The "post-lockdown Protocol" amended
Following the new rise in COVID-19 cases, the "Post-lockdown Protocol" of 3 May 2020, already updated on 3 August 2020, has been amended.
The now "National protocol to ensure the health and safety of employees in companies following the COVID-19 epidemic" is a more permanent protocol intended to adapt the health rules to allow companies to resume their activity, applicable as of 1st September 2020.
Updated health measures to be implemented in companies on 1st September 2020
In addition to maintaining preventive measures (i.e. regular hand washing, coughing into one's elbow, using disposable handkerchiefs, greeting without shaking hands), the Protocol renews and/or adapts the following health measures in the workplace:
1. Wear a mask :
- The masks must be provided by the employer.
- In closed and shared
spaces : mask must be worn.
Adaptations to this general principle may be introduced to meet the specificities of certain activities or professional sectors after (1) carrying out an analysis of the risks of transmission of the virus and the preventive measures to be implemented and (2) discussions with staff and their representatives.
In any case, the possibility to temporarily remove the mask is subject to certain conditions depending on the level of virus circulation in the department where the company is located:
- Ventilation with proper operation and maintenance
- Protective screens between workplaces
- Wear a visor
- COVID-19 referent in the company and implementation of a procedure for the immediate care of symptomatic people
In addition to the above :
- Large volume premises
- High air extraction
In addition to the above :
- 4 m2 per employee (e.g. less than 25 people for a space of 100 m2)
- Mechanical ventilation
Thus, under certain conditions, the employee at his workstation
can sometimes remove his mask during the day while continuing his
activity. He is not allowed to leave his mask during the entire
For jobs that are not compatible with the wearing of a mask, a suitable framework may be defined.
- In other places :
- In individual offices : wearing a mask is not mandatory if there is only one person present.
- In the workshops : possibility of not wearing the mask if :
i. Ventilation with proper operation and maintenance.
ii. Limited number of people present in the work area.
iii. Wear a visor.
iv. Respect the greatest possible distance between them, including in their movements.
- Outdoors: mask must be worn in case of gathering or inability to respect the distance of one meter between people.
- In vehicles: the presence of several employees in a vehicle is possible if:
i. Everyone wears a mask (general public or surgical mask for people at serious risk).
ii. Hand hygiene.
iii. Regular cleaning / disinfection of the vehicle.
- In some places open to the public : As a reminder : mask must be worn, except in specific circumstances provided for by Decree of 10 July 2020 as amended, in some places open to the public, such as audition, conference, meeting, show or multiple-use rooms ; restaurants and drinking establishments.
2. Implement a periodic cleaning service plan with follow-up :
- The daily cleaning of floors and equipment is carried out according to the processes normally used in the company.
- Specific provisions :
For surfaces and objects that are frequently touched (by employees and/or customers) :
- "Frequent" cleaning (at
least once a day and at each rotation at the workplace) with a
SARS-CoV-2 virus killing product.
This includes furniture, equipment and utensils that are subject to bodily contact and may be contaminated. In particular: in common areas for doors, handles, switches, taps and collective equipment (e.g. coffee machines, dispensers, etc.).
- Hand hygiene before/after the use with soap and water (preferably) or hydro-alcoholic friction.
- Information of employees and customers (or other persons concerned by these procedures).
- It is possible to dedicate objects to an employee.
- For objects that cannot be cleaned or steam-cleaned (e.g. clothing and footwear) : temporary storage of objects (24 hours minimum).
- Particular attention must be paid to cleaning and disinfection of toilets (with provision of soap, disposable towels and a waste bin that must be emptied regularly).
For changing rooms :
- Hygiene measures and physical
distance of at least one meter to be respected (a "gauge"
can be used).
- The changing rooms (lockers) are for
- Daily cleaning with a SARS-CoV-2 virus killing product.
For floors :
- Daily cleaning.
Disinfection (in addition to cleaning) when the risk assessment justifies it, particularly in the event of active circulation of the SARS-CoV-2 virus in the company:
- Disinfection should only be carried out when strictly necessary (because the frequent use of disinfectants can create an imbalance in the microbial ecosystem, havesignificant chemical environmental impacts and constitute a risk for those who handle them).
- With a product that meets the virus killing standard (NF EN 14476 July 2019), or with other products such as bleach with a virus killing concentration of 0.5% active chlorine (e.g. 1 liter of 2.6% bleach + 4 liters of cold water).
- These operations will be carried out in accordance with the recommendations set out in INRS document ED 6347. In this respect, the Protocol gives several guidelines to be followed.
