

As British Columbia moves toward re-opening and many workers head back to the workplace, WorkSafeBC has provided industry-specific guidance for developing COVID-19 workplace safety plans. In this article, we focus on the guidance for small businesses.
WorkSafeBC requires that all employers have a COVID-19 safety plan in place. If a formal plan is not in place prior to work operations beginning, employers must develop one. WorkSafeBC has provided a template COVID-19 safety plan which may be of assistance to employers. WorkSafeBC will review plans of employers during inspections of workplaces. Pursuant to the order of Provincial Health Officer Dr. Bonnie Henry, COVID-19 safety plans must be posted at worksites.
WorkSafeBC sets out six steps for developing a COVID-19 workplace safety plan. The first step is to assess the workplace in order to identify areas where there is risk of COVID-19 transmission. This assessment process must include frontline workers, supervisors and joint health and safety committees or worker representatives, as applicable. Assessments should be ongoing after work operations resume to ensure identification and management of risk. Issues that employers should consider at this first step of the process include:
The second step in developing a COVID-19 workplace safety plan is to implement measures to reduce risk. A primary method of reducing risk is to maintain physical distance among people whenever possible. Employers may consider:
Where it is not possible to maintain physical distance, employers should consider separating workers and/or members of the public with partitions or plexiglass. If other measures are insufficient, use of non-medical masks may be helpful.
Employers must ensure that measures for effective cleaning and hygiene are put in place and are reflected in their COVID-19 safety plan. Employers should provide workers with cleaning and hygiene supplies such as soap and water, hand sanitizer, disinfectant wipes, nitrile gloves and garbage bags. Employers should also ensure that there are sufficient washing facilities available for employees. In addition, employers should:
Employers must implement workplace policies which address who can be at the workplace, how to deal with illness arising in the workplace and how workers can be kept safe in adjusted working conditions. In particular, these policies should reflect the guidance from the Provincial Health Officer and the BC Centre for Disease Control regarding self-isolation. Those policies should include:
Other policy considerations include prohibiting or limiting visitors in the workplace and having a plan in place for what steps to take if workers begin to feel ill when they are at work.
Employers who have workers working from home must establish work from home procedures and policies to ensure worker safety. In our previous article “Workplace Safety During the COVID-19 Pandemic” we discuss the obligations of employers who have workers working alone or in isolation.
Employers should implement training and documentation protocols for COVID-19 safety. Staff should be informed of and trained regarding changes that have been made to work policies, practices and procedures due to COVID-19. Supervisors should be trained to monitor workers and the workplace to ensure policies and procedures are followed. Employers should retain records of that training.
Occupancy limits and reminders regarding handwashing practices should be posted on signage throughout the workplace. Signs indicating who is restricted from entering the workplace (such as workers with symptoms) should be posted at main entrances.
If new areas of concern regarding COVID-19 safety arise employers must take steps to update their policies and procedures. Workers should be involved in this process.
Employers must ensure that there is a process in place for workers to raise concerns about safety. In workplaces of 9 to 20 employees, this may be done with a worker representative. In workplaces of more than 20 employees, a joint health and safety committee must be in place and workers can raise concerns about safety through that committee. In workplaces of fewer than 9 workers, it is up to the employer to ensure that there are procedures in place for workers to raise health and safety concerns.
In workplaces that have not been operating, there may be additional risks that arise from restarting business. In such cases, employer should consider:
Employers are reminded that the Workers Compensation Act and the accompanying Occupational Health and Safety Regulations apply to all workplaces, whether employees are full-time, part-time, temporary or participating in the Work-Sharing program
When hiring temporary workers, employers should ensure that those workers:
Temporary workers should receive regular new employee orientation in addition to training regarding COVID-19 exposure risks and prevention policies that are in place in the workplace. Consider retaining additional records regarding temporary workers, particularly if those workers are also working elsewhere. Recording the details of temporary workers’ other workplace may help employers to assess and mitigate potential risks.
Where employers are hiring foreign temporary workers, they must abide by the Government of Canada’s Guidance for Employers of Temporary Foreign Worker Regarding COVID-19.
Workplace safety is at the forefront of employers’ and workers’ minds during the COVID-19 pandemic. Employers are reminded that workers in British Columbia have the right to refuse work, without being disciplined by their employer, if they believe the work they are being asked to do presents an undue hazard to their health and safety. We discussed the right to refuse work in detail in our previous article.
Our Employment Law team is eager to assist you in understanding your legal rights and obligations as workplaces re-open. To find out more about how the WorkSafeBC requirements apply to your situation contact our Managing Partner, D. Rodney Urquhart.
Read more EKB Updates about the legal implications of COVID-19 and the impact on B.C. business.