Practical Considerations for Reopening or Reoccupying a Business

As the world begins to emerge from emergency orders, businesses face challenges in maintaining continuity. With the potential for flare-up outbreaks, they need to be ready to alter their plans quickly and efficiently. Businesses that are prepared in advance may be positioned to recover with more resilience.

Reoccupying a closed building

The process to reoccupy a building begins before reopening day. Businesses that have been closed or have had equipment shut down for an extended time period may be required to undergo a health department reinspection. An accredited third-party expert will need to verify that equipment is functioning properly, that certifications and ongoing maintenance are current, and that there has been no vermin activity. 

One initial step is to review building operating status during building partial or full closure, e.g., vacancies, heating and cooling schedules, and set points. For example, water systems need to be flushed and tested, as they can have quality issues and can cause major health issues. Even the U.S. Centers for Disease Control and Prevention had to keep some of its offices closed in August 2020 due to the presence of Legionella bacteria, the pathogen that causes Legionnaires’ disease. 

Additionally, both potable cold and hot water systems need to be flushed and tested for quality. Potable water samples need to be collected by a trained professional to characterize post-flush water quality. Hot water temperatures should be sampled at the point of use. 

Ventilation assessments can determine if an issue, such as mold, has developed. An indoor air quality assessment, with emphasis on volatile organic compounds, may be a smart consideration. Assessments will determine if building systems are operating properly and providing adequate outside air for potential infection control. 

If the building requires additional air capacity, be aware that increasing airflow can affect the efficacy of opening and closing fire doors. Increasing air movement will pressurize corridors and stairs, potentially putting you in violation of the life safety code of the National Fire Protection Association (NFPA). A trained fire expert needs to test your fire protection systems if you have adjusted any heating, ventilation or air conditioning (HVAC) levels, added different types of filters or closed off vents.

With low occupancy, there will have been fewer reports of leaks and hygiene issues surrounding sinks, showers, toilets, kitchens, fountains, water coolers, refrigerators, janitor’s closets, accessible pipe chases and decorative indoor plant containers. These areas can all harbor mold or develop fungal issues. Outside water may have leaked through walls, windows, vents and roof membranes without notice, so they must be checked to reduce mold and building damage. You may want to perform a visual and infrared inspection of representative available surfaces for leaks/mold (ventilation, filtration and hygiene). 

Most buildings are adopting more frequent and thorough cleaning standard operating procedures (SOPs). It’s important to assess the use of any new/proposed cleaning products in rotation and review janitorial procedures and protocols, including environmental, health and safety considerations. New and returning staff should be trained well and provided with appropriate personal protective equipment (PPE).

Keeping the business open

The process of keeping a business open is far from static. One first step is to know what limitations the business might be facing. Regulatory guidance can vary from one jurisdiction to another and can change over time, so it’s crucial to obtain reliable information from local, state and federal regulatory bodies. If possible, business owners may consider joining or participating in a workgroup that helps set the guidelines and the site SOPs. This will allow them to provide important input, help shape the location’s response and provide early notification about potential changes.

In most countries, employers are obligated, legally and ethically, to provide safe and healthy workplaces. The stakes are high for continued operations. For example, a single employee who tests positive for an infectious virus in a facility without social distancing may cause the quarantine of all colleagues who were within 6 feet for more than 10 minutes over the two previous days. That can disrupt all the progress a business has made in reoccupying.

Frequent hand cleansing is one of the most important steps employees can take to help prevent the spread of illnesses. However, businesses would be making a mistake if they simply install hand sanitizing stations and believe they have addressed the issue. Sanitizer, with 60% or more alcohol content, helps protect from infection but is also highly flammable. The NFPA specifies that sanitizer dispensers may not be installed in exits, over ignition sources or over carpeted floors in rooms without sprinklers. They must be separated by not less than 48 inches and are limited in their liquid capacity. Adhering to these rules can decrease fire risk.

Finally, facility sanitization is an essential aspect of preventing the spread of illnesses. When approved sanitizers run low, some businesses turn to chlorine sanitizing agents such as unscented bleach. Bleach can be a highly effective sanitizer, but it can also be potentially hazardous when misused: specifically, when mixed with other cleaning products that contain ammonia, it creates a highly toxic chlorine gas. The cleaning staff needs proper training on how to mix and use cleaning solutions, use the appropriate PPE, such as wearing gloves or a protective outer garment and to provide appropriate ventilation in rooms where sanitizers are mixed and stored.

Specific industry challenges

While many reopening and reoccupying challenges will be similar between businesses, there are specific challenges within certain industries.

Commercial Real Estate: 

Commercial real estate companies face a daunting challenge in managing buildings with multiple tenants and vacancies. Managing unoccupied and partially reoccupied spaces require attention to HVAC and water issues. Any diversion of air or water flow must be carefully monitored to make sure that building systems are not disrupted, and regulations are met. As tenants return, any individual modifications to office space need to be monitored and evaluated. Social distancing measures should not interfere with emergency egress.

Any common spaces that tenants share, like lobbies and bathrooms, require special attention. Commercial real estate companies face considerable legal risk from diseases such as Legionnaires’ and have been found liable for exposures and infections. Because COVID-19 is so new, it is not clear yet how courts will rule. However, it may be a prudent decision to review liability clauses and update agreements with current and future customers. Companies should consult legal counsel to evaluate leases and make sure operations meet local, state and federal regulations.   

Hotels and Hospitality:

Hotels and hospitality companies need to understand how and when employees interact with guests and with each other. Close interpersonal interaction is no longer recommended, so they may need to alter the business model to reduce staff interactions. Additionally, they may need new PPE requirements, physical controls (such as temporary walls or shields) and changing SOPs. They may also need to limit the number of guests to a prescribed percentage of maximum building occupancy, limit the number in the elevators in use, and adjust the flow direction of entrances and exits. Limiting or changing access to common areas such as lobbies will also be an important new consideration. 

Any hotels or resorts with recreational swimming pools, hot tubs and saunas will need to monitor water quality and ventilation. Although its efficacy has not been tested with the coronavirus that causes COVID-19, properly chlorinated water has been known to kill viruses. It will be important to monitor pool chemical levels to meet accepted standards and limit guest access according to local, state and federal regulations.

Retail and Restaurants:

Guest occupancy limits, face-covering recommendations and single-directional aisles are here to stay, at least for the near term. Customers are likely to continue online shopping, which has its own set of challenges for food and delivery safety. It will be critical for retailers to obtain reliable information, specific to the store’s location and to follow local, state and federal mitigation guidelines. Trusted sources of such information include the National Institutes of Health (NIH), the Centers for Disease Control and Prevention (CDC) and the World Health Organization (WHO), plus state and local health departments.  

Retailers need to consider how and when employees interact with customers. Acrylic barriers at checkout lines are one method of physical control. Providing PPE and appropriate training on its use is another good method for maintaining infection control. As regulations relax, retailers need to evaluate what, if any, other changes should occur to keep safety at the forefront.

For critical employees who touch food, increasing handwashing frequency can help prevent the transmission of other types of illnesses beyond respiratory viruses. Employees should take care to wash their hands before donning gloves for any food preparation, after touching exposed skin, after handling soiled utensils, and after engaging in any other activities that could soil hands. All employees should be encouraged to wash and sanitize their hands frequently.

As regulations change, it is important for business owners to adapt and find trusted partners. There is no new normal, other than continual change. Companies that develop the flexibility necessary to anticipate and adapt will be best positioned for whatever the future holds.