Do employers need a workplace Contact Tracing plan or app?

If you are an employer, you have a positive duty to protect workers from harm.  Industry-specific guidelines on how to do that in the COVID-19 environment are now published by occupational safety and health organizations (such as  CDC, SafeWorkAustralia, and WorkSafeBC). The physical barriers, personal protective equipment, physical distancing, cleaning guidance and safe-work protocols required to discharge this duty are essential preventative measures. 

Prevention is rarely perfect.  The safeguards, barriers and defenses put in place to protect workers from harm may be subject to inadvertent active or latent defects;  despite multiple layers of precautions, when gaps or defects in prevention align, workers in your workplace may well be exposed to harms including the COVID-19 virus. 

Every jurisdiction has specifically emphasized employer responsibilities during this pandemic.  For example, consider this guidance to employers in Ontario:

The employer is required to take every reasonable precaution in the circumstance to protect the health and safety of workers, and do a risk assessment to determine what parts of the jobsite and what other workers the affected worker would have had contact with.

Based on this risk assessment, the employer may be required to:

• send co-workers who were exposed to the worker home for two weeks. Ask them to self isolate and self monitor and report any COVID-like illness to their employer
• shut down the job site while the affected workplace area and equipment are disinfected

[See Government of Ontario, COVID-19 (coronavirus) and workplace health and safety]

No employer wants any worker to be exposed to or infected by this virus; nor does anyone want to see operations shut down or healthy employees quarantined.  Yet, close contact exposures may occur in your workplace; planning for them can mitigate the impact on your employees and operations. 

Just the facts

The science around COVID-19 is still developing but there are four very important facts to keep in mind:

1. COVID-19 is a respiratory illness contracted when virus particles are either directly inhaled from droplets expelled by an infectious person or indirectly transferred from contaminated surfaces to face, eyes, mouth or nose. 
2. After unprotected close contact with an infectious person or contaminated surface, an exposed person’s symptoms may develop during an incubation period of 14 days, however, up to a quarter of those infected are asymptomatic. 
3. An infected person is infectious to others during a communicability period; that period for those with mild symptoms begins two days before the onset of symptoms.  Infected persons are considered infectious until 10 days after onset of illness, as long as they are fever free and have improved. Those with more severe cases may be infectious until two consecutive negative laboratory test results, at least 24 hours apart, which could take weeks to establish.
4. Just because a person is no longer infectious does not mean they are fully recovered.  Lingering symptoms including fatigue, cough, respiratory and neurological issues may persist. 

Exposure and Close Contact

Unless you are in the healthcare sector, you or your employees may not know when, where, or exactly how an exposure to COVID-19 has occurred.  It is very unlikely a customer will produce a sudden, uncovered cough or sneeze then announce, “I’m positive of COVID-19”.  (If that every happens, your response as an employer would have to be immediate).   More likely, an employee or public health contact tracer will report a close contact exposure, an illness suspected to be caused by the coronavirus, or a positive test result.  The actions you take next are critical to stopping the spread of the disease in your enterprise and the broader community.   

COVID-19 is a respiratory illness.  Your employee breathing in a quantity of droplets from an infectious person, for example, is certainly an exposure that may lead to the development of the disease.  The now ubiquitous plexiglass shields erected in workplaces prevent some of that, but surfaces, tools, and containers may become inadvertently sources allowing a worker to transfer virus particles to their hands then to their eyes, nose or mouth.  Just because a barrier is in place does not mean all potential contact in the workplace has been eliminated; nor do the precautions you take eliminate the possible introduction of the virus into the workplace by other routes. 

Workers may also be exposed to the virus outside the workplace and not realize they have been exposed. Crowded spaces like transit, house parties, and shopping venues have been identified as places where the virus easily spreads.  An employee may be exposed in any of these settings, become infectious, and expose others at work. 

You employees may be exposed at work or in the course of their employment.  It is not uncommon for a worker, customer, or other person in the workplace (such as a delivery person, courier, student, service technician, inspector) to begin to feel symptoms while at work.  Infectious persons (possibly asymptomatic or pre-symptomatic) in “close contact” with workers or customers may inadvertently and unknowingly expose others in the workplace. Definitions of “close contact” vary but if you work within two meters (6 feet) of another worker, customer, or other person in the workplace for fifteen minutes or more, you would likely meet the definition in most jurisdictions. 

Not all exposures or close contacts with a person who is infectious will result in illness. With the knowledge that some people are asymptomatic or pre-symptomatic but infectious, we now know that exposures to this virus may be more common and less obvious than in the above example.   In many cases, the first sign that one of your workers was exposed will be when they report being ill.  Where they were infected may not be obvious.  Their safety and health are paramount but beyond that, investigating the source of the exposure and protecting workers and others in the workplace must be your priority.

A Workplace Scenario

As an employer, you are likely to encounter a case of COVID-19 in your workplace at some point.  Whether or not an employee becomes infected in the course or employment, you are going to have to determine who came in close contact with a source of the infection (an infectious customer or co-worker, contaminated surfaces or discarded tissues used by an infectious person) , which employees should be quarantined, and when the diagnosed and quarantined employees can return to work.  Acting quickly is critical to stopping the spread of the virus and limiting the impact on operations.

Consider this scenario:

Anna and her two other team members worked in close proximity Monday to Thursday.  They did their best to keep physically distanced, but the nature of their work meant working side by side for periods of time.  On Friday morning, Anna woke with a dry cough, headache and fever.  She called her manager’s line and left a message regarding her symptoms; she then called her doctor who told her to self-isolate and immediately referred her to testing.  On the following Monday morning her test results were received:  positive for COVID-19.  After receiving the diagnosis and instructions from her physician, she called her manager with the news.

