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General Guidelines: New Normal

COVID-19 Client Advisory

AS OF 04 MAY 2020

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COVID-19 Client Advisory Guidelines on “New Normal”

On 30 April 2020, the Department of Trade and Industry (DTI) and the Department of Labor and Employment (DOLE) jointly issued the Interim Guidelines on Workplace Prevention and Control of COVID-19 (DTI-DOLE Interim Guidelines) to outline the safety and health standards that workplaces, employees and workers in the private sector should implement for the duration of the Enhanced Community Quarantine (ECQ) and General Community Quarantine (GCQ). This is in addition to various guidelines issued by the Department of Health (DOH) and previously issued by the DOLE. The President also issued Executive Order No. 112 dated 30 April 2020 (EO 112) identifying the areas to be placed under ECQ and GCQ, and adopting the Omnibus Guidelines to be implemented over these areas. Likewise, pending before the House of Representatives is proposed House Bill No. 6623 or “The New Normal for the Workplace and Public Spaces Act of 2020” (the New Normal Bill), which seeks to establish guidelines, policies and regulations for a new normal way of life and institutes penalties for violation thereof. The Q&As below provide some highlights of the DTI-DOLE Interim Guidelines as well as the New Normal Bill to guide clients in the preparation of their re-entry policies/protocols post-ECQ/GCQ.

Part 1: Executive Issuances 1. What are the duties of the employers under the DTI-DOLE Interim Guidelines?

Under the Guidelines, employers have the following duties:

(a) Provide company policies for the prevention and control of COVID-19; (b) Provide resources and materials needed to keep the workers’ health and the

workplace safe, (e.g. masks, soap, sanitizer, disinfectant, PPEs, including COVID-19 testing kits)

(c) Designate the safety officer to monitor COVID-10 prevention and control measures;

(d) Enhance health insurance provision for workers; (e) Where feasible, provide shuttle services and/or decent accommodation on

near site location to lessen travel and people movement; (f) Enjoin the hiring from the local community; and (g) Put up a COVID-19 Hotline and Call Center for employees to report if

symptomatic.

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2. What other measures are employers required to implement to reduce

transmission of COVID-19 under DