sensors and apps on cellphones can alert workers when they are in close proximity to others.  Several sensors are in the form of wearable disks or tokens that provide light and/or sound cues when workers are within defined distances.  Enhanced versions can also track the identities of the participants and even their locations during encounters—factors that could be useful should the need for contact tracing arise. 


Several token-based products are directed more at industrial applications such as food processing and equipment manufacturing.  Safeteams technology implementation requires each employee to be issued a wearable fob.  The fob emits a light cue if a worker is near another worker.  “Beacons” installed in the workplace periodically communicate via Bluetooth allowing for mapping and contact tracing.   [See Mary George, Contact Tracing, Social Distancing Monitoring, and Other Technologies for Keeping Workers Safe, Food Industry Executive, 22 July 2020 at https://foodindustryexecutive.com/2020/07/contact-tracing-social-distancing-monitoring-and-other-technologies-for-keeping-workers-safe/ ]

 

Again, tokens or other monitors (including human observers) are not a complete solution.  A sensor chip is into a shield.  Like any protection, it has its limitations including how well users actually attend to the warnings emitted.  Other strategies and tactics including active supervision to ensure safe work procedures are followed are needed.   


Strategy 8: Actively limit chains of transmission

This strategy relies on frequent, wide or universal testing within the workplace, rapid results and rapid, thorough contact tracing with effective support for quarantine and isolation. Quickly identifying a workplace exposure to Covid-19 and stopping the transmission of the virus in a workplace is essential to safe work.  Procedures for rapid reporting and contact tracing within workplaces are essential to limiting chains of transmission.


This strategy is particularly applicable in natural resource and construction camps where accommodations are often closely spaced and food services are provided en masse.  Camps often operate in a sort of bubble but with rotating members.  The possibility of an infected worker entering the camp and unknowing spreading the virus puts all personnel at risk. 


To better manage this risk, New Gold Mining in Northern Ontario is now testing every employee for COVID-19.  New Gold has 150 workers in 14 day rotations entering the camp.  The company uses Precision Biomonitoring test kits at its River operations.  The battery-operated analysis device is about the size of a toaster and contains the necessary reagents and technology to analyze nine samples at a time and deliver results to a smartphone app in about an hour. Rapid identification of anyone carrying the virus allows containment of virus and protect other workers.  [see Sarah Bridge, Ioanna Roumeliotis, “Ontario mining company 1st to try new mobile test that diagnoses COVID-19 in as little as an hour,” CBC News, 11 August 2020 available at https://www.cbc.ca/news/canada/rapid-onsite-covid-test-1.5680526 ]


Rapid testing with rapid results is essential to limiting chains of transmission in the community.  That is why many jurisdictions place such an emphasis on contact tracing.  While smartphone-based contact-tracing apps are being implemented in many countries and some firms, not everyone has a cellphone and many who do have older ones that may not be compatible with the contact tracing app. 


Singapore was among the first to roll out a contact tracing app but privacy concerns and low uptake from the general population limited its use. Although migrant workers were required to download the app, large gaps in coverage made the app less effective.  Now Singapore is handing out small TraceTogether “tokens” to those without phones or reluctant to use GPS based technologies.  The battery-operated token is worn or carried in a purse or pocket.  It interacts with other tokens and smartphones with the enabled TraceTogether app.  In the event of a positive COVID-19 test result, the token can be turned over to public health contact tracers.  Close-proximity Bluetooth contacts over the previous 25 days stored on the device facilitate contact tracing.  [See Saira Asher, “Coronavirus: Why Singapore turned to wearable contact-tracing tech”, BBC Singapore, 5 July 2020 at https://www.bbc.com/news/technology-53146360 ]


Testing poses lots of questions: who to test, how often, how quickly can results be obtained, how reliable are the results, how are results communicated and to whom… Equally important is what happens next.  Without rapid isolation of positive cases and quarantine of close contacts, testing does not effectively break the chains of transmission. 


Many other strategies and tactics

This set of observed strategies and tactics illustrate what steps are being taken to protect workers, but these observations are illustrations not a comprehensive examination.  Organizations are innovating and implementing many other ideas to achieve the objective of keeping workers and others in the workplace safe from Covid-19 infection.  As our understanding of the virus, the sources of transmission and the means of prevention improve, strategies and tactics must evolve.


Most techniques rely on more than awareness of the hazard.  Managing this risk relies on training, supervision, and support.  Implementing broad use of PPE, for example, requires more than putting a box of masks and gloves on the breakroom table or a bottle of hand sanitizer in the lobby.


Strategies and tactics may be fine in the abstract but meaningless if not fully implemented. If the COVID-19 safety plan posted in most businesses is not being followed, everyone who engages in that workplace is at increased risk—a risk that they may unknowingly carry with them to their families and community. 


Almost all effective safety plans rely on more than one strategy and associated tactics.  Even in isolated bubbles, handwashing, testing, monitoring, and PPE are needed.  Multiple strategies may overlap but never think of that overlap as wasteful.  Safeguards, controls, and defenses are always subject to defects—latent or active deficiencies that can permeate allow the hazard a pathway.  Each additional layer of protection decreases the risk of harm. 


As you traverse your communities, engage in your workplaces, and patronize businesses observe the actual COVID-19 prevention actions being taken.  Think about the underlying strategies and how well the implemented tactics contribute to achieving the prevention objective.      


Final comment

All the signage, plexiglass, and PPE in the world will make a difference in the trajectory of this pandemic if there is no buy-in from workplace participants.  As a consumer, I now where a three-layer non-surgical mask inside all inside workplaces I visit.  I have walked out of businesses that are obviously exceeding their allowed capacity.  I have gone out of my way to engage in businesses visibly following and enforcing their own workplace COVID-19 safety plans.


The best strategies and most effective tactics will not work if they are not followed.  Complacency and failures to prioritize safety are the biggest threats to the success of any safety plan.  As a worker, supervisor, consumer or other person in the workplace, this is not just a matter of following the plan but helping others to maintain vigilance and compliance every day.  COVID-19 will be a risk in the workplace for months and months to come.  Despite the natural tendency toward fatigue, making the strategies and tactics in every COVID-19 safety plan part of the culture is the only effective way forward.