COVID-19 Cleaning Guidance for Employers

As the Coronavirus Disease of 2019 (COVID-19) stay-at-home orders start to lift, and business restrictions begin to relax, you may be considering how to ramp up operations and bring employees back to work safely and within compliance. Employers have a responsibility to protect their employees from potential COVID-19 exposure in the workplace. No matter what type of business you run, one of your main concerns should be creating or strengthening your site’s housekeeping plan.

Why Housekeeping?

The Center for Disease Control (CDC) has declared that housekeeping is an essential part of an employer’s strategy to protect workers from COVID-19. Enforcement agencies like The Occupational Safety and Health Administration (OSHA), Oregon Occupational Safety and Health (Oregon OSHA), and Washington’s Labor & Industries (L&I) have also stated that they will investigate any complaints against employers who are not taking appropriate steps to protect their workforce. Luckily, these agencies have also provided some helpful guidance on good housekeeping practices. When it comes to developing your housekeeping strategy, you do not have to waste time and resources fumbling in the dark.

Defining Key Terms: “Cleaning” vs. “Sanitizing”

Before you consider the contents of your program, it’s essential to understand that regulatory agencies like L&I and OSHA differentiate between cleaning and sanitizing. A compliant and robust housekeeping strategy will incorporate both. The CDC recommends using both cleaning and sanitizing in succession to adequately prepare surfaces and equipment for employee use.

Cleaning means removing dirt and grime, such as with a broom, vacuum, or mop, or scrubbing with soap, water, and a rag. Cleaning not only smooths surfaces so that germs cannot readily hide on them but also removes germs from the surface.

Sanitizing means applying a disinfectant to kill germs. The germs remain on the surface but are dead. When sanitizing, it is important to use a chemical approved by the Environmental Protection Agency (EPA) for use against the virus that causes COVID-19, called SARS-CoV-2. A list of approved products are found here. Additionally, a mixture of water and regular household bleach can be effective. Mixing 1/3 cup bleach with 1 gallon of water creates a combination that can kill SARS-CoV-2. Be sure to consider contact times as well. Chemicals take time (anywhere from 30 seconds to several minutes) to kill viruses. These times are noted on the EPA’s list of effective disinfectants.

Now, let’s go over how to develop a compliant and robust housekeeping strategy.

Developing a Housekeeping Plan

The CDC recommends that businesses establish a cleaning and sanitation strategy to help them implement a successful COVID-19 housekeeping regimen. Employers should document their cleaning and sanitation strategy as part of their COVID-19 response plan, which is part of their required Infectious Diseased Preparedness and Response plan. This strategy should include:

1. Identifying areas or items that may need to be cleaned and how often.
2. Identifying frequently touched surfaces or items that may need to be disinfected and how often.
3. Determining what resources and equipment will be needed.
4. Determining how and when the plan will be implemented

You will also need to develop procedures to address a suspected or confirmed COVID-19 exposure in the workplace. Housekeeping methods for this situation will likely go above and beyond your routine practices.

Considerations for the Plan Elements

Let’s go over each of the four plan elements in detail, paying close attention to the considerations you should make when developing them.

1. When identifying areas or items that may need to be cleaned and how often, consider how areas and items are used. Note any area or item that sees a lot of use, is accessible by the public, or gets dirty quickly. Use this information to create priorities in your cleaning regimen. Questions to ask include:
   • What are your site’s potential sources of infection (e.g., workers, vendors, delivered goods, etc.)
   • How many people go in and out of the area or use the item?
   • How dirty does the area or item typically get over time?
   • Is the area indoors or outdoors? Recent research suggests that the virus that causes COVID-19 does not survive long in sunlight or warm temperatures.
   • Does the general public access the area or item?
   • Are there any areas outside the main site that need attention, such as vehicles or satellite buildings?
2. Similarly, when identifying frequently touched surfaces and how often they may need to be sanitized, prioritize those that are touched the most or are most likely to be a source of infection, such as those surfaces handled by members of the general public. Common frequently touched surfaces include tables, light switches, doorknobs, shared equipment controls, and bathroom surfaces (sinks, toilet handles, etc.). Consider how well sanitizing will work on that surface and whether any specialized chemicals or techniques are required. Questions to ask include:
   • How many people typically touch the surface or item per hour?
   • Is the surface or item hard and non-porous? If not, specialized sanitation practices or additional equipment may be needed. For example, L&I states that soft, porous surfaces should be covered with single-use barriers or a hard surface that can be sanitized, while OSHA suggests using sanitizers appropriate for fabric or whatever the surface is.
   • Can the surface or item be damaged by frequent contact with certain chemicals?
3. The first two elements of your plan will help you decide what resources and equipment will be needed. This may include normal cleaning and sanitizing supplies, or any specialized chemicals or services needed for the disinfection of sensitive equipment or soft, porous surfaces. Additional questions to ask include:
   • Are the required cleaning and disinfecting supplies readily and continually available?
   • Who will be responsible for procuring supplies?
   • Will you need training resources to educate employees on how to use chemicals effectively and safely? OSHA requirements include implementing all Hazardous Communication (HAZCOM) regulations and following manufacturer-recommended usage and storage guidance in the chemical’s Safety Data Sheet or SDS.
   • Will you require additional PPE or equipment for cleaning personnel, such as gloves, goggles, ventilation, etc.?
4. Lastly, identify how and when your plan will be implemented. Ideally, once you have the details of your plan worked out, much of the how should already be addressed, and the when should be simple to determine. Questions to consider:
   • Who will perform the cleaning and sanitizing (e.g., cleaning staff, individual workers, every team member, etc.)?
   • How will you train workers to use chemicals safely?
   • How long has the site been closed? The CDC suggests that workspaces that have been empty and closed for seven or more days do not require any COVID-19 specific cleaning. However, regular housekeeping to get the area ready for operations is generally recommended.
   • When are employees returning to the workplace? At a minimum, your cleaning regimen should begin when the workforce returns.

Procedures for COVID-19 Exposure

Another plan element you should develop is what to do in case of a suspected or confirmed COVID-19 exposure in the workplace. For example, if a worker is sent home sick with a fever and cough or notifies the workplace that they have COVID-19, you should have a plan to perform additional deep cleaning. Take the following steps:

1. Identify any work areas the person occupied and any surfaces, tools, or equipment they likely touched. Keep other employees out of these areas and prevent them from using the same tools or equipment
2. Open doors and windows and then leave the area undisturbed for 24 hours to allow time for live viruses to die and respirable droplets to ventilate out. If this is not feasible, then allow the area to sit undisturbed for as long as practical. Consider if the area is connected to others via central ventilation and turn off access to and from this area if possible.
3. Clean and disinfect floors by sweeping and then mopping with an EPA-recommended sanitizer. Vacuuming can be performed instead, though the CDC recommends that vacuuming not occur in areas occupied by other people. Scrub surfaces (i.e., counters, tables, equipment, tools, etc.) with soap and water to remove dirt, grime, and germs. Afterward, disinfect with an EPA-recommended sanitizer. Pay close attention to any frequently touched surfaces.
4. Once cleaning and disinfection are complete, normal work can resume.

Running a business during a global pandemic is unchartered territory for most employers. There is a lot to stay on top of with new information about COVID-19 emerging every week. Developing a strong housekeeping plan should be just one part of your business’ overall strategy to navigate operations during COVID-19. If you need more guidance on anything from providing your workforce with appropriate personal protective equipment, implementing physical distancing practices, or even developing an Infectious Disease Preparedness and Response Plan, please reach out to the Archbright team at info@archbright.com.