Human Resource Policy Considerations During a Pandemic

Since the April 2009 H1N1 outbreak, business continuity professionals around the world began the process of reevaluating their pandemic preparedness strategies. A commonly-identified preparedness activity is the evaluation of Human Resources policies. In the past, some organizations amended their policies to enable appropriate responses, others drafted amended policies but held them in reserve until a time when they may be necessary. Still others did nothing, hoping for the time to make amendments if needed.  However, with the rapid spread of the April 2009 H1N1 outbreak and its origination in North America, those organizations that chose to wait because they made an assumption that they would have time were greatly impacted. Human Resources policies, with appropriate content reflecting issues present during a pervasive public health event, were needed almost immediately due to heightened concern brought on by the media and government agency responses (i.e. school closures, social distancing recommendations, and additional sanitization measures). The purpose of this article is to equip business continuity professionals with the information necessary to partner with their Human Resources professionals in establishing (or amending) policies in preparation for a pandemic response, regardless of severity or locality.

Policy Recommendations
In evaluating organizational response to the 2009 H1N1 outbreak, Castellan’s professionals found that even though an organization’s “normal, day-to-day” Human Resources policies may be consistent with industry best practices and standards, some problems may exist which could degrade the organization’s pandemic response.

The U.S. Dept of Health and Human Services (HHS) and the Occupational Safety and Health Administration (OSHA) introduced recommendations to help organizations prepare for a pandemic. These policy recommendations / considerations include:

  • Defining select positions as critical to continuous operations and establishing specific duties and/or restrictions for employees in critical positions
  • Establishing “special circumstances” policy modifications including:                                      * Employee compensation/payroll continuation                                                              * Sick leave absences (including liberal leave and non-punitive, as well as                    caring for ill family members)                                                                                        * “Send home” policy for when employees become ill at work                                      * “Return to work” policy, including a method to verify employees are no                      longer contagious                                                                                                            * Telecommuting/flexible worksite considerations                                                        * Flexible work hours (staggered and/or multiple shifts)                                              * Visitor restrictions/bans
  • Defining which critical roles receive Personal Protective Equipment (PPE) and if families should / would be included
  • Establishing the employer’s ability to demand or recommend travel restrictions and geographical evacuations
  • Defining policies for employer childcare service restrictions (including shutting down on-site daycare programs)
  • Establishing policies related to vaccination mandates and recommendations

Other potential actions to take into consideration include:

  • Tracking sick employees
  • Tracking compliance and implementing disciplinary measures for employees who abuse sick leave or time off
  • Cross-training employees (OSHA recommends 3+ for critical positions)
  • Establishing and publishing hygiene “best practices” to prevent the spread of disease (cough etiquette, proper hand washing)
  • Establishing social distancing guidelines (separate desks, closed conference rooms and cafeterias, online conferencing, etc)
  • Establishing guidelines for increased facilities cleaning and contaminated waste disposal

Incorporating Recommendations
There are two approaches to consider when updating policies. One approach involves modifying each relevant, existing policy section to include exceptions or modifications that could occur during a pandemic. The other approach involves drafting a separate pandemic section or addendum that encompasses “everything pandemic” in one location.  This document could then either be inserted into the policy (once finalized and approved) or added to the policy when an appropriate trigger is reached. Triggers could include WHO Phase escalation, severity and locality of the outbreak, the implementation of public response strategies, or other organization-specific triggers. Business continuity professionals should engage in dialogue with their executive management teams to determine the triggers most suitable for their organization, as well as update their crisis management and / or pandemic plans to capture these triggers.

Regardless of when the pandemic-related policies are officially implemented, Human Resources should provide pandemic-related awareness communications so employees are familiar with and prepared for the policy change implications before implementation.

In Conclusion
The 2009 H1N1 outbreak put crisis management processes and pandemic preparedness strategies to the test. Upon reflection, many of those organizations with pandemic preparedness strategies, plans and policies realized that many of their assumptions were not appropriate for this particular event. The outbreak started near the United States and spread much quicker than expected. Those who did not have plans realized the need to address supplier, customer, employee, and other stakeholder concerns, even if the business was operating as normal.

A key part of preparedness is having as many answers as possible before the event. Due to a lack of advance planning, many Human Resources departments scrambled to provide executives with ad-hoc guidance as employees looked to their organization’s leadership for solutions. Future outbreaks demand organizations provide clear policies and strategies to respond to the unique challenges of managing an organization before, during and after a pandemic.

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