INDIANAPOLIS—The novel coronavirus outbreak has elicited new and critical human resource, health and safety policies, forcing companies to make difficult decisions with immediacy.
Sometimes that involves posting a new policy, such as the Family First Coronavirus Response Act, an extension of the Family Medical Leave Act, which took effect April 1 and broadens the eligibility requirements for employees to receive paid sick leave. Or it might involve a critical medical response if an employee begins showing symptoms of COVID-19.
As such, three of the largest member-led associations in the rubber, mold-making and plastics industries have joined forces to publish an extensive resource manual addressing many of these unprecedented issues, using best practices submitted by member businesses and official guidelines issued by the Centers for Disease Control and Prevention, and by state and federal governments.
The Association for Rubber Products Manufacturers, Manufacturers Association for Plastics Processors and the American Mold Builders Association have issued the 300-page compendium known as the COVID-19 Policy Report, which contains pandemic procedures for nearly every stage of the supply chain.
"The response has been extremely positive. Members are using this to develop and update their own policies," said Ashley Turrell, analytics manager for ARPM who assembled the report. "We have companies who actually divvied up the report among four or five team members to identify best practices to improve their own policy. One company president told our team, 'Your support, knowledge, sharing, resources and community is such a blessing in a time like this.' Company leaders are looking for information, community and a way to help make sense of this situation."
The document is updated about once a week and alerts are sent to the hundreds of members of ARPM, MAPP and AMBA to notify them of updates, Turrell said.
Between the three associations, which typically are charged with offering industry studies, networking opportunities, company savings programs and best practices, 88 resources are compiled in the report, from internal and external communications with employees and customers, to infectious disease action plans and safety instructions.
The websites for each association offer a link to the report, at arpminc.com; mappinc.com; and amba.org.
According to Turrell, member companies are expressing three major concerns in their communications: care for employees and their families, cash flow reserves and maintaining morale and company culture.
First and foremost is safety, said Troy Nix, executive director of ARPM, MAPP and AMBA, all based in Indianapolis.
"I just want people to know that it's the little things in our lives that matter, and we as leaders need to understand it is the little things," Nix said in a March 25 podcast with Brennan Lafferty, group publisher of Rubber & Plastics News. "We're all going 100 mph. But now more than ever, it is the little things that matter, and we need to exercise human dignity toward one another."
And to exercise this care, businesses need to understand the rapidly evolving legislation, especially as it relates to the Families First Coronavirus Response Act and how it will impact their company and work force. Details on the legislation are offered within the COVID-19 Policy Report.
"Small- and mid-sized companies are now trying to understand how they can comply with this new ruling and still maintain their business operations," Turrell said.
Businesses also are concerned about dwindling cash flow, Nix said.
With the shocking slowdown across every industry, especially those in automotive or those who are deemed a "non-essential" service, companies are concerned because they only are operating at a 30-, 40- or 50-percent capacity, Turrell said.
But the supply chain determination as to what is "essential" can be ambiguous, according to Turrell.
"We actually put together a handout of what is considered essential by state for any state with a stay-at-home order to help manufacturers understand where their organization fits into that," Turrell said. "Overall, if you are serving any of those critical markets and you are part of that supply chain, you could be deemed an essential business—but once again, it is very specific depending on your geographic location."
In Michigan, essential businesses are a matter of interpretation, Nix added. A business farther down the supply chain could be deemed essential, if for instance a product is used to make another product in the medical or any of the aforementioned essential industries.
Thirdly, companies are trying to maintain their unique cultures in the face of the coronavirus chaos, and have offered their tips to doing so in the COVID-19 Policy Report.
"They want to make sure they are keeping their staff safe and protecting their people and their people's livelihoods, keeping morale high, maintaining culture, all while the whole world is dealing with a pandemic," Turrell said. "With so many new policies and social distancing guidelines, companies are looking for creative ways to make sure they are keeping their people healthy, respecting everyone's individual situation and managing employee morale and stress levels."
While the original policy report listed only one or two guidelines regarding official action if an employee tests positive for the virus, ARPM, MAPP and AMBA recently added another benchmarking report that has examples of policies and procedures, as dictated by the CDC.