As Anna’s employer, you will be concerned for her.  You will also have concerns for your other staff and your production.  While it may not be clear if Anna contracted the disease at work, you have a duty of care for your other employees who were in close contact with her and others who may have been exposed through the immediate operational space.

When can my employee return to work?

In the above scenario, Anna will be told to isolate and will not be returning to work for at least 10 days from symptom onset. Isolation prevents sick persons from spreading the disease to others, including family members.  Isolation means not going out for food or entertainment and definitely not to the workplace.

If Anna is well enough and can work from home while isolated, that may be an option; she can’t end her isolation until she is no longer infectious.  The infectious period begins two days before the onset of symptoms and extends for at least 10 days even if symptoms subside.  Beyond the 10 days, isolation is required until the worker is fever free for three days and all other symptoms are resolving. 

Even though the isolation period may have ended, workers like Anna may need more time to recover from other symptoms to return to work. For some occupations, another test may be necessary to confirm a worker is no longer infectious.  Although no longer infectious, many who recover from COVID-19 experience fatigue and other symptoms that may delay a full, safe, and durable return to work.  Your “duty to accommodate” a worker extends to such cases. 

What about close contacts?

Remember, Anna was likely infectious for the two days prior to symptom onset.  It is likely her team members were in close contact with her during that time.  Cleaners, supervisors and others who visited Anna’s work area may have been exposed.  Perhaps she met with her manager or another team concerning the next project.  None of those employees may report being ill (or ill yet). 

The sooner well employees are informed of their exposure, the better the chances of arresting the spread of the disease.  As a precaution, workers with close contact should be told to self-quarantine for fourteen days from the date of exposure.  Quarantine is a means of restricting the contact and movement of a person who has been exposed; it prevents the spread of disease to others.  The following concisely describes what Anna’s close contacts will be expected to do 14 days from last contact with her:

• stay at home and monitor yourself for symptoms, even just one mild symptom
• avoid contact with other people to help prevent transmission of the virus prior to developing symptoms or at the earliest stage of illness
• do your part to prevent the spread of disease by practicing physical distancing in your home

[see How to quarantine (self-isolate) at home when you may have been exposed to COVID-19 and have no symptoms, https://www.canada.ca/en/public-health/services/publications/diseases-conditions/coronavirus-disease-covid-19-how-to-self-isolate-home-exposed-no-symptoms.html]

Exactly how your enterprise will handle COVID-19 absence for those who must isolate or quarantine is up to you.  It may require amended sick-leave policies, new procedures for initiating quarantine, and even supports to enable quarantine to be effective.  Your quick action can prevent cascading exposures to other workers, their family members, and the broader community.  If Anna’s test results are negative for the COVID-19 virus, then her continued self-isolation and quarantine of her close contacts would not be necessary.

If informing employees waits until there is a positive test result, the implications may be more profound. The well employees may have returned to work on Monday morning but once Anna (or a public health contact tracer) makes you aware of the positive COVID-19 test, all employees having had close contact with Anna must quarantine for fourteen days following the last close contact.  The potential length of the quarantine does not change but the delay in starting their self-isolation raises the potential for Anna’s close contacts to unknowingly become infectious and infect others at work, home or in their community.    

In the scenario above, Anna experienced the first symptoms on Friday morning and got her test results on Monday.  That may be close to the ideal case.  Had she come to work ill, the potential for a wider exposure would expand.  The fact she stayed home and got her test result so quickly means she had limited contacts and the virus had limited opportunities to spread.  Co-workers with close contact would count their quarantined period from their last close contact.  Team member that worked with Anna on Wednesday or Thursday would count their quarantine date from their last close contact with Anna.  Hopefully, quarantined employees will not get sick but if they do, they will not spread the disease further.  Quarantined workers can return to work once the quarantine period expires if they are otherwise healthy and symptom free.

Can I leave identifying close contacts up to public health contact tracers?

Public health contact tracers have special training and knowledge to do their jobs but you, as an employer, have a duty to protect your workers.  As an employer, you have important information for contact tracers. You know your workplace and are in the best position rapidly identify close contacts.  Your attendance records, work schedules, employee contact information, building entry logs, and meeting minutes can help you rapidly identify close contacts and prevent wider exposure.

It may be that you as an employer will be contacted by public health with information that an infectious customer, technician or other person was at your workplace, raising the possibility of close contact exposure.   Your records of who was working with or serving that customer will be important to the contact tracer but also to your ability to fulfill your duty of care for your employees.  Remember, the faster exposures are identified, the sooner the spread of the virus can be halted; the impacts on your workers’ health and your operation’s production are limited the sooner you act.

Isn’t there an app for that?

Many countries and some employers are mandating or recommending smartphone apps or other technologies to facilitate contact tracing.  Korea, Singapore, the UK, Iceland, Norway and others have implemented programs with varying degrees of success.  The apps generally use Bluetooth technology to register either location and/or proximity to others with the app or tracking “token”.  If a person is identified as infected with COVID-19, the app can quickly identify others who may have had close contact during the infectious period. [see Ryan Brown, Why coronavirus contact-tracing apps aren’t yet the ‘game changer’ authorities hoped they’d be, CNBC, July 3, 2020].

These apps are not without controversy.  They only work well if widely enabled on many devices, so public acceptance (or government mandate) are required.  In Singapore, for example, temporary foreign workers are required to carry a tracking token and that interacts with the nationally mandated smartphone app (voluntary for citizens).  [see Saira Asher, Coronavirus: Why Singapore turned to wearable contact-tracing tech, BBC News, Singapore, 5 July 2020].  Not all smartphones are capable of handling contact tracing apps and those with greatest vulnerability such as lower income citizens and older individuals may not have access to the latest technology.          

