As "stay-at-home" orders approach expiration or are
lifted, it appears that a return to the workplace through
"phasing-in" is rapidly approaching. Employers must now
anticipate how to prevent the introduction and spread of COVID-19
upon the resumption of operations. There is no one-size-fits-all
approach, and an Equal Employment Opportunity Commission
(EEOC)-recommended workplace hazard assessment will be key in
determining the best way to allow employees to return to work as
safely as possible.1 Approaches to ensuring compliance
with the Occupational Safety and Health Administration (OSHA)
general duty clause (which mandates that employers provide a safe
working environment)2 will universally include increased
sanitation practices, strict policies and procedures around the
reporting of illness and exclusion of sick employees from the
workplace, and social distancing requirements, as well as, in many
instances, the provision and required use of personal