"As the situation continues on, leaders know that it could be just a matter of time before someone in their facility contracts this, so having this published early was crucial," Turrell said. "This report also features resources from the CDC on cleaning guidelines to keep the rest of the team safe."
All entries that are submitted for the COVID-19 Policy Report, as long as they do not conflict with known guidelines, are included.
"It is the belief of our team that regardless of your current policy, there is always something to be learned by looking at the policies and procedures that have been put into place by other manufacturers," Turrell said. "Our goal is to provide members with as much information as possible, but in an organized, succinct way."
'Your obligation has increased'
Attorneys Alan Rothenbuecher and Johanna Parker from Cleveland-based Benesch, Friedlander, Coplan and Aronoff, offered advice on the Families First Coronavirus Response Act, CDC guidelines and other workplace-related topics surrounding the pandemic during a March 27 webinar, organized by ARPM, MAPP and AMBA.
The FFCRA applies to companies with 500 or fewer employees, is available to view on the U.S. Department of Labor website and offers six extended justifications for receiving paid medical leave.
According to the legislation, a full-time employee may use two weeks of the emergency paid sick leave if they are quarantined, a doctor advises the employee to self-quarantine, or the employee has COVID–19 symptoms and is waiting for a diagnosis. Under these circumstances, the employee must be paid at their regular rate of pay, up to a maximum of $511 per day or $5,110 total.
Employees also can use the emergency paid sick leave if they are caring for an individual under quarantine or medical self-quarantine, or if the employee is caring for a child whose school or place of care has been closed or is unavailable due to COVID-19 precautions.
The paid sick leave law expires Dec. 31, 2020, according to the legislation. According to Parker, who urged employers to give broad latitude in interpreting the paid sick leave eligibility requirements, the U.S. Department of Labor is not expected to enforce infractions of the law for the first 30 days, as long as an eligible employer is "operating in good faith."
"I would not be too punishing of folks to grant leave if they cannot give a form of medical paper work," Parker said. "In fact, we are urging employers not to require doctor's notes, as hospitals and offices are overrun and we don't want to take up resources there. My thought is to apply the law broadly."
In lunchrooms and on production floors, the CDC encourages 5S practices, social distancing, maintaining hand washing stations, keeping sanitizers on hand and keeping visitors out. Ohio Gov. Mike DeWine even has encouraged taking employees' temperatures.
"Normally, this is something that the Equal Employment Opportunity Commission does as a medical test," Parker said. "Now, in this situation, employers absolutely can do it. The biggest piece is how do we accomplish this? We need to be very careful not to put staff or another employee at risk when administering it."
Parker said employees either should take their own temperature or have a nurse or member of a medical staff on site to administer it. DeWine has suggested that the "threshold" temperature for concern should be 100.4 degrees or above.
And while the CDC has no power to enforce its suggested guidelines, they remain "strong suggestions" for employers, Parker said. "What was reasonable two weeks ago may not be reasonable today," she said. "I do believe your obligation has increased."
If an employee tests positive for COVID-19, the employer should notify their local health department.
"Know your local health jurisdictions so you can be proactive about understanding what local health departments are telling businesses," Parker said. "Maybe you can comply, and maybe not—but you at least have the knowledge and are not reckless in not acting."
Turrell said the COVID-19 Policy Report can augment such health department suggestions, and offers additional tried and true best practices.
"The policies and procedures, along with our peer crisis management calls, have revealed best practices across nearly every aspect of managing COVID-19," she said. "They include using medical grade, UV lights for sanitizing their workplace; companies using basic 5S principles to tape out safe, 6-foot social distancing guides on floors in the break rooms and on production floors; and companies actively practicing their pandemic response procedures, videotaping culture-building messages and playing them on the floor and sharing them with families."
One organization in food and agriculture has posters across its facility stating, "Thank you for helping to feed America!", Turrell said.
"What has stood out is that each organization, regardless of size or industry, has found ways to rally their troops and that nearly everyone is opening up and sharing with others across the industry," Turrell said. "Each organization has a varying amount of resources, so seeing the policies and best practices from such a large group of diverse manufacturers allows them to tailor the resources to fit their needs. People are dedicated to getting through this together."