Corporate apps are also available.  These may be adopted and mandate by a firm for employees but there are both privacy and efficacy issues.  Not everyone is OK with 24 hour a day GPS tracking by an employee or a government.  Questions about how data will be collected and used are often raised. 

Privacy issues aside, efficacy issues include the false positives of proximity.  Even if the app only measures proximity to another smartphone for a given period (say, 15 minutes), that may not mean any exposure has taken place.  Just because the agent renewing your insurance or the Uber driver were taking you to your appointment were close enough to register contact in a tracing app, the presence of a plexiglass shield  or divider will not be registered;  if either you or the other person is identified as infectious, the close contact warning would be a false positive.  The converse is also true; a missed close contact is like a false negative.  If an infectious person does not have the app or token (or the device is out of power or app not enabled), no close contact can be recorded.  Tracing apps cannot record proximity to environmental exposures and may yield a false sense of security.   These technologies cannot detect the virus; they only detect proximity (or location, in some cases).  

Take action now

Before COVID-19 hits your workplace, put your plans in place.  Besides doing what is necessary to comply with OSHA and public health orders or guidance, you need to have a plan for what to do when an employee or public health identifies a COVID-19 exposure or transmission. Your plan may include containment and decontamination teams, but you will need to address policy issues like when and how to isolate, deep clean and disinfect the area concerned.  Your personnel plan for containment, informing close contacts, supporting quarantine, isolation and return-to-work is even more important.  The speed and thoroughness of your actions to stop the chain of transmission is essential to the safety and health of your employees and others in your workplace.  With that in mind: 

1. Prepare:  develop policies and procedures so staff know what to do if they feel ill and particularly if they are diagnosed with COVID-19.  Privacy laws and policies will vary so keep those in mind as you prepare.  Confidentiality is important and safeguards should be built into your policies and procedures. Involve staff and union representatives in your plan development. Consultation, addressing concerns, developing policies, and then training staff will challenging in the COVID-19 era but critical to your planning and preparation.   
2. Update and keep current:  Where people work, seating floor plans, travel records and entry/exit logs need to be accurate and immediately available when required.  Meetings may not always have minutes, but every meeting should have a record of attendees, location and times. Update employee contact information for home, mobile phone numbers, and email.
3. Operationalize your plan:  Assign specific resources to manage suspected or known COVID-19 exposures.  Delays in identifying close contacts can result in wider spread within your operations and beyond.  Having key resources familiar with operations and records, knowledgeable of your policies and equipped with the commensurate authority to act will be necessary.  Be sure to build redundancy into your plan. Your plan needs to operate even if the specific resources become ill or unavailable.
4. Consult, train, build awareness:  Your operations depend on people.   The very steps necessary to limit the spread of COVID-19 and facilitate contact tracing need to be understood and concerns addressed in advance of any need.  Activity logs, attendance at meetings, entry and exit logs are necessary but concerns over why they are needed, how long they will be kept, who has access and the purposes allowed for that access need to be clear and understood.  Build awareness of your plans and why the procedures are needed to protect workers and others in the workplace.
5. Build resilience:  For the near to medium term, COVID-19 is part of our reality.  Anticipating the consequences of exposures and close contacts in your workplace can mitigate against the greatest impacts and accelerate your ability to keep workers safe and restore operations.  Having your plans and resources in place, assigning and cross-training personnel, and testing your plans are essential to restoring and maintaining the health and safety of your employees and the success of your operations.

COVID-19 will be in our workplaces for some time—likely measured in years rather than months.  Whether this or some other infectious disease, workplaces must adapt in ways to protect workers and others in the workplace.  

Should workplace health and safety go back to “normal”?

Let me be emphatic:  a pandemic was inevitable.  Maybe not this COVID-19 virus pandemic but a pandemic involving a virus with close-contact transmission and serious health consequences was absolutely going to happen.  Every strategic planner knew it and, to their credit, many organizations planned for it.  Their plans might not have been perfect, but many plans addressed situations where employees would be unwell for extended periods of time (and worse).  Planned for or not, this pandemic is changing workplace health and safety.

The COVID-19 pandemic is revealing vulnerabilities in our workplaces.  These occupational health and safety vulnerabilities were there all along; many were known (or should have been known) but were latent —without consequence until the harsh, impersonal reality of this virus brought them to into stark focus.

We are at the early stages of businesses reopening and envisioning what the workplace will look like when the pandemic recedes.  Knowing what we know now, should workplaces simply plan to go back to the old “normal”, or is now the time to revamp workplace health and safety?

Why are our workplaces vulnerable?

Every workplace has hazards.  Some hazards present obvious risks to workers.  Employers have a duty to assess and manage those risks.  Many of the actions necessary to prevent transmission and protect workers from infectious-disease risks are well known.  Some protections are built into the design of workplaces and the structure of safe-work procedures—protections that are maintained through training and supervision.  Together, these fundamental barriers, safeguards, and defenses decrease the risk of harm arising from those ever-present and emergent hazards. 

The COVID-19 pandemic has revealed defects and deficiencies in the barriers, safeguards and defenses that would otherwise protect workers from harm. In retrospect, it is obvious that care workers moving between long-term care homes for the elderly carry the risk of transmission between facilities.  It is now painfully clear that workers in close contact with each other in meat processing plants or agricultural bunk houses could spread disease to each other.  We always knew we should not come to work sick, but we let our workplace culture view those who came to work despite the sniffles, mild cough or fever as heroic.  The hazards were there all along. 

