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Massachusetts Safety Standards for Office Spaces During the COVID-19 Reopening Period

On May 18, Governor Baker announced the State’s Plan to safely reopen the Massachusetts economy, while minimizing the health impacts of COVID-19. The guidance includes mandatory sector-specific standards and recommended best practices for sectors that are eligible to open in Phase 1. In my May 20th blog, I discussed the Safety Standards for Laboratories. Since that blog was posted, the State has clarified that offices associated with laboratories must comply with The Safety Standards for Office Spaces. Like the Safety Standards for Laboratories, these standards are organized around four categories: social distancing, hygiene protocols, cleaning and disinfecting, and staffing and operations.

Social Distancing

Social distancing requirements for offices include limiting occupancy within the office space to no more than 25% of the maximum occupancy limit specified in the certificate of occupancy, or the typical occupancy as of March 1, 2020. Any business or other organization that has been operating as a “COVID-19 Essential Service” as of May 18, 2020 shall have until July 1, 2020 to comply with these occupancy limits. In addition, businesses and other organizations may exceed this maximum occupancy limit if there is a demonstrated need for relief based on public health or public safety considerations, or where strict compliance may interfere with the continued delivery of critical services. (Note that these occupancy limits are not applicable to laboratory space.)

Other office social distancing requirements are similar to those for laboratories including ensuring separation of six feet or more between individuals, unless this distance is unsafe due to the nature of the work or configuration of the workspace. This may require closing or reconfiguring worker common and high-density areas such as eating areas, and redesigning workstations including the use of physical partitions (must be taller than a standing worker). Directional hallways/passageways should also be established where possible with clearly visible signage regarding the policy.

In addition, designated work areas should be assigned where possible to limit movement throughout the facility. Lunch and break times should also be staggered and the use of confined spaces such as elevators by more than one individual should be minimized. The number of visitors should be limited where feasible and people should avoid congregating in common areas (e.g., lobbies). Office meeting sizes should also be limited to ensure six feet of social distancing; remote participation is encouraged.

Hygiene Protocols

Hygiene protocols for office spaces are similar to those for laboratories and require that employers ensure access to handwashing facilities including soap and running water and/or provide alcohol-based sanitizers with at least 60% alcohol. In addition, the sharing of office material and equipment such as telephones and fax machines should be avoided, or they must be disinfected between use. Visible signage must be posted throughout the site to remind workers of the hygiene protocols.  Employers must also provide disinfecting wipes and other supplies to conduct the required cleaning and disinfecting discussed below.

Cleaning and Disinfecting

Employers are required to conduct cleaning and disinfection of the facility at least daily and more frequently if feasible. They must also ensure regular cleaning and sanitation of all high-touch areas such as workstations, door handles and restrooms. Shared spaces such as conferences rooms must be cleaned between uses. Cleaning logs that include the date, time, and scope of the cleaning must also be maintained. In the event of a positive case, the facility is required to be shut down for a deep cleaning and disinfecting in accordance with current guidance unless the individual who tested positive has not been onsite for seven days.

Staffing and Operations

Requirements include the use of face coverings where six feet of social distancing isn’t possible, except where doing so may be unsafe due to a medical condition or disability. (Note that the Workplace Safety Standards for Laboratories requires face coverings even when six feet of social distancing can be maintained.) In addition, office workers should continue to telework if feasible and external meetings should be remote to reduce office density. For employees that do have to be onsite, adjusted workplace hours and shifts with teams working on different schedules or with staggered arrival times should be put in place.

Employers should also limit visitors and service providers on site, and shipping and deliveries should be completed in designated areas. Everyone who does come in contact with the site should be logged to enable contact tracing, including temporary visitors such as delivery personnel.

All businesses in Massachusetts must develop a written COVID-19 Control Plan that outlines how their workplace will comply with the requirements of the Safety Standards for their particular sector as well as federal, state, and local guidelines. The Plan must include contact information for local health authorities and procedures for isolation, contract tracing, and communications if a worker is diagnosed as positive with COVID-19, or comes in close contact (within 6 feet for 10 minutes or more) with an individual diagnosed with COVID-19.

Training on the COVID-19 Control Plan is also required. This training must include the importance of: social distancing, handwashing, and proper use of face coverings; self-screening at home (e.g., temperature and symptom checks); not coming to work when ill; as well as information on when to seek medical attention and which underlying health conditions may make individuals more susceptible to COVID-19.

For additional information on the Massachusetts Safety Standards for Office Spaces, or for assistance with your company’s written COVID-19 Control Plan and training, please email [email protected].

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