The entrance to Barnstable Town Hall, in Hyannis, Mass.

It’s been two months since city and town halls have been fully staffed with their doors open to the public.

While office spaces may reopen on May 25 during the first phase of the state’s reopening plan, the centers of local government activity, when they do decide to open, will look quite different than they did before the COVID-19 state of emergency.

Occupancy
For starters, municipal buildings are subject to the 25% occupancy limitation imposed on office spaces in the state’s new Sector-Specific Workplace Safety Standards.

According to the Department of Labor Standards, municipalities “should limit occupancy of municipal office spaces to 25 percent of (a) the maximum occupancy level specified in any certificate of occupancy or similar permit or as provided for under the state building code; or (b) the business organization’s typical occupancy as of March 1, 2020.

“However, if a municipality designates a municipal office as a ‘COVID-19 Essential Service,’ which it has discretion to do, then that Office has until July 1, 2020, to comply with the 25% occupancy limitations.

“Further, a municipality may determine that a municipal office can exceed the maximum occupancy level if the municipality determines that it is in the interest of public health or safety considerations, or where strict compliance may interfere with the continued delivery of a critical service, as determined by the municipality.”

The DLS has clarified that the 25% occupancy limit is per office space and not by building. While essential service offices have until July 1 to comply, they’re advised to do so as soon as they’re able.

The state plan does not require any business – or city or town hall – to reopen.

Plans, posters, supplies and training
The state’s reopening plan is designed to be self-compliant. Like all employers, cities and towns are expected to:
• Use a template to develop a COVID control plan.
• Acquire the required supplies (such as face coverings and sanitizers).
• Conduct employee training.
• Display compliance attestation posters and checklists to assure both employees and visitors that the workplace is in compliance.

The two-page control plan template must be filled out to indicate that the workplace is complying with the mandatory safety standards for operation in the COVID-19 reopening period. The template asks for business contact information, a human resources contact, and the number of employees on site. It then includes a list of check boxes in the areas of Social Distancing, Hygiene Protocols, Staffing and Operations (covering items such as training and what to do when an employee is ill), and Cleaning and Disinfecting. Control plans do not need to be submitted for approval, but must be kept on premise and made available in the case of an inspection or outbreak.

The single-page attestation poster is a four-item list, with assurances about face coverings and social distancing, hand washing capabilities and sanitization, staff training, and cleaning and disinfecting protocols. The attestation poster should be displayed in an area on the premises that is visible to employees and visitors.

The two-page COVID checklist for office spaces goes into additional detail on the four main areas covered in the attestation poster.

The employee training would explain the social distancing and hygiene protocols that have been put in place to comply with the state’s mandatory health and safety requirements, according to the DLS.

Department of Labor Standards Director Michael Flanagan assures local leaders that the compliance standards “may sound more daunting than they really are.”

“It’s a half dozen checkboxes, you make sure that you’re meeting all those requirements, you check the boxes, you sign it, you post it, and that’s what self-certification is,” he said. “It’s not a particularly arduous process.”

Regarding training, he said, “this doesn’t need to be a full-blown day of training. This can be 15 maybe 30 minutes of training that is no more elaborate than what your specific protocols are in order to meet the reopening requirements and the self-certification requirements.”

General guidance
Like all businesses in Massachusetts, cities and towns are expected to continue and encourage social and hygiene practices that have become new habits over the past two months, such as hand washing and distancing, and to continue remote-work practices where feasible.

Employers must do the following:
• Ensure that all persons, including employees, customers and vendors, remain at least 6 feet apart to the greatest extent possible, both inside and outside workplaces
• Establish protocols to ensure that employees can practice adequate social distancing
• Post signage for safe social distancing
• Ensure frequent hand washing by employees and provide adequate supplies to do so
• Require face coverings or masks for all employees
• Provide regular sanitization of high-touch areas, such as workstations, equipment, doorknobs and restrooms
• Establish and maintain cleaning protocols specific to the business
• Ensure that employees who are displaying COVID-19-like symptoms do not report to work
• Ensure that cleaning and disinfecting is performed when an active employee is diagnosed with COVID-19
• Establish a plan for employees getting ill from COVID-19 at work, and a return-to-work plan
• Prepare to disinfect all common surfaces at intervals appropriate to said workplace

Areas where workers are likely to congregate (e.g., break rooms, eating areas) need to be closed or reconfigured to allow 6 feet of physical distancing, and cafeterias may operate only with prepackaged food.

Physical partitions must separate workstations that cannot be spaced out.

Meeting sizes should be limited to ensure distancing, and remote participation should be encouraged.

Staggered work schedules, lunches and break times may be required to meet safety standards.

Workers are required to wear face coverings in cases where they cannot maintain a distance of 6 feet, such as in elevators, control rooms and vehicles.

Directional hallways for foot traffic, and visible signage, are recommended to minimize contact.

Workplace locations must stock cleaning products such as sanitizers and disinfecting wipes.

The sharing of office materials and equipment is discouraged.

Signage should be posted throughout the site to remind workers of the hygiene and safety protocols.

The DLS has created a web area for COVID-19 workplace safety rules.

Questions can be directed to the DLS hotline at 508-616-0461, ext. 9488, or safepublicworkplacemailbox@mass.gov.

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