In hospitals and on the front lines of emergency care, the urgency of ministering to others and dealing with staff shortages may have created gaps in those defenses and safeguards we failed to recognize until now.  The virulence of this virus has revealed how minor gaps in any of our safeguards can result in an infection with serious health consequences.  The supply of our Personal Protective Equipment (PPE) may have been assumed sufficient in the past; we know now that gaps here can be fatal to the very people we need to care for us and manage this pandemic.  Even minor defects in the quality of PPE can result in exposure that can decommission a valuable, scarce staff member or team for weeks in quarantine or, at worse, result in infection, illness and even death.

Failure to fit-test respirators, to train the proper use of PPE, ensure initial quality, safely maintain stockpiles, and ensure the availability in sufficient quantities of quality product always exposed workers to greater risk.  COVID-19 laid bare those vulnerabilities.   It is one thing to have safe work procedures, require PPE or mandate hand-washing with hot water and soap but quite another to supervise or assure adherence to those safe work procedures.  We knew these shortcomings were there but their consequences seemed minor; the apparent time/effort cost of compliance lost out to the more immediate benefits (and often rewards) of time and production.  This pandemic has changed all that.

To be clear, it is rarely one defective product, one error in practice or one oversight in supervision or training that results in harm.  Jobs are typically designed with multiple barriers, safeguards and defenses that prevent harm.  To use the late James Reason’s "Swiss cheese” analogy, it is the alignment of holes or defects in the barriers, safeguards and defenses that allows a straight-line trajectory between the hazard and the worker that results in harm. The COVID-19 pandemic has illustrated just how porous our layered protections really are. Reducing the size and number of those “holes”, particularly those revealed by this pandemic, is necessary if we are to progress toward any new sense of normal.

Will the defects in our barriers, safeguards, and defenses really matter when we get back to “normal”?

The world has changed and there is no going back.  We know this virus is going to be here for a while.  Massive lockdowns have had their effect.  The mantra of “flattening the curve” has been achieved in many (but far from all) places.  So far, only a few jurisdictions have seen their health systems overwhelmed as we saw in New York, Italy and Spain.  Lockdowns have bought us time. Next comes the hard part.

Economic activity will resume.  Consumers may be wary of returning to the market place and workers may also have concerns for their health and welfare as much as their livelihood as they return to the workplace.  In this next phase of our pandemic experience, any gap or defect in our barriers, safeguards, and defenses can result in local shut downs and community spread.  The cost of a local outbreak may be an immediate lockdown of a community and no guarantee of a rapid return to production or service for the enterprise.

There may be a vaccine at some point… maybe. There may be a treatment for the worst cases….maybe.  Neither looks imminent and the long-term prospects for immunity are unknown for those who have had the disease. 

Testing, containment, and contact tracing is the new mantra for controlling this pandemic but that does not mean any workplace can return to its pre-pandemic state. 

How do we get to the new normal?

Every workplace will have to navigate the new reality, informed by the science of workplace safety and health and the imagination that comes with local knowledge.  There may be new resources to help but ultimately workers and employers are going to have to put their lives and the lives of those they serve on the line.  Shrinking if not eliminating the gaps and defects in our barriers and safeguards has to be the priority. 

The vision of workers and workplaces safe and secure from injury, illness and disease cannot be achieved without excellence in prevention.  Jobs, processes and equipment must be designed to minimize risk. Managers and supervisors must continually monitor and refine systems and incentives.  Training must be thorough and frequent. There is no point in telling staff to “work safely” while praising production achieved by cutting corners.  I’m was guilty as anyone in the past for pressing ahead to work with a runny nose or feeling a little ill—that just can’t happen in this new reality. 

Work is still good for your health and wellbeing.  Work can be therapeutic for physical and mental injury recovery.  That doesn’t change, particularly for most workplace injuries.  Illness (feeling ill) and disease (test-positive diagnosis even if feeling well) are in a different category in this new reality.  Workplace culture—the way we handle illness and actual asymptomatic test-positive or possible disease—has to change.   If workers aren’t empowered in their workplace and supported financially and emotionally to stay home, all of us may suffer the consequences. 

There will be consequences… and challenges

As we progress through this pandemic, there will be more people infected but more will recover, presumably with some immunity for some period of time.   Already, questions concerning the organization of work teams are beginning to arise.  Should workers who have recovered be grouped together? How much detailed contact recording should we do in anticipation of a positive case with an employee?  How do we determine who is a close contact?  What do we do when a person in the office or shop floor does test positive?  Who will sanitize a test-positive employee’s work station and what happens in the mean time?

Almost all businesses will have lower productivity, at least initially.  New staff will still have to be oriented and trained to the new reality; existing staff will have the added complication of unlearning  behaviors and replacing them with new ones (it’s hard to change a reflex like shaking hands when meeting a client).  Even the way we orient, educate and train will have to change.  Large conferences and classroom sessions may have been efficient but won’t work for some time to come; smaller groups and innovative delivery methods may be effective if somewhat slower alternatives.  

Controlling customers in retail, having fewer workers in call centres, providing wider spacing on production lines, mandating PPE (and allowing the time to put it on, test and safely remove), increasing site sanitation and hygiene—all these measures will be necessary for months, perhaps years to come.  This will alter production timing and costs but may make alternative designs and ways of doing things safer, more efficient and perhaps more profitable in the long run. 

Your workplace health and safety procedures are going to have to change, too.  Each change in procedures, process design and operations can generate potential issues for workplace health and safety.  Moving from open-office floor plans to more offices, staggering working and break hours, adding physical dividers to workspaces, changing ventilation, adding more wash stations, allowing more time for sanitation—these are not trivial changes to the workplace.  Each change has immediate and intended consequences but also unintended ones.  Evacuation plans change when open spaces suddenly have walls, for example.  Cleaners will need more time between those working hours to increase surface cleaning.  And those contingency plans you have in case of fire or flood or evacuation are all going to have to be revisited to take into account the changed environment and physical distancing requirements. 

