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New Guidance from Massachusetts on Reopening Office Space

By on May 20, 2020

Reopening The Office 

Under the Governor’s phased reopening plan office spaces outside Boston will be allowed to resume operations at 25% capacity beginning on May 25, 2020 and offices inside Boston may reopen at 25% capacity on June 1. Prior to reopening, businesses in all industries  are required to develop a written COVID-19 Control Plan outlining how the business will prevent the spread of coronavirus; sign and display a Compliance and Attestation poster informing visitors and employees that the business has developed and implemented procedures and protocols related to social distancing, hygiene, staffing and operations, and cleaning and disinfecting; and hang posters informing both employers and employees of the mandatory safety standards that have been established.

The Commonwealth released additional safety standards specifically for office spaces that must be implemented before workers are allowed to return to the office. The safety standards fit into four main categories; (1) social distancing; (2) hygiene protocols; (3) staffing and operations; and (4) cleaning and disinfecting.

Social Distancing

Initially, offices may only operate at 25% capacity. Capacity is determined either by the maximum occupancy specified by the office’s occupancy permit or the state building code, or the office’s typical occupancy as of March 1, 2020. Importantly, if the office has been operating as an essential business it must be in compliance with the occupancy requirements by July 1, 2020. Under limited circumstances related to public health and safety, or the provision of critical services, businesses may operate at a higher occupancy if there is a demonstrated need.

Businesses are encouraged to take creative approaches to social distancing and must take all practicable steps to ensure that individuals are at least six feet apart. Offices may need to be reconfigured to prevent congregating in common spaces, or to adequately separate workstations. Businesses should consider separating tables or desks, or by marking spots for people to work that are at least 6 feet apart. If work stations cannot be physically spread out, businesses must install physical barriers that are taller than standing workers.

If possible, businesses should create single-direction walkways and should assign workers specific physical locations to reduce movement and contact between workers. Moreover, businesses should consider staggering start, end, and break times to avoid large groups of people arriving and leaving at the same time, to prevent bottlenecks at exits and entrances, and to allow adequate social distancing in common areas.

Businesses must also take steps to create adequately ventilated spaces by opening windows and doors when possible. Only one person should be in a confined space at any given time. If more than one person must be in a confined space, all workers must wear a mask or face covering. To limit the use of shared, confined spaces, in-person meetings should be limited in quantity, duration, and attendance. Additionally, cafeterias may only serve pre-packaged foods. Businesses should limit visitors.

Hygiene Protocols

As from the beginning of the COVID-19 emergency, employees should be encouraged to wash their hands frequently and thoroughly. Businesses must make sure that employees have access to either handwashing facilities with soap and running water, or alcohol-based hand sanitizers with at least 60% alcohol. Employers should provide employees with cleaning supplies to keep their individual workstations clean and sanitized. High-touch surfaces must be cleaned at least daily, and workers should avoid sharing office equipment. If workers must share office equipment, the equipment should be disinfected after each use. Employers should post signs to regularly remind workers of the safety standards.

Staffing and Operations

Businesses will likely need to alter their operations to comply with safety standards and protocols. Businesses should provide training to workers on proper and up-to-date safety procedures relating to social distancing, hygiene, and cleaning. Workers should wear masks when social distancing is impossible and should continue to work at home if possible. Meetings should continue to be held virtually to enable social distancing.

Schedules should be staggered when possible to keep occupancy low. Visitors and on-site service providers should be limited, and businesses should create a designated shipping and receiving area to reduce contact between employees and outside workers. The business should keep a log of everyone that comes into the office, including temporary visitors, to enable contact tracing if someone in the office is diagnosed with COVID-19.

Most importantly, workers should be encouraged to stay home if they are feeling ill or experiencing any symptoms of COVID-19, or if they have been in close contact with anyone who has been diagnosed with COVID-19. If a worker tests positive for COVID-19 they should be encouraged to disclose their diagnosis to their employer so that the office can be properly cleaned and disinfected.

Cleaning and Disinfecting

The office should be cleaned daily, at minimum, but more often if possible. Businesses should keep a log that includes the date, time, and scope of cleaning to ensure that cleanings are completed regularly. High-touch surfaces such as doorknobs, vending machines, and elevator buttons must be frequently disinfected and shared spaces such as conference rooms should be cleaned in between uses. If a worker is diagnosed with COVID-19, the office must be shut down for a deep cleaning and disinfecting.

These guidelines from the Commonwealth are the minimum safety standards businesses must put into practice in order to reopen. Businesses are encouraged to be creative and to develop additional safety procedures and protocols in order to prevent the spread of COVID-19. By taking careful, meticulous steps to create safe workspaces, businesses can make their reopening process as smooth and uncomplicated as possible.

Meghan Hayes
Ms. Hayes is a 2019 graduate of Boston University School of Law. While in law school, Ms. Hayes worked with the New York State Attorney General’s Office, the Erie County Bar Association Volunteer Lawyers’ Project, and a prominent tort litigation firm in the greater Boston area.
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About Meghan Hayes

Ms. Hayes is a 2019 graduate of Boston University School of Law. While in law school, Ms. Hayes worked with the New York State Attorney General’s Office, the Erie County Bar Association Volunteer Lawyers’ Project, and a prominent tort litigation firm in the greater Boston area.