Author: Julie Bastian

Before joining Horton Law, I spent most of my legal career working as in-house counsel for a large privately-held global workforce solutions and business service company. I assist businesses with risk mitigation by analyzing their existing human resources policies and procedures and handling employment matters that come up. Nothing on the firm blog should be considered legal advice. If you need legal advice and think we can help, let me know!

June 23, 2020

New York Phase 3: Reopening Personal Care Services

In Phase 3 of New York’s reopening plan, businesses may resume providing “personal care services.” Activities in this industry group include

Tattoo parlors
Piercing facilities
Appearance enhancement practitioners
Massage therapy
Spas
Cosmetology
Nail specialty
UV and non-UV tanning
Waxing

Hair salons and barbershops could already reopen during Phase 2 under limited industry guidelines. But they may be able to expand their operations in Phase 3.

The industry-specific guidelines for personal care establishments fall into six categories: Physical Distancing; Workplace Activity; Protective Equipment; Hygiene, Cleaning, and Disinfection; Communication; and Screening. Summary Guidelines for personal care services include both Mandatory and Recommended Best Practices. The guidelines indicate that companies must also follow other CDC and DOH recommendations to protect workers and customers and prevent the spread of the coronavirus.

Physical Distancing

All of the personal care services identified above have a 50% occupancy limit for each location. This restriction applies to both personnel and customers. Workstations must be at least 6 feet apart from others, which may require businesses to modify their layout.

Employers must post 6-foot social distancing markers to remind workers and customers to keep space between them. These markings are especially crucial in commonly used areas such as around cash registers, places where employees clock in and out for their shift, locations where health screenings will occur, break rooms, and restrooms. Signs must direct traffic to reduce bi-directional foot traffic within the building and clearly identify exits and entries.

Businesses should implement an “appointment only” policy to control the number of individuals within the building at any one time. The use of waiting rooms is discouraged when possible, and companies should establish designated areas for pick-up and delivery. Customers should remain in their cars or outside until their appointment time.

Your business can find the maximum occupancy limit by locating the certificate of occupancy for each location. If your company is leasing the property, you can contact the landlord to obtain this information. The maximum occupancy applies to all tenants within a multi-unit building. You may need to consult with the building owner to determine what portion of the reduced occupancy limit applies to your business operations.

To comply with the 50% occupancy limit, businesses offering personal care services must consider alternative methods for reducing their workforce. Possible options may include adjusting retail hours, shifts, and schedules to limit occupancy.

Industry-Specific Suggestions

Businesses offering personal care services should consider posting customer instructions, lists for pricing and available services, and any other information that may assist in expediting the visit to the office. For example, tattoo and piercing parlors may want to consider posting their designs online or in a window display.

Nail specialty facilities should remove displays containing nail polish or any other products often handled by customers and clean and disinfect shared objects after each use.

Workplace Activity

Customers must continue to wear face coverings while receiving personal care services, including lip and nose piercing, face massages, facials, and waxing.

Guidance for Tattoo and Piercing Facilities

Businesses that offer tattoos and piercing must use brand new needles on each customer and clean and disinfect tools after each use. Follow the guidelines for cleaning and disinfecting set forth by the New York State Department of Health (DOH), the U.S. Occupational Health and Safety Administration (OSHA), and the Centers for Disease Control and Prevention (CDC).

Businesses offering nail specialty services and waxing must clean and disinfect the following items using an EPA-approved solution after each use:

Manicure and pedicure baths and bowls
Hand and foot drying tables
Wax containers and applicators
Towels, finger bowls, and spatulas

The use of disposable gloves is encouraged for mixing and sampling products, cleaning tools, and during application.

Salons that offer spa and massage therapy services must adhere to the following guidelines:

Clean and disinfect all rooms, linens, and face cradle covers after each use.
Customers must wear face coverings when receiving services and positioned face side up.
Close saunas, steam rooms, or any other services that occur in enclosed spaces where it is difficult to maintain social distancing or wear masks.
Clean and disinfect tanning beds and booths after each use.

Protective Equipment

All customers must wear face coverings unless they are under two years old or have a medical condition that restricts their ability to wear them.

Employers must provide face coverings to all employees at no cost and clean or replace them when necessary. Employers are also responsible for adequately training employees on how to use face coverings properly while at work. However, employees may wear personal face coverings. Employees must wear face coverings whenever they come within 6 feet of a coworker or customer.