3. Ventilate enclosed spaces regularly :
- Regular ventilation of enclosed
spaces out of the presence of people :
- Ensure the proper operation and maintenance of the mechanical ventilation.
- A fan should not be used if the air flow is directed towards people.
- Air-conditioning systems, which must be maintained regularly, must avoid generating air flows towards people and must avoid recycling air, seeking the most efficient filtration from a health point of view.
- For work spaces and
public reception areas :
- Regular ventilation (for 15 minutes every 3 hours).;
- If not possible : ensure an adequate supply of fresh air through the ventilation system.
4. Respect physical distancing :
- Distance of one meter between an employee and any other person (e.g. other employee, customer, user, service provider, etc.).
→ Employers can apply a "gauge" defining the number of people who can be present simultaneously in the same space and posted at the entrance to the space (e.g. meeting rooms). For ease of use and to allow employees to remove their masks from time to time, the gauge may be set at 4m2 per person to guarantee a distance of at least one meter around each person in all directions.
- To respect physical distancing, the employer must :
- Seek to review the organization of the workspace and, if necessary, the organization of workers' time slots to avoid or minimize people gathering and crossover. Each employee shall be kept informed of these provisions.
- Define a flow management plan (that includes employees and customers, suppliers and service providers) with the implementation of incentive traffic plans aimed at making traffic flow more fluid rather than slowing it down (see "good practices" in appendix 1).
- The employer may set up transparent screens to separate employees from each other or from other people present in the workplace (customers, service providers) for certain workstations (e.g. reception, open-space).
Treatment of certain persons:
For employees at increased risk of adverse health effects related to COVID-19
- Limit contacts and business trips
- Give priority to working from home if possible (at the request of the employees and, if necessary, after a discussion between the general practitioner and the occupational health doctor, while respecting medical confidentiality).
→Opt for working from home also for employees who, without themselves being at risk of serious illness, live in the home of a person who is.
- If working from home is not possible
- Surgical mask provided by the company.
- Pay attention to regular hand hygiene of the employees.
- Fit out the workstation : dedicated office or limit the risk (e.g. protective screen).
- Possibility of requesting the occupational health service's help to study possible adjustments to the workstation.
- As of 1st September: possibility of resorting to short-time working for employees with very serious illnesses (listed in the decree of 29 August 2020) if the general practitioner deems it necessary.
For workers on secondment, seasonal workers, temporary workers and short-term contracts :
- Inform these persons on how the virus spreads, barrier gestures, physical distancing measures and health protection measures (which must be equivalent to those for the company's employees).
- In the case of accommodation of workers by the employer: check that barrier gestures are respected (e.g. by giving preference to accommodation in a single room).
- The obligation of vigilance on the part of project owners and purchasers also applies to the direct or indirect subcontractor with regard to compliance with the rules relating to health and safety at work, and therefore those relating to accommodation.
5. Draft a procedure for the immediate care of symptomatic people :
- The employer must, in cooperation with the occupational health service, draw up a procedure for the immediate care of symptomatic people:
- Isolate the symptomatic person in a dedicated and ventilated room wearing a surgical mask (+ : respect barrier gestures and keep a reasonable distance with him/her - at least 1 meter).
- Call the company's health professional, a lifeguard/rescuer trained in COVID risk or the COVID referent (wearing a mask before his/her intervention), depending on the company's organization.
- If the person doesn't show
signs of seriousness : call the occupational doctor or ask the
person to contact his/her GP for medical advice. If confirmation of
absence of signs of seriousness : organize his/her return home
avoiding public transport.
If the person shows signs of seriousness : call the SAMU (15) and follow several guidelines indicated in the Protocol.
- Once the person has been taken in charge : call the occupational health service and follow its instructions, including the cleaning and disinfection of the workstation and the follow-up of employees who have been in contact with the person.
- In the event of a confirmed case: the identification and taking care of contacts will be organised by level 1 and 2 contact-tracing actors (doctor taking charge of the case and Health Insurance platforms). Contacts assessed as "at risk" according to the definition of Santé publique France will be taken care of and placed in a fortnight (for 14 days after the date of the last contact with the confirmed case), except in special situations (professionals from health establishments or medical and social establishments, crucial operators, etc.). The contact-tracing actors can use the matrices of contacts in the company carried out by the referent for confirmed cases and, if necessary, on occupational medicine to facilitate the identification of contacts and their qualification ("at risk" or "negligible risk").
How to implement the health measures :
- Present them to the Social and Economic Committee (CSE).
- Circulate them to employees by memo.
- Possibility of incorporating them into the company's rules and regulations.
Originally published by Mayer Brown, September 2020
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