New York State recently announced the process that businesses will need to adhere to in preparation for the reopening. Read on for details on reopening guidelines from New York State, as well as details on a webinar presented by Ferrara Fiorenza PC on this topic.
WEBINAR: Operating Your Business in the Shadow of COVID-19: An Employer’s Guide
Friday, May 22nd | 9 am
Click here for more information and to register.
Reopening your printing business depends on two factors:
(1) you must be located in a region of the state that has satisfied the metrics for loosening restrictions
(2) you as an employer have a COVID-19 Health and Safety Plan in place that details the methods and procedures that will be undertaken to manage COVID-19 risks to employees and customers in the course of operations.
Various elements of our economy have been identified and designated to open in phases, subject to conditions 1 and 2 above. Printing has been designated as a manufacturing industry and has been included in Phase One with eligibility for regional reopening determined on Friday, May 15, 2020. Again, to be considered for reopening, you must be physically located in a region that satisfies the reopening criteria.
If your region has or is close to satisfying the metrics for reopening, you need to start developing your company specific reopening plan! The COVID-19 Health and Safety Plan must describe the ways in which you intend to comply with applicable guidance to safely reopen your printing business. Here is a link to a Region by Region analysis of the health metrics that will control reopening: https://forward.ny.gov/regional-monitoring-dashboard
Factors You Must Consider in Developing Your Reopening Plan
Under New York Forward, each employer reopening its business must create and implement a COVID-19 Health and Safety Plan to protect employees and consumers, make their facilities or other physical worksites safer, and implement processes designed to lower the risk of potential infections occurring at their business.
New York Forward sets forth three main requirements that businesses must include in their COVID-19 Health and Safety reopening plans:
1. Protections for employees and customers – These include possible adjustments to workplace hours and shift design as necessary to reduce density in the workplace; enacting social distancing protocols; and restricting non-essential travel for employees.
2. Changes to the physical workplace – Requiring all employees and customers to wear masks if in frequent close contact with others and implementing strict cleaning and sanitation standards.
3. Implementing processes that meet New York State’s changing public health obligations – Screening individuals when they enter the workplace, or reporting confirmed positives to customers. While these processes will vary from business to business, all will have to adapt in some way to the new normal.
Important Information on Developing Your COVID-19 Health and Safety Plan
Each reopening business must develop a written Safety Plan outlining how its workplace will prevent the spread of COVID-19. A business may fill out this template to fulfill the requirement, or may develop its own Safety Plan. This plan does not need to be submitted to a state agency for approval but must be retained on the premises of the business and must made available to the New York State Department of Health (DOH) or local health or safety authorities in the event of an inspection.
• Template COVID-19 Health and Safety Plan available – Click here to download the template plan developed by New York State.
• Additional guidance on procedures to incorporate into your plan – In developing and implementing these plans, employers should incorporate procedures to follow Center for Disease Control recommendations (CDC), New York State Department of Health guidance, applicable safety regulations under the Occupational Safety and Health Act (OSHA), and other evolving federal, state, and local public health and COVID-19 safety guidelines. Proper employee training will also be critical to the effectiveness of the Plan. Click here to download some helpful guidance from NYS on steps to take when developing your plan. Printing Industries Alliance can assist you in locating additional information on procedures and regulations to safeguard your workplace.
• Frequently Asked Questions – New York State has created a preliminary FAQ page regarding New York Forward and business reopening. It has begun to provide specific information, guidance, and requirements, including: (1) businesses that previously qualified as “essential” are subject to the reopening plan requirement going forward, and (2) there are no waivers for businesses (including essential businesses) that cannot comply with the current guidance.
• Detailed Guidelines and required affirmation that you have read and understand what needs to be done to reopen your printing business – Again, each reopening business must develop a written Safety Plan outlining how its workplace will prevent the spread of COVID-19. A business may fill out this template to fulfill the requirement, or may develop its own Safety Plan. This plan does not need to be submitted to a state agency for approval but must be retained on the premises of the business and must made available to the New York State Department of Health (DOH) or local health or safety authorities in the event of an inspection. Click here to download manufacturing master guidance and to submit required affirmation to New York State.
Responsible Parties must conspicuously post completed safety plans on site.
We expect the State to continue to supplement its guidance and requirements. Therefore, employers are encouraged to check the website regularly for additional updates. Additionally, the FAQ page directs businesses with immediate questions to contact their regional office of Empire State Development, and provides specific contact information by region.
Timothy Freeman, President
Printing Industries Alliance
Cell: (716) 983-3826
Office: (716) 691-3211
Toll Free: (800) 777-4742