Businesses should eliminate the sharing of objects or equipment. Where that is not possible, they must supply employees with rubber gloves to prevent the transmission of the virus.

Industry-Specific Suggestions

Individuals performing tattoo or piercing services must wear a surgical mask covering their nose and mouth, eye protection, and disposable gloves. The risk of transmission is much higher due to the type of service.

Hygiene, Cleaning, and Disinfection

Businesses offering personal care services must adhere to hygiene and sanitation requirements set forth by the CDC and DOH. These guidelines include providing and maintaining proper hand hygiene stations throughout the building.

Businesses must arrange for frequent cleaning at least after every shift, daily, or more frequently. Companies should pay particular attention to shared objects and surfaces and high traffic areas. This cleaning and disinfecting should be performed using the Department of Environmental Conservation (DEC) products recommended for COVID-19. A daily cleaning log should be maintained on-site and should include the date, time, and scope of cleaning and disinfection. Employees must also be provided with the supplies to clean and disinfect commonly used areas, shared equipment, and worksites before and after each use.

Businesses must perform a deep cleaning and sanitation as frequently as possible. This requirement may require companies to engage the services of a third party specializing in cleaning and disinfecting buildings.

Where possible, companies should increase the circulation of outdoor air while maintaining safety precautions.

Industry-Specific Suggestions

All workstations, reusable tools, and non-disposable instruments must be cleaned and disinfected between each use. There must be adequate time between clients to conduct proper cleaning.

Communication

Every business must develop a COVID-19 safety plan. New York State has created a safety plan template to use as a starting point. However, safety plans must be consistent with the business and facility.

Employers may include additional policies and procedures that will assist with slowing down or eliminating the virus’s transition. Once that is complete, the company must submit an affirmation confirming that they have read, understood, and intend to implement the guidelines.

All employees should be trained on the new protocols and educated on the importance of cleaning and sanitation, as well as the need to respect social distancing guidelines and wear face coverings, when appropriate.

Signs will need to be posted inside and outside of the retail locations to act as a constant reminder to customers and staff of the importance of proper hygiene, social distancing, appropriate use of PPE, and the mandatory cleaning and disinfecting protocols.

You can find many of the required signs on the CDC website. It contains printable posters for businesses to utilize related to the following:

How to protect yourself and others in public settings;
The importance of wearing face coverings;
How to safely wear cloth face coverings;
Symptoms of COVID-19 that individuals should look out for;
How to stop the spread of germs;
Facts about COVID-19; and
Hand washing.

Screening & Tracking

All employees and visitors should be subject to a mandatory health screening assessment. This screening should include questions about symptoms and an individual’s contact with COVID-19 patients. Employees must be tested for COVID-19 every 14 days while their Region remains in Phase 3 of the State’s reopening plan.

Screening can also include temperature checking, testing, and the collection of contact information. Companies cannot force customers and delivery personnel to participate in health screening, but should attempt to collect this information if possible. Remote screening before a person comes on-premises is ideal.

For situations involving positive cases or potential exposure, business operators must follow the DOH’s “Interim Guidance for Public and Private Employees Returning to Work Following COVID-19 Infection or Exposure”. The guidance, which is likely to change, includes instructions on how to properly clean and disinfect work areas after learning of a positive case and when employees may return to work after exposure.

Employers must keep a daily continuous log of all employees and visitors that enter the worksite. Where possible, companies should try to collect customer information as well. All individuals entering the building should provide their contact information for purposes of contact tracing. While it is not mandated, businesses should try to collect customer contact information. A communication plan should assign responsibilities for tracking visitors, collecting contact information, conducting mandatory health screenings, and provide clear instructions on how to report positive cases.

Next Steps for New York Businesses Providing Personal Care Services

If your business fall into this Phase 3 category, you must review the industry-specific guidelines and affirm that you have read, understood, and intend to implement them before reopening. You must draft and post a safety plan and put up appropriate signage. You also need a strategy to perform health screenings and assist in contact tracing when required.

Businesses that offer personal care services must designate a safety monitor responsible for ensuring compliance with the company’s safety plan and New York State Guidelines. Employers have to train individuals responsible for conducting the health screening, collecting contact information, performing contact tracing, and notifying the state and local health department of positive tests.

The company must also develop a plan for cleaning, disinfecting, and performing contact tracing if a positive case occurs. Minimum measures should include cleaning and disinfecting all heavy-transit areas and high-touch surfaces.