COVID-19 is potentially everywhere but your community, your plant, or your office may be COVID-19 free, at least for a time.  That doesn’t mean you can dispense with prevention or count on the absence continuing.  You have to prepare for when this pandemic comes to your operation. 

Workplace transmission of COVID-19 may well result in workers’ compensation claims or potential action from customers or other non-workers in the workplace.  Incident investigations are going to have to include contact tracing.  The interactions of field staff, customer contacts on-site, delivery personnel movements, and cleaning staff patterns must be part of every incident investigation.  Record keeping becomes less of an accounting tool and more of a health and safety imperative.

You are going to need very detailed plans on what to do when a member of your staff, a customer, supplier or visitor to your worksite tests positive.  The immediate cleaning and sanitation needs are obvious but who does what, how do you determine close contact are just the beginning.  How long will you have to close, will key staff members be forced to quarantine (and will you pay them while well but in quarantine), what happens to non-close contact workers who are displaced---just some of the questions that will need answers.  The general duty to protect workers is not diminished in a pandemic.

The bad news is that many businesses will not survive the transition to the new reality.  There will be disruptions and cost pressures, bankruptcies and closures, and operations that resist necessary changes (sometimes with no consequences in the short term, reinforcing actions that put workers in danger).  And even if normal economic theory applies and new enterprises fill the breaches created, the risks do not just disappear. 

And the good news?

There are positives to all this.  If nothing else, there is a heightened awareness of occupational hygiene and safety in the workplace.  We may not have been ready for a pandemic, but ready or not, workplaces are rapidly adapting and innovating now.

We may not have a vaccine or effective treatment yet, but we do have solutions to prevent the spread of this disease in workplaces and communities.  The solutions recommended by public health around the world are based on tried and true principles.  Most of the advice from the Spanish Flu pandemic a century ago applies today:  wash your hands, isolate the sick, keep physical distance, wear a mask, and avoid large gatherings like funerals. 

We may not have all the answers about this virus but we have the sciences of genetics, epidemiology, and statistics to accelerate our understanding.  We have science-based principles protect workers and others in the workplace.  The “Hierarchy of Controls” has been central to health and safety since the middle of the last century.    The physical distancing (eliminating the hazard), those now ubiquitous plexiglass barriers in retail (engineered controls), and markers directing flow in supermarket aisles (administrative controls), and even mandated masks on planes and buses (personal protective equipment) are principle-based and the best defense we have for now.

Perhaps changes in work procedures will result in fewer injuries and work-related illnesses overall as processes are reviewed and re-designed.  A shift in workplace culture towards prevention of COVID-19 may include a more general re-think of priorities and incentives in the workplace.   Already, workplaces are innovating based on what we know.  Processes, equipment, and physical plants are being re-imagined in light of the pandemic with greater safety and health for workers.

That’s not to say workers won’t get hurt in our redesigned workplaces.  Physical injuries and non-COVID-19 injuries are still a risk in every workplace.  Trips and falls still are still happening; cuts, contusions and fractures are still common; mental injuries and other work-related trauma are still very real injuries in our workplaces.    

Workers are still going to need treatment and rehabilitation for injuries.  Physiotherapists may need new protocols for working with their patients but the work they do is vital to increasing function and preventing disability.  Prosthetists are still going to have to work one-on-one with amputees.  Some professions may be able to work remotely with some clients some of the time.  The good news here is that there are ways to work safely and manage the risks revealed in this pandemic.

What happens if we get a broadly effective treatment, an effective vaccine, or reach “herd” or community immunity?  Many of the changes made because of this pandemic will persist.  And that may be for the best. 

We were not “lucky” with this pandemic –it is serious and deadly but could have been more so; this pandemic has revealed vulnerabilities that were always in our workplaces.  Hopefully, in making workplaces safer, healthier and more resilient for this pandemic, we will re-imagine workplace health and safety … and be far more ready for the next one. 

[  I-61504  Spanish Influenza poster:  Fight the Flu  1918-1919, British Columbia Archives]

How do you report unsafe work?

Suppose you are in a hotel and you see the window washer outside your room being blown around and unable to secure the platform.  Should you say something?  Would you?  And to whom? 

What if you stop for lunch on the weekend and the roofers on the steep slop of the mall across the street are three stories up and not tied off (and have no other fall restraint system in place)?    

What if your child comes home from his first week on a summer job concerned about the lack of personal protective equipment for the pesticides they are having to use but is fearful of losing the work by complaining?   

If you see an unsafe work situation at work, you have an obligation to say something.  Employers have a duty to keep workers and the workplace safe for workers and “other persons” in the workplace.  If you are a worker, you also have a right to refuse unsafe work.  But what if you are not a worker? What if the unsafe work or condition is something you observe but are fearful of reprisals if you intervene on your own? 

Most people would agree that you have a moral obligation to say something to prevent harm.  Most occupational safety and health and workers’ compensation authorities have information on their websites advising who to call or contact in the case of immanent danger to life or health.  For example, WorkSafeBC’s Prevention Information Line (see webpage https://www.worksafebc.com/en/contact-us/departments-and-services/health-safety-prevention ), states the following: 

Prevention Information LineContact us to:

• Report a serious incident or major chemical release.
• Report unsafe work conditions (see also Refusing unsafe work).
• Report anonymously, in almost any language.
• Request a worksite inspection consultation.
• Get information about workplace health and safety.
• Get information about the Occupational Health and Safety Regulation.

