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Michigan’s recent Executive Order (EO 2020-77 COVID-19), indicates that manufacturing companies must conduct daily entry screening protocols for workers, contractors, suppliers and any other individuals entering the facility. Under the Executive Order, various businesses are excluded from this requirement but are adopting this process as a safety measure for their employees. The risk and compliance experts at Axios HR have compiled a complete guide to COVID-19 employee health screening to help answer questions and provide guidance on key areas of concern.
Employee screening is the routine process of systematically reviewing each employee’s potential to carry or transmit COVID-19 based on observable or self-reported physical symptoms, an increased temperature, or their recent proximity to other potentially infected individuals.
The most recent Executive Order (EO No. 2020-77 May 7, 2020) mandates that manufacturing facilities conduct a daily entry screening protocol for workers, contractors, suppliers and any other individuals entering their facility. EO No. 2020-77 defines screening protocols as follows:
The screening protocols outlined in EO No. 2020-77 apply to “businesses or operations in the construction industry” and “manufacturing facilities.” However, all employers currently open for business can screen their employees, including small to large businesses, educational organizations and other employers.
Below is a list of basic recommendations for setting up access control, screening questions and temperature checking best practices.
Below are examples of screening questions that can be used by any employer to effectively screen for COVID-19 symptoms:
Nothing should be asked about an employee’s personal health history as this could cause disclosure of HIPAA-protected information.
According to EO No. 2020-77, screening should be conducted with touchless (temporal) forehead thermometers. Employees can submit responses to the screening questions verbally to be recorded by whoever is conducting the screening, or through an electronic application (as available).
Employers should also consider PPE and other protective equipment needed to create a safe environment for anyone conducting the employee screening processes (e.g. plexiglass barriers, etc.).
Manufacturing facilities must conduct daily entry screening protocol for contractors, suppliers and any other individuals entering the facility, which includes a questionnaire and temperature screening.
All visitors, suppliers and contractors, should be notified of your protocols prior to visiting your facility to prevent the spread of the virus.
Non-critical in person visits should be suspended. Businesses and operations that require in-person visitors critical to operations should follow their COVID-19 preparedness and response plan supporting safe distancing, limiting meetings.
Appropriate actions should be taken to protect other workers who are exhibiting symptoms. Therefore, it is important for employers to develop and follow their workplace policies and procedures to minimize the disease from spreading. For more information on developing a COVID-19 response plan, visit our article here. Best practices include the following:
Currently, no federal or state agency has recommended or mandated employers store or maintain health screenings for a specific period of time. If an employee tests positive for COVID-19 the healthcare provider that receives the confirmation of a positive test result is a mandatory reporter who will handle the reporting responsibility.
Under EO No. 2020-77 employers could be subject to sanctions to the fullest extent of the law.
Currently, no state agency has provided a timeframe on when this process will be discontinued.
Yes, for more information please inquire about Axios HR’s Workplace Health Screening services. Advantages of using a 3rd party screening system include a standardized, expedited process and single point of control for health information. If a 3rd party vendor is utilized, ensure that the provider is using compliant processes and coordinating with all required internal departments accordingly.
The ADA requires that any mandatory medical test of employees be “job related and consistent with business necessity.” Applying this standard to the current circumstances of the COVID-19 pandemic, employers may take steps to determine if employees entering the workplace have COVID-19 because an individual with the virus will pose a direct threat to the health of others.
Therefore, an employer may choose to administer COVID-19 testing to employees before they enter the workplace to determine if they have the virus.
No employee waiver or addition to an employee handbook is needed to screen employees as companies are not asking for any confidential medical information.
For more information on our Workplace Health Screening services, contact us here.
May 19, 2020
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