For our latest information on reopening your workplace and other issues of importance to New York employers, subscribe to our newsletter and follow Horton Law on LinkedIn.

June 16, 2020

New York Phase 3: Reopening Restaurants

Phase 3 of New York’s reopening plan allows restaurants and food service businesses to expand or resume operations. Reopening restaurants encompasses most food service establishments, including food trucks and concessions.

In Phase 1, food service businesses could reopen for takeout and delivery only. In Phase 2, restaurants could host diners in open outdoor seating, with restrictions. Once in Phase 3, they may resume indoor customer seating under State guidelines.

The industry-specific guidelines have been divided into five categories: Physical Distancing; Protective Equipment; Hygiene, Cleaning, and Disinfection; Communication; and Screening. Summary Guidelines for food services include both Mandatory and Recommended Best Practices. The restaurant guidelines also indicate that businesses must follow other CDC and Department of Health recommendations to help protect workers and customers and prevent the spread of the coronavirus.

Interim Guidance for Outdoor and Take-Out/Deliver Food Services During the COVID-19 Public Health Emergency

Interim Guidance for Food Services During the COVID-19 Public Health Emergency

Physical Distancing

All food service establishments are subject to a 50% indoor occupancy limit in Phase 3. This restriction applies to both personnel and customers. To achieve this, employers should consider reducing on-site headcount, adjusting work hours and shifts, prioritizing tasks to focus on those that allow for social distancing, and posting signs that provide clear directions to staff.

Outdoor seating capacity is restricted to the number of tables and seats that can be safely arranged with proper social distancing. Indoor and outdoor tables must be placed at least 6 feet apart. When this is not practical, businesses can install physical barriers between tables that are a minimum of 5 feet in height.

Employees must wear acceptable face coverings at all times. Patrons must wear face coverings unless they are sitting at their table. Everyone at the table must be part of the same party, up to a maximum of 10 people. Customers can sit at a bar or communal tables only if they can maintain 6 feet between them.

Restaurants must post 6-foot social distancing markers to remind workers and customers to keep space between them. These markings are especially crucial in commonly used areas such as cash registers, places where employees clock in and out for their shift, where health screenings will occur, break rooms, restrooms, and take-out windows. Restaurants should mark exits and entries to avoid confusion, ideally reducing bi-directional foot traffic.

Additional Physical Distancing Suggestions

Servers should have specific work areas to avoid unnecessary crossover. Kitchen staff assigned to prepare food, cook during the shift, or clean should be designated to one area for the entire shift. Management should train these employees on ways to reduce physical contact with food, shared surfaces, or other coworkers. If asocial distancing is not practical, restaurants can use physical barriers where it would not negatively affect airflow or block emergency and fire exits.

As in earlier phases, reopening restaurants should continue to enable customers to place takeout orders online or by phone only. Customers should remain in their cars until the food is ready for pick-up and take advantage of contactless orders, delivery, payment, and pick-up procedures.

Protective Equipment

Except when seated at their table, all customers must wear face coverings unless they are under two years old or have a medical condition that restricts their ability to wear them. This requirement applies, for example, for trips to the bar, restroom, outside, or to pay.

Employees must wear face coverings whenever they come within 6 feet of a coworker or customer. Employers must provide face coverings to all employees at no cost and clean or replace them when necessary. However, employees may wear their own face coverings. Employers also must train employees on how to use face coverings properly while at work.

Food service businesses should reduce the sharing of objects or equipment. Where that is not possible, they must supply employees with disposable gloves to prevent the transmission of the coronavirus. Staff should wear disposable gloves when handling food and replace them before switching to a new task. Workers must practice proper hand hygiene when disposable gloves are not being used.

Additional Protective Equipment Suggestions

Operators of food trucks and concessions without running water must require staff to wear disposable gloves, use hand sanitizer, and follow proper federal, state, and local food handling and hygiene requirements.

Hygiene, Cleaning, and Disinfection

Businesses offering food services must adhere to hygiene and sanitation requirements set forth by the Centers for Disease Control and Prevention (CDC) and the Department of Health (DOH). These requirements cover areas of the kitchen where employees may handle food preparation and serve customers, high-touch surfaces and equipment, and indoor and outdoor seating areas.