Phone: 604.276.3100 (Lower Mainland)
Toll-free: 1.888.621.7233 (1.888.621.SAFE) (Canada) Hours of operation: Monday to Friday, 8:05 a.m. to 4:30 p.m. Fatalities and serious injuries: Call the numbers above, 24 hours a day, 7 days a week.

Note how this organization removes the barrier of language and allows anonymous reporting.  There are, however, other barriers.  There is no facility to report by email or internet form, no facility to submit files, documents or photos, and, short of emergencies, access time is limited to normal daytime hours Monday to Friday.  Ideally, any person—worker or member of the general public—should  be able to report unsafe work without having to judge if it is an “immanent” danger.

In Washington State, the Department of Labor and Industries advises you fill out the following form: 

“Alleged Safety Or Health Hazards (DOSH Complaint Form)” Document number  F418-052-000 http://www.lni.wa.gov/Forms/wordforms/F418-052-000.doc

The website continues with instructions to “Mail, fax, or hand deliver a completed complaint form to any L&I office.”  It also advises “Your name & contact information (you may request anonymity or confidentiality for safety complaints).”  

This approach has some barriers.  First, not all of us have the time or inclination to download a document with about 20 fields,   (try and do that on your smartphone and I bet you will abandon the effort) . The form cannot be submitted as an email.  There is no provision for the form to be completed anonymously (although you can request anonymity and confidentiality).

Contrast this approach with taken by Alberta Labour.  You can “complain” about unsafe work using an online form.  Their website  (https://work.alberta.ca/occupational-health-safety/file-a-complaint.html )  states “Anyone can report unsafe conditions at a workplace; you don’t have to be employed by a business to do so.”  The web form has only a few mandatory fields and you can remain anonymous, although anonymity, of course, means officials can’t contact you for follow-up details or additional information. 

The Workers’ Safety and Compensation Commission (WSCC of the Northwest Territories and Nunavut) has a similar online form but has the added “search and view” feature.  The screen shot shows the detail available using this function.  It allows anyone to follow up on what is being reported and what happened as a result of a report.  The report is sortable on multiple fields. 

I particularly like this level of transparency.  While individual firms and persons are protected, it raises the profile of health and safety.  It also increases the perception that unsafe work will be detected and reported.  For some organizations this increased risk may act as a deterrent to unsafe or unhealthy workplaces. I’m not suggesting OH&S inspection should be crowd sourced, but allowing and encouraging public participation in making workplaces safe and healthy has the added advantage of raising societal awareness on this important issue.  

Some systems say the don’t respond to anonymous sources.  Note this line from the Yukon Workers’ Compensation Board’s website (https://wcb.yk.ca/QuestionResults/OHS/Reporting/Q0228.aspx ):

When you report a dangerous workplace, you will be required to give your name and contact information for follow-up. Our safety officers do not respond to anonymous complaints.

This barrier may discourage anyone from “getting involved” and the rationale for this exclusion is not explained.

One of the best online forms I’ve seen for reporting unsafe work comes from the Australian Capital Territory.  The Access Canberra webpage (https://www.accesscanberra.act.gov.au/app/forms/worksafe_report )  has a simple form complete with the ability to upload documents or files and includes an interactive map to pinpoint the closest physical location of the concern.   Think about the investigative value of uploading photos that are geotagged and timestamps.  It also has a tick box to “submit anonymously”.   The mobile version of this page is just as good and works well on a smartphone.

The purpose of reporting an unsafe workplace is prevention.  Barriers to reporting defeat this purpose.  Reporting unsafe workplaces and situations should be simple, quick and  as barrier free as possible.  My checklist for a good “report unsafe work” site includes:

• Accessible (multi-lingual if possible)
• Available 24 hours a day, 7 days per week
• Open to reports from the general public
• Allows anonymous submissions
• Permits attachments (documents, photos, etc.)
• Simple and quick to submit from a smartphone
• Provides a tracking reference to the submitter
• Provides a transparent process for showing recent submissions and actions

Its time workers’ compensation and Occupational Health and Safety  organizations begin to leverage the power of instant communications and encourages greater public participation in making workplaces as safe and healthy as possible. 

What, if anything, does a “near miss” have to do with health and safety?

“Well, no one died, so what’s the problem?”  I have heard lines like this before and I heard it again yesterday.  What irks me is that the people saying (or reported to have said) these words are often in supervisory or managerial positions.  Some even have a title or function that includes “safety and health”.  The truth is, the absence of injury is not a true measure of workplace health and safety.   And how a “near miss” is reported and reviewed reveals much about the safety culture of a workplace.

I instruct classes and seminars with learners and talk about safety with a lot of workers.  When I ask about their health and safety experiences, they often relate incidents like the following—serious incidents but without injury: 

•  The ladder I was on began to slide sideways and I had to jump off.     
•  The patient suddenly lost balance and collapsed on top of me.
•   The student I was helping impulsively started the drill press while my eye was next the bit aligning the project.    
• As I pulled out the top drawer, the file cabinet began to fall forward… I was just able to step out of the way before it went crashing to the floor.        
• Someone had sprayed a lubricant in the hallway and I nearly slipped and fell when I stepped in it.
• The metal plate broke loose from the winch and missed my toes by a fraction of an inch.

The workplaces above are varied:  a paint job on a residential site, a clinic, an industrial education shop in a school, an office, a hallway in a public building, a fabrication shop.  From an outcome perspective, there were no injuries, no lost days due to accidents, no need for doctor’s visits or alternate duties.  Yet, most of us would recognize that what separated the worker from injury in each case was a matter of luck (or millimetres) and not safety. 

Regardless of the workplace, each of the above incidents is a wake-up call, an opportunity to review the “near miss” to see if there are improvements or changes that might prevent a repeat of the incident.  Each case is worthy of an incident report and an investigation by the site safety committee. 

