By Conn Maciel Carey’s COVID-19 Task Force
On May 1, 2020, Governor Wanda Vázquez Garced of Puerto Rico issued a COVID-related Executive Order (“EO 2020-038”), which imposes a number of requirements upon employers, included among them that every employer must develop a comprehensive, site-specific COVID-19 exposure control plan prior to reopening. The Executive Order also makes clear that employers already open under prior exemptions to prior lockdown orders must also prepare a plan and must do so as soon as possible.
To implement the Executive Order, the Puerto Rico Secretary of Labor issued Circular Letter 2020-03 (“CL 2020-03”), setting forth the elements that must be covered in the plan, including the requirement that the plan be “exclusive to [your] particular workplace.”
There are 22 total elements that must be covered, including the requirements that the plan:
- Be a written document, specific to the workplace and contemplates the particular tasks, the physical structure and the number of employees.
- Include recommendations issued by local, national and international health agencies regarding controls to prevent the spread of COVID-19.
- Detail the monitoring and/or screening process of personnel prior to entering the workplace.
- Indicate the control measures that will be taken to achieve the physical distance between employees and clients/public.
- Indicate how adequate ventilation will be provided to ensure adequate air flows and, in locations with air conditioning systems, effective filtering.
- Include and detail the method that will be implemented for Continue reading