Restaurants must arrange for frequent cleaning at least after every shift, daily, or more frequently. They should pay particular attention to shared objects and surfaces and high-traffic areas. This cleaning and disinfecting should be performed using the Department of Environmental Conservation (DEC) products recommended for COVID-19. Restaurants must maintain a log that documents the date, time, and scope of cleaning and disinfection.

Restaurants must perform a deep cleaning and sanitation as frequently as possible. They may need to engage the services of a third party specializing in cleaning and disinfecting buildings.

Where possible, restaurants should increase the circulation of outdoor air while maintaining safety precautions–hence, the preference for outdoor seating.

Staff must be provided with hand hygiene stations that include soap, running warm water, and disposable paper towels, as well as an alcohol-based hand sanitizer containing 60% or more alcohol for situations where handwashing is not feasible. Signs near hand sanitizer stations should direct employees to wash visibly soiled hands with soap and water. Restaurants also need to ensure that receptacles for proper disposal of soiled items, including face masks and disposable gloves, are available.

Additional Cleaning Suggestions

Owners of food service establishments should consider switching to disposable menus. Reopening restaurants should also try to reduce the distribution of electronics to customers. These include buzzers used to notify customers that their table is ready and tablets used for digital menus or entertainment during the visit. Hand sanitizer should be readily available to customers, especially in high-touch areas.

Establishments offering take-out and delivery must implement the following:

Provide hand hygiene stations for takeout customers.
Require all staff to practice proper hand hygiene and use disposable gloves when necessary.
Increase ventilation of indoor takeout areas through windows or some other means.
Use single-use condiments and sauces whenever feasible. If not, staff must clean condiment bottles and containers after each use.

Communication

Once a reopening restaurant has read and digested the guidelines, it must determine how to implement them. Each business must develop a COVID-19 safety plan. The State has created a safety plan template to use as a starting point. However, each company should have a plan that is consistent with its business and facilities.

Employers may include additional policies and procedures in their safety plan that will assist with slowing down or eliminating the virus’s transition. Once that is complete, the company must submit an affirmation confirming that they have read, understood, and intend to implement the guidelines.

Restaurants must have signs inside and outside of the building to remind staff and visitors of the importance:

Covering their nose and mouth with a face covering.
How to properly store and, when necessary, discard PPE.
Adhering to physical distancing instructions.
The need to report symptoms of or exposure to COVID-19, and how they should do so.
The need to follow hand hygiene and cleaning and disinfection guidelines.
Following appropriate respiratory hygiene and cough etiquette.

Many of the recommended signs can be found on the Centers For Disease Control and Prevention website, located here.

Screening & Tracking

A mandatory health screening assessment must be performed on all employees and vendors that visit the worksite. The screening should include questions about symptoms and an individual’s contact with COVID-19 patients. It can also include temperature checking, testing, and the collection of contact information. The guidelines encourage employers to screen staff before they report to work, if possible.

Upon reopening, employers must keep a daily continuous log of all employees and vendors that enter the restaurant. The log should consist of contact information for anyone who had close contact with workers, unless they wore appropriate PPE. Businesses should attempt to collect contact information for customers, but they cannot mandate customers to provide it. Contact information will help facilitate proper contact tracing when necessary.

Food service establishments will be required to notify state and local health departments if a worker tests positive for COVID-19 or has had contact with an infected individual. In the event of a positive case, employers must cooperate with contact tracing efforts while maintaining confidentiality.

What Should New York Restaurants Do Next?

Restaurants and other food service establishments open in Phase 3 must review the industry-specific guidelines and affirm that they have read, understood, and intend to implement them before reopening. You must draft and post a safety plan and post appropriate signage. You also need a strategy to perform health screenings and assist in contact tracing when required.

Each food service business must designate a safety monitor responsible for ensuring the company’s compliance with the safety plan and reopening guidelines. Employers have to train individuals responsible for conducting the health screening, collecting contact information, performing contact tracing, and notifying the state and local health department of positive tests.

All reopening restaurants must also develop a plan for cleaning, disinfecting, and performing contact tracing if a positive case occurs. Minimum measures should include cleaning and disinfecting all heavy-transit areas and high-touch surfaces.

For our latest information on reopening restaurants and other businesses, subscribe to our newsletter and follow Horton Law on LinkedIn.

June 14, 2020

New York Phase 2: Reopening Offices

Phase 2 of New York’s reopening plan includes separate guidelines for offices and commercial building management. Where different entities own and operate portions of a commercial building, multiple parties have obligations related to keeping people safe within the building.