Safety is a function of the safeguards, barriers and defenses that protect workers from harm due to the hazards inherent in all workplaces.  Every near miss reveals active or latent defects in the barriers, safeguards and defenses that protect workers from harm.  Design, supervision, training, safe work procedures are some of the safeguards, barriers and defenses I’m talking about; an effective investigation will reveal the possible defects that had to align in order for the near miss to occur. 

If you are looking for a leading indicator of your workplace health and safety program, focus on incident or “near miss” reports.  How many are we getting?  Are they being investigated and discussed at the Joint Health and Safety Committee?  Are means of preventing future incidents being considered?  If incidents are not being reported, don’t assume they aren’t occurring.  And if incident reports are met with a “no one died” or “that’s just part of the job” sort of response, you’ll know a true concern for health and safety is not part of the culture of your workplace.  

Work-related injuries can’t happen here…can they?

One of the biggest barriers to improving health and safety is the belief that work-related injury, disease or death “can’t happen here”.  I’m not saying injuries are an inevitable part of work.  What I am saying is that believing work-related injuries are not possible actually makes it more likely they will occur. 

A teacher commented to me that workplace health and safety really wasn’t an issue where he worked—a high school.  The only health and safety issues he could identify involved the occasional issue in one of the industrial education or foods classes.  “Schools are safe places for students and staff.  Work-related injuries can’t happen here.” 

I agreed that schools are generally safe for students and teachers but hazards and risks of injury are present in every workplace in every sector—including education.   I listed Sandyhook,  Columbine,  Virginia Tech,  and École Polytechnique as high profile examples of a very real risk of  violence in the education sector that has lead to the injury and death of students and workers.   These tragedies tell us about very real risks—risks that have been identified and have led to most schools to perform a risk assessment and develop new procedures.

He conceded that his school now practiced procedures in the case of an intrusion but he put the risk of such an incident right up there with earthquakes and fires:  possible but not probable.   “These are rare events—terrible but rare.  Work-related injuries to teachers, teaching assistants, administrators and other staff in educational settings just don’t happen in day to day work…do they?”

That little bit of doubt provided an opening.  I agreed to check and sent along the following table [data from http://worksafebc.com/publications/reports/statistics_reports/occupational_injuries/default.asp ] :

That’s 10,000 claims for short-term disability or new long-term disability or survivor benefits in British Columbia alone in the last ten years.  Most common injuries were strains and sprains from over exertion or falls on the same level , but hundreds were injuries caused by violence or acts of force including biting, kicking, scratching and hitting. The average age for injured workers in most of these occupations was in the mid 40’s and these injuries were serious enough to cause a work absence.  Getting seriously injured is never “just part of the job” (another widely-held attitude that has to be challenged).   

Injuries can occur in any workplace including schools, colleges and universities.  Work involves risks; complacency and an unfounded belief that “work-related injuries can’t happen here” heighten the probability of injury.  Joint Occupational Safety and Health meetings, safe work procedures, safety plans, new worker safety orientation, ongoing safety training are all part of controlling the apparent and hidden risks in every workplace including all educational settings.

Whether you work in an office, hospital, school or factory, there are ongoing risks to your health and safety.  This is a fact.  It is not meant to scare you.   Unless you believe work-related injuries are possible, that “It really could happen here,” you won’t really engage in the health and safety training, orientation, or practices that make workplaces safer and healthier for everyone. 

Is it time to introduce cone-zone cameras?

It happened again.  Another flag person was hit and badly hurt in another roadway incident.   Another community shocked by the tragedy; another call from police looking for witnesses. Add another tragic case to approximately 400 or so that occurred in this province alone in the last decade.  This particular incident occurred in Northern BC on July 21^st, but a quick scan of any news feed will show you just how common this sort of incident really is in North America. 

In the US, the Bureau of Labor Statistics reports in their Fatal occupational injuries by selected characteristics, 2003-2011 publication 373 entirely preventable worker deaths while directing or flagging traffic.  Despite our best efforts at education, on-site warnings, large signs proclaiming “My Mommy works here”,  even labeling cones with the words “Mom” and “Dad”,  it just keeps happening. 

A few days ago I was out for a walk.  At one intersection, a crew of electricians was working on the overhead traffic signals.  A flagger was controlling some of the traffic lanes and also directing pedestrians to cross when safe to do so.  She was about five and a half feet tall but with the hi-viz fluorescent green/yellow coveralls and jacket, hard hat and safety boots she had a six foot presence.

I watched as she used her body language, voice, stop/slow sign, and eye contact to effectively manage the flow of most drivers and pedestrians.  However, in the space of two minutes, she was nearly hit twice.  Both drivers were down the road in an instant; and one actually slowed down, turned and sheepishly mouthed “Sorry”… the other just accelerated through the intersection in a literal cloud of dust. Through all of this, the flagger stayed calm and focused on her immediate task: the safety of crew, drivers and pedestrians like me.

In an extended break in the action as the equipment and crews were out of the intersection, I asked her about her job and, in particular, what she thought was behind the two close calls I witnessed.  She said, “It happens all the time” and added, “If you could see the [stuff] I see…”. 

She described people on their cell phones or texting, others with dogs on their laps, and even a cab driver—supposedly a professional driver—eating noodle soup from a bowl.   “If you could see the [stuff] I see…”

Her comment got me thinking.  Red light cameras are widely accepted.  I note some jurisdictions are putting photo radar in construction zones (Saskatchewan).  Others are banning cell phone use in construction zones (in Illinois, any phone use at all, hands-free or hand-held, is illegal statewide in school and construction zones) but I don’t know of any jurisdiction that installs “cone zone cameras” –not to detect speeding in construction zones but to actually record what the flagger actually sees.  Why don’t we have “cone zone cameras” ? 

