COVID-2019 Safe Operation Standard

MEDIA, PUBLICATIONS \ 02.06.2020

Organizations that have resumed their activities since May 12, 2020 or continue their work, including in remote mode, are obliged to draw up a safe operation standard in order to counteract the spread of coronavirus infection. Acsour specialists will tell for what this document is necessary for and what provisions it should contain.

What does the Standard mean?

A Safe Operation Standard is an internal local document that regulates the main actions of employees at work during the coronavirus infection epidemic. Suсh actions will allow the spread of coronavirus infection among the company’s personnel to be reduced.

The document is valid on the basis of an approved Order, which employees will need to be familiarized with against their signature.

Please note that the Standard should be drawn up by those companies that operate in St Petersburg and are not subject to the prohibitions and restrictions established by Decree No.121 of the Government of St Petersburg dated March 13, 2020.

What is the procedure for drawing up a Standard?

The procedure for drawing up the standard is the same as for other internal regulatory documents (IRD) of the company. There is no unified form; therefore, companies may develop the document themselves, guided by the following legislative acts:

– Letter No. 02/3853-2020-27 of the Federal Service for the Supervision of Consumer Rights Protection and Human Welfare (abbreviated in Russian as “Rospotrebnadzor”) dated  March10, 2020;

– Resolution No. 6 of the Chief Sanitary Inspector of the Russian Federation dated March 13, 2020.

Acsour’s experts recommend including the following sections in the Standard:

1. General provisions.

This section describes the main purpose of the document and contains the main requirements for the sanitary conditions and personal hygiene of employees.

• Sanitary and hygienic requirements and the procedure for allowing employees to work.

In this clause, it is recommended to specify:

– the number of employees who are directly involved in the company’s functioning processes and who can perform their work functions in remote mode;

– the obligation of managers of departments to inform employees about the risks of infection, individual preventive measures and the need to contact medical professionals when symptoms of acute respiratory viral infection (ARVI) appear;

– the organization of a daily visual examination (in the form of temperature measurement) and an inquiry of employees for the purpose of the early detection of ARVI symptoms.

– the obligation of employees to inform the Manager of any adverse changes in their health status. A sick employee is suspended from work. It will be possible to grant permission to resume work only if the affected employee presents a medical document confirming full recovery;

– the obligation to provide employees with individual protective gear (disposable face masks, disinfecting wipes, skin antiseptics). At the same time the re-use of disposable face masks is not allowed;

– personal hygiene rules that employees should observe (frequency of handwashing, hand disinfection in areas specially designed for this purpose, etc.).

• Sanitary treatment of premises.

In this clause, it is possible to specify:

– the procedure for airing and disinfecting office premises. The second action may be carried out by one’s own efforts or by specialized organizations.

– the procedure for cleaning in rooms of the office (the frequency of cleaning, method of surface and air treatment, what chemical agents are used in cleaning, the procedure for the disposal of cleaning products, storage of disinfecting agents).

• The organization of meals.

This section establishes the basic rules for organizing meals for employees. It is recommended to clearly specify:

– the schedule of visits to the premises for taking of food with the possibility of employees being seated at a distance of at least 1.5 meters from each other (if there are such premises);

– the procedure for washing dishes both mechanically and manually;

– the procedure for using disposable tableware.

• The procedure of actions if an employee is suspected of having a coronavirus infection.

This is important in case one of the company’s employees falls sick. In this section, it is recommended to specify:

– the procedure for familiarizing employees with the scheme for routing employees with symptoms of ARVI and community-acquired pneumonia to medical organizations;

– the obligation to make a call to a special mobile team of emergency health services and facilitate the patient’s reaching of a medical organization;

– the need to disinfect the surfaces in the premises and to disinfect the air environment of the premises after a sick employee has been sent to a healthcare institution;

– the obligation to put together information about those employees who were in contact with the sick employee. These employees should be suspended from work for 14 days in order to comply with the self-isolation regime.

• Final provisions. Here it is possible to specify additional working conditions for employees during the coronavirus pandemic (the introduction of a special working hours, the organization of transportation for employees, etc.).

What is necessary to do after the company approves the Standard?

After the organization approves the Standard, it will have to notify the Committee for industrial policy, innovations and trade of St Petersburg (the “Committee”) of the carrying out or resumption of its activities, along with the adopted document. To do this, it is necessary to:

1. Register or log in to the personal account on the official website of the St Petersburg Publicly Funded National Institution “Unified Entrepreneurship Center”.
2. In the section “Sending of information about the carrying out of activities”, select the required sphere of activity and fill in all the necessary information.
3. Confirm the accuracy of the specified information and send a notification.
4. On the basis of the results of entering the information, a QR code will be sent to the company’s email address specified upon registration.
5. The received QR code should be placed in a clear and intelligible form, including on its official website on the Internet.

Please note that it is necessary to draw up a Standard, as well as send a notification to the Committee, before starting the carrying out or resumption of activities in the company.

What does the absence of a Safe Standard entail?

Despite the fact that Resolution No. 121 does not establish a separate punishment for the absence of a Safety Standard in the company, liability is still established for such absence.

Given that the provisions of the Standard secure rules for the implementation of sanitary and hygiene rules during the coronavirus infection pandemic, non-compliance with these rules is subject to administrative liability under article 6.3 of the Administrative Code of the Russian Federation:

• for citizens – a fine of 15,000 – 40,000 rubles;
• for officers – a fine of 50,000 – 150,000 rubles;
• for legal entities – a fine of 200,000 – 500,000 rubles or a suspension of activities for up to 90 days.

If the acts (omissions) that were committed entailed damage to human health or the death of a person, but, at the same time, such actions are not a crime, then the liability will be increased:

• for citizens – a fine of 150,000 – 300,000 rubles;
• for officers – a fine of 300,000 – 500,000 rubles or disqualification for between 1 and 3 years;
• for legal entities – a fine of 500,000 – 1,000,000 rubles or a suspension of activities for up to 90 days.

Criminal liability will be stipulated for a legal entity’s officers under article 236 of the Criminal Code of the Russian Federation if the violation of sanitary and epidemiological provisions and hygiene rules entailed mass disease among people or a threat of such consequences. For more information about the scope of punishment and the amount of fines, see our article on our company’s website.

You can always contact Acsour’s specialists with regard to matters of preparing or updating of your Safe Operation Standard, as well as of notifying the Committee for industrial policy, innovations and trade.