The industry-specific guidelines have been divided into five categories: Physical Distancing; Protective Equipment; Hygiene and Cleaning; Communication; and Screening. Summary Guidelines for these industry groups include both Mandatory and Recommended Best Practices. The office and commercial building management guidelines also indicate that businesses must follow other CDC and Department of Health recommendations that will assist in protecting employees and customers and prevent the spread of the coronavirus.

Office-Based Work

Companies whose core functions are performed in an office environment may reopen in Phase 2. But to do so, they must implement the mandatory requirements outlined in the NYS guidelines. These include businesses previously operating as essential businesses that fall into the office-based work category.

Office-based work typically includes these categories, as well as an office location that performs similar functions for a company even if it falls into another industry category:

Professional Services
Non-Profit
Technology
Administrative Support
Higher Education Administration (excluding full campus reopening)

NYS Summary Guidelines

NYS Detailed Guidelines

Commercial Building Management

This category covers all commercial and non-residential buildings in regions that have been permitted to reopen offices, including those that were previously operating as essential businesses. Since most commercial buildings have other industries operating within them, the guidelines for this business sector add to the requirements placed on a physical location overall. Thus, where one party owns the building and another or multiple others operate within it, several businesses may need to work together to satisfy the combined requirements for reopening offices.

NYS Summary Guidelines

NYS Detailed Guidelines

Physical Distancing Requirements

The mandatory health and safety guidelines address the physical distancing requirements for commercial building management and locations performing office-based work. Offices are restricted to no more than 50% of the maximum occupancy for the location, as set forth by the certificate of occupancy.

Individuals must stay at least 6 feet from each other at all times unless the core activity requires a shorter distance. If people must come within 6 feet of each other, they must wear proper face coverings.

Social distancing markers must be posted in all commonly used and other areas within the office where individuals may gather (e.g., health screening stations, clock-in/clock-out stations, or restrooms located within the office). Commercial Building Managers will be responsible for posting social distancing markers in any common areas throughout the building (e.g., restroom, elevator, lobby, health screening stations).

The use of confined spaces should be restricted to only one person at a time, unless all individuals are wearing proper face coverings. Even when utilizing suitable face coverings, no more than 50% of maximum occupancy will be permitted (e.g., elevators, restrooms). All non-essential common areas in the building and individual offices should be closed.

In-person gatherings must be limited to the extent possible. The guidelines encourage the use of tele- or videoconferencing. Shared workspaces should be eliminated or reduced to the extent possible. At a minimum, shared workspaces must be cleaned and disinfected between each use.

Employers in office-based environments should take advantage of alternate means to reduce interpersonal contact and congregations. Possibilities include adjusting workplace hours, only requiring essential staff to report to the office, modifications to employee shifts and office design, or changes to arrival and departure times.

Additional Physical Distance Requirements

Commercial building managers have some additional responsibilities. They must educate tenants on maximum occupancy limits for all rented or leased space and monitor compliance with the restrictions. They must inform tenants of social distancing requirements and of the need for wearing proper face coverings whenever a 6-foot distance from other individuals is not feasible. Depending on the terms of the lease agreement, building managers might be responsible for making physical altercations to the office space to allow for compliance with these requirements.

Protective Equipment Guidelines

Commercial building managers and employers overseeing locations with office-based work must provide employees with acceptable face coverings. They must provide masks at no cost to the employee and ensure that there is an adequate supply. They must educate employees on how to correctly put on, take off, and discard the face coverings.

Workers should avoid the sharing of objects, equipment, or workspaces whenever possible. These include items such as tools, laptops, touchscreens, printers, and writing utensils. Employers can either require workers that share objects and equipment to wear disposable gloves, provided at no cost by the employer, or clean and disinfect shared equipment between each use and provide employees with proper hand hygiene stations.

Additional Physical Equipment Guidelines

Commercial building managers will likely need to install physical barriers in any location where employees interact with the public, such as reception and security desks. OSHA recommends this measure.

Hygiene and Cleaning Guidelines

Commercial building managers and companies performing office-based work must adhere to the hygiene and sanitation requirements set forth by the Centers for Disease Control and Prevention (CDC) and the Department of Health (DOH). These protocols include providing and maintaining proper hand hygiene stations throughout the building. Hand hygiene stations include soap, running water, and disposable paper towels, as well as an alcohol-based hand sanitizer containing 60% or more alcohol for areas where handwashing is not feasible.