Police cruisers are fitted with dashboard cameras, cabs have cameras that record passengers, some police forces and security personnel have wearable video recorders.  Why not flaggers?  Video evidence is curtailing property crime and has been invaluable to investigators when serious incidents occurs on transit systems, in airports and at public events. 

Most of us respect flag personnel.  Most of us understand the inherent risk their jobs entail.  Most of us will not speed by them, cut corners, or disobey their directions.  For the few that do, my guess is that the behavior is not isolated to a particular cone zone and one particular time.  Identification and intervention may make a difference but most of our ad campaigns and public education are preaching to the converted.  Perhaps a database of outrageous violations will help us identify those that really need to hear the message.   

Flagging should not mean putting your life on the line or under the wheel of a distracted driver’s car or a bloody image in the rear view mirror of someone who really couldn't care less.  Cone zone cameras focused on the “stuff” flaggers actually see might be an added deterrent and could help make a difference.  

Is now a good time to invest in greater occupational illness and injury prevention?

The global economic crisis brought terms like Gross Domestic Product (GDP) from the financial section of your weekend paper to the lead headlines on the evening news.    Even the non-economists among us are more in touch with the standard definition of a recession (a period of temporary economic decline during which trade and industrial activity are reduced, generally identified by a fall in GDP) because of what it means in real, everyday terms to our communities and our families.

    

In the current environment where economic growth is being measured in parts of single percentage points of GDP, many are searching for ways to stimulate growth.   Some argue for cutting red tape and reducing “impediments” to business.  A few even suggest cutting safety and health rules, inspections or enforcement.  It begs the question, is now the time to reduce our focus on OH&S?

A few years ago, the Australian National Occupational Health and Safety Commission (NOHSC) estimated the total direct and indirect cost of workplace injury and illness to the Australian economy at 2000–01 reference year to be $34.3 billion.  That is the equivalent of 5 per cent of Australian GDP.  I was taken aback by the size of this estimate. It made me wonder what the estimate might be for other jurisdictions. 

Last month, László ANDOR, European Commissioner responsible for Employment, Social Affairs and Inclusion, spoke at the Institute of Occupational Safety and Health 2013 conference in London.  His talk separated the myths from the facts about OH&S.  He noted a recent study by the European Agency for Safety and Health and Work that puts the occupational injury and disease loss to the European economy at between 2.6 and 3.8% of GDP.

The International Labour Organization (ILO) in its 2003 Safety Culture at Work study pegged the cost of work-related injury and illness at 4% of the global GDP.  Estimates put the figure at about 3% for the largest economy on earth, the United States. 

These estimates converge on about 3% of GDP average.  Economic growth at that level would be considered healthy in most developed economies.  Recent estimates of current annual growth rates for Canada, Australia and the US are all under that level.  If we could eliminate the direct and indirect costs of workplace injury and illness, the benefits are obvious. 

If more evidence is needed, another study (the Socio-economic costs of accidents at work and work-related ill health [European Commission 2011]) study found, the median value of the profitability index for investments in occupational safety and health (the ratio of pay-off to investment in a particular project ) ranges from 1.29 to 2.89.  Fabulous results for any investment!

Working toward greater health and safety particularly in the low growth, post recessionary period, is not just good for workers, it is good for the economy.  

How do leading indicators fit into the planning and implementation of health and safety plans?

I’ve had a lot more questions about leading indicators and how they fit into the planning and implementation of health and safety plans, and so, I thought a further example and simple graphic organizer may help.

A few years ago, I was speaking with the head of the safety and wellness program for a large US manufacturing firm. The company has factories in several states. I asked her how she knew her programs were working. Her responses gave me a practical insight how leading indicators fit into that process. 

 

Central to her approach, was a sound theory of behavioural change and a clear logic model of the factors that lead to injuries.

Occupational injuries and illnesses, near misses, and individual health issues like obesity, diabetes, and hearing loss are usually multi-causal. The physical plant, equipment design, training, and behaviours such as the adherence to safe work procedures, were very important but underlying these are attitudes. She pointed out that behaviours such as violating safe-work procedures had a feedback effect: the more violations of safe-worker procedures that occur and tolerated or ignored, the more they will occur. Before she could change the behaviours that opened employees to injury, she needed a model of what drives behaviour and a way to integrate that into planning and implementation of health, safety and wellness. 

 

From a planning perspective, the “theory of reasoned action” and its revised version, the “theory of planned behaviour,” suggest that attitudes and beliefs determine much of voluntary behaviour. Changing behaviour must rely on changing attitudes and beliefs. This is consistent with concepts such as “bounded rationality” and safety culture. Workers and managers act rationally and if safety and health are demonstrably important to supervisors and upper management, that will get translated to the shop floor.

 

My US contact described her approach to eliminating eye injuries in their plants. Her model included many components. She and her staff looked at design (including guards), considered awareness sessions, worked to have supervisors insist on and reinforce compliance with wearing eye protection, as well as consistently modelling the behaviour will likely contribute to your goal.

 

Her final planning step was to decide the inputs, resource, activities, and products her plan would encounter (and to seek budgetary approval where required).

 

Remember, her goal was to eliminate eye injuries. Counting the number of workers who suffer eye injuries is a trailing indicator. She developed several possible leading indicators including the percentage of staff participating in awareness sessions and observational data on violations detected by her safety officers. She also made the inspection of guards and shields routine with a plant manager report on guards filed monthly.

 

I hope this example helps. Leading indicators are a powerful prevention tool that may make your prevention program more effective.