NY State has asked businesses to state their compliance with New York Forward’s reopening guidelines by submitting an online form (https://forms.ny.gov/s3/ny-forward-affirmation). It is way too early to know if and how these guidelines will be monitored, but it is important to know what you are signing up for.
This blog focuses on the required records that are explicitly stated in this guideline, of which we have found just 4 statements. Each of these is listed below along with practical solutions for the creation and management of these records:
Note: The attached PDF is a copy on NY State’s master guideline document with the 4 requirements highlighted in red: Manufacturing Master Guidance – Required Records
- (Section III. Processes – A. Screening and Testing) “Responsible Parties must review all employee and visitor responses collected by the screening process on a daily basis and maintain a record of such review”
- The biggest challenge for organizations will most likely be the daily review of employee responses as the review of visitor responses will be a less frequent and more in line with your current visitor onboarding process
- Assuming your employees are providing daily responses, a record needs to be generated that their responses have been reviewed
- Utilizing a typical paper based visitor log (or spreadsheet), the addition of two fields for the initials of the authorized approver and date should be sufficient
- If the individual responses are being recorded, these should also be saved and available as records
- (Section III. Processes – A. Screening and Testing) “An employee who has responded that they have had close contact with a person who is confirmed or suspected for COVID-19 may not be allowed to enter the site without abiding by established precautions and the Responsible Parties has documented the employee’s adherence to those precautions”
- Company needs to first have a document that identifies all of these establish precautions
- A new form should be created denoting this adherence and include the following:
- Check boxes for each of these precautions
- Exposed person’s name
- Status designating approval
- Signature/initials of recognized approver(s)
- (Section II. Places – B. Hygiene and Cleaning) “Responsible Parties must maintain cleaning logs that include the date, time, and scope of cleaning”
- Most companies may have this already logs that include the date, time, and scope of cleaning
- Suggest creating an updated cleaning policy/statement that includes all of the new guidelines
- Strongly suggest maintaining a record of any training which may confirm that the individual(s) performing the cleaning have been trained to the new cleaning policies
- Would be nice to also have a record stating that their cleaning activities have been audited and confirmed to conform to the new cleaning policy
- (Section III. Processes – A. Screening and Testing) “To the extent possible, responsible parties should maintain a log of every person, including workers and visitors, who may have had close contact with other individuals at the work site or area”
- This by far is the hardest record to accurately maintain as the complexity of this solution will vary based on the size of your organization and the number of employees & visitors
- Maintaining a record of visitors entering your building is the easiest task; a previous Insyte blog suggested that this could be managed using a paper sign in log sheet or as part of a visitor management software system
The biggest challenge is coming up with a simple and effective way to generate daily records of people that others may have come in close contact with. There is no defined expectation as to the amount of information that needs to be captured in this log on a daily basis. The best approach may be to start with the end in mind.
Assuming an employee tests positive, how much information would you want to know about their whereabouts and/or close contacts?
Which employees would need to be tested as part of your remediation plan?
How much potential down time or administrative contact tracing time can be saved if you can accurately determine these close contacts?
This particular log should contain the level of detail your particular remediation plan requires, and no more. Let’s assume your remediation plan requires you to know the general areas that someone has worked but does not need to know definitively the people that have come within 6 feet of that individual. Here is an example of an approach that could be quickly implemented with little cost:
- Break down a facility into quadrants or areas
- Production (larger areas should break this into more detailed areas)
- Determine if you want this log to cover common areas (if so, add to above list)
- Identify people that primarily work out of each area
- (as best as possible) Limit visitation into each area to only essential employees/visitors and reduce the number of entry points into each of these areas
- Place video cameras at each entry point
- Establish a policy covering the retention period of the videos being recorded and identifying the individuals responsible for archiving these daily recordings
- Having separate video cameras capturing both the incoming and outgoing faces will provide specific times of people entering and leaving a particular area
We are all in this together; if any of our clients or partners have successfully implemented changes regarding these concepts and are willing to share with the WNY manufacturing community, we are asking you to submit them to us and we can share these best practices with all the manufacturers in our community. Descriptions, photos, examples, etc. would be beneficial and we can give you credit for any submissions that would be published.
Please submit any ideas to: firstname.lastname@example.org
Read more of Insyte’s #ReopenWNY blog series:
Reopen WNY: Covid-19 Visual Controls – As your employees start coming back and settling into their existing or new jobs, the time is right to think about enhancing your visual controls.
Reopen WNY: The New Office Environment – With an estimated 60+% of employed Americans working from home during the pandemic, the latest wave of change surrounds getting these people safely back to the office.
Reopen WNY: Touchless Visitor Sign In – If you are considering a visitor management system, this blog highlights those that offer touchless options & are compliant with NYS COVID-19 guidelines.
Reopen WNY: Workplace Activity – As manufacturers work to reopen their facilities and begin production, New York state has issued the Reopen NY Master Guidance for Manufacturing Activities.
More from our blog: click here.