Offices must be adequately cleaned and disinfected using registered disinfectants, at least as often as employees and contractors change work stations. Commonly used or high-risk areas should be cleaned and disinfected even more frequently. Employers are responsible for conducting rigorous cleaning and disinfection at least after each shift, daily or more often.

Companies must establish procedures to follow for confirmed COVID-19 cases. These should cover the cleaning and disinfecting of the individual’s worksite and the surrounding area, all heavy transit areas, and high-touch areas (e.g., such as elevators, lobbies, building entrances, badge screeners, restroom handrails, and door handles).

Commercial building managers and tenants should refer to the terms of their lease for guidance on which party is responsible for complying with these requirements for reopening offices.

Communication Guidelines

Once the company has had an opportunity to read and digest the guidelines, it must determine to implement them in the workplace. They must develop a safety plan. New York State has created a safety plan template to use as a starting point. However, each business should have a plan that is consistent with their business and facilities.

Employers may include additional policies and procedures that will assist with slowing down or eliminating the transition of the virus. Once that is complete, the company must submit an affirmation confirming that they have read, understood, and intend to implement the guidelines.

Companies must train employees on the new protocols and educate them on the importance of cleaning and sanitation, as well as the need to respect social distancing guidelines and wear face coverings when appropriate.

Offices must have signs inside and outside of the building to remind staff and visitors of the importance of proper hygiene, social distancing, appropriate use of PPE, and the mandatory cleaning and disinfecting protocols.

Many of the recommended signs can be found on the Centers For Disease Control and Prevention website, located here. It contains printable posters for businesses to utilize related to the following:

- How to protect yourself and others in public settings;
- The importance of wearing face coverings;
- How to safely wear cloth face coverings;
- Symptoms of COVID-19 that individuals should look out for;
- How to stop the spread of germs;
- Facts about COVID-19; and
- Hand washing.

Screening & Tracking

Businesses reopening offices must implement mandatory health screening assessments for all employees and visitors. This screening should include questions about symptoms and an individual’s contact with COVID-19 patients. It can also include temperature checking, testing, and the collection of contact information. Remote screening before a person comes on-premises is ideal, if possible.

Those businesses located in a shared commercial building should coordinate with the building manager to help facilitate those screenings upon reopening offices. Some building managers could decide to organize mandatory health screenings for any individual that enters their building each day. By screening employees and visitors when they first enter the building, it would reduce potential exposure of an individual that was symptomatic or COVID-19 positive from interacting with others in the building’s common areas.

Employees who have COVID-19 symptoms and either tested positive for the virus or did not receive a test must remain home for a minimum of 14 days. An employee who does not have symptoms, but tested positive for the virus must self-quarantine for 14 days. If an employee had close contact with a person with COVID-19 for a prolonged period of time and is symptomatic, they must remain in quarantine for 14 days. An employee who had contact with an individual with COVID-19, but is not symptomatic, should also stay in self-quarantine for 14 days.

Upon reopening, employers must keep a daily continuous log of all employees and visitors that enter the worksite. The log should consist of contact information for anyone who had close contact with workers without using appropriate PPE. Businesses should attempt to collect contact information for customers, but they cannot mandate customers to provide it. Contact information will help facilitate proper contact tracing when necessary.

Next Steps for Reopening Offices

If you fall into one of these Phase 2 categories, you must review the industry-specific guidelines and affirm that you have read, understood, and intend to implement them before reopening. You must draft and post a safety plan and post appropriate signage. You also need a strategy to perform health screenings and assist in contact tracing when required.

Employers in shared commercial buildings should coordinate with building management. Individual companies may not have sufficient control over the premises to meet all State guidelines alone. Regardless, each business must designate a safety monitor that is responsible for ensuring compliance with the company’s safety plan. Employers must train individuals who will be responsible for conducting the health screening, collecting contact information, performing contact tracing, and notifying the state and local health department of positive tests.

Each company reopening offices must also develop a plan for cleaning, disinfecting, and performing contact tracing if a positive case occurs. Minimum measures should include cleaning and disinfecting all heavy-transit areas and high-touch surfaces.

For our latest information on reopening your workplace and other issues of importance to New York employers, subscribe to our newsletter and follow Horton Law on LinkedIn.