COVID-19: an EHS Perspective for Employers

by Jessica Sarnowski, Head of Content Marketing & Thought Leadership 12 Mar. 2020


If you are part of any business right now, you are, no doubt, aware of the global outbreak of COVID-19. This virus is the cause of event cancellations around the world, from sporting events to EHS industry gatherings. No one is “immune” to the impact of this virus and you may be concerned about how your business processes will continue in the face of such a crisis. However, before you spiral into a panic, you should take a step back and consider, from a business perspective, what guidance there is for your responsibilities toward employees.

In the United States, for instance, employers are bound by the Occupational Safety and Health Act of 1970 (OSH Act) Section 5’s well known “general duty” clause (OSH Act, Section 5; This clause requires employers to provide employees with a workplace (and work itself) that is “free from recognized hazards” and this includes hazards "that are causing or are likely to cause” harm – which means "death or serious physical harm" (OSH Act, Section 5(a)(1)). COVID-19 falls neatly into this definition. As just the bare bones starting point, any employer in the US should be aware of this general duty towards employees.

The US, like other countries, has a dedicated government department, the U.S. Department of Health & Human Services, and agency therein, the Centers for Disease Control and Prevention (CDC), that handle outbreaks of the kind of this virus. The CDC is the US authority on all things COVID-19. When reviewing the CDC’s website, one can find a plethora of useful information. It is worth taking a close look at this website if you are operating in the US. One link that is fascinating if you are an employer in the healthcare industry is the Checklist for Healthcare Facilities: Strategies for Optimizing the Supply of N95 Respirators during the COVID-19 Response. This checklist breaks down the difference in engineering controls, administrative controls and personal protective equipment (PPE) by way of example and for a non-expert in virus outbreaks, this is quite a useful page. There is also a CDC webpage that explains who needs PPE (e.g. face masks) and who does not – along with a webinar for those in the healthcare field.

The takeaway here for the US is pretty clear – follow the CDC’s advice and keep in mind that there are general responsibilities under OSHA’s jurisdiction that you should continue to follow as in normal operations.

The US isn’t, however, the original hotbed of this virus. If you are an employer at a multinational corporation, you should take note of the guidance and recommendations of specific countries where your facilities are located.  


What is Happening Around the Globe?

Below are some examples of what Enhesa’s EHS experts are finding when they research COVID-19 around the globe:


If you operate in Italy in any of the areas affected by COVID-2019 epidemic, you should allow employees to work from home. You must also adequately inform these remote employees about health and safety precautions to undertake. For more information:

Best practice (possible future requirement) would be to review the Risk Assessment Document (Documento di valutazione dei reschi), in light of the presence of the new biological risk linked to the COVID-19 virus.

China -


During the COVID-19 epidemic prevention period, facilities are required to continue to carry out applicable safety training to employees through online training platforms even if the operation is not fully resumed. The training must also include temporary workers.

In addition, the certificates of safety managers or personnel remains valid during the period even if passed the expiration, the safety managers and personnel can renew and complete the certification process within 3 months after the end of the epidemic prevention period. The end of Level I emergency response will mark the end of the epidemic prevention period.

China -


Facilities in Liaoning are required to take special measures at workplace to prevent and control the spreading of the coronavirus during the epidemic period. This follows from the policies published by several competent authorities in Liaoning. Of these are 20 Epidemic Prevention and Control Measures for Enterprises and Workers. For instance, measures for employers include, most importantly:

  • to ensure the worker is not infected before starting to work in the company;
  • to strengthen the health monitoring and inspection (such as temperature check-up);
  • to avoid people gathering during meetings, dining, resting or commuting time;
  • to develop an emergency plan and take action accordingly; and
  • to prepare epidemic prevention supplies (such as masks and hand soap).



Companies in Zhejiang are required to take special measures at the workplace to prevent and control the spread of the coronavirus during the epidemic period. This follows from the Zhejiang 17 Provisions on Operation Resumption and Epidemic Prevention and Control of Enterprises. Companies cannot resume their operation without approval from the local authority, except for the companies in key industries (such as pharmaceutical products manufacturing, transport, retail and telecom).

Companies resuming their operation are required to do the following (this is not an exhaustive list):

  • establish an epidemic prevention and control group, which consists of the main responsible persons of the company;
  • develop an epidemic prevention and control plan and an operation resumption plan, which must include detailed information on, for example, division of responsibilities, daily management and control, and emergency response;
  • report the abovementioned epidemic prevention and control plan, operation resumption plan and other material to the competent local authorities before the resumption;
  • establish a health declaration system and keep track of worker's traveling history and people contact history in the last 14 days.

United Kingdom

The Department for Business, Energy and Industrial Strategy recommends that the following general cold and flu precautions are taken to help prevent the spread of COVID-19. Facemasks are only recommended to be worn by symptomatic individuals (advised by a healthcare worker) to reduce the risk of transmitting the infection to other people. It is recommended that the best way to reduce any risk of infection is good hygiene and avoiding direct or close contact (closer than 2 metres) with any potentially infected person. Employees returning from affected areas are advised to self isolate for a period of 2 weeks and are advised to ring NHS 111 for advice upon return.

If someone becomes unwell in the workplace and has travelled to China or other affected countries, the unwell person should be removed to an area which is at least 2 metres away from other people. If possible, employers should find a room or area where they can be isolated behind a closed door. If possible, employers should open a window for ventilation. NHS 111 must be called.

It is not recommended that the company close, if a member of staff has or is suspected of having the virus, however the self isolation period of 14 days should be observed by any employee who has been in close contact with the affected person. The management team of the office or workplace will be contacted by the local Health Protection Team to discuss the case and a risk assessment of each setting will be undertaken by the local Health Protection Team.



Keep in mind that the above information is constantly developing and that employers must continue to check local authorities for the most up to date information. Enhesa's experts are writing about more than just these examples above. If you want more information on our forecaster service which provides emerging updates on these issues, please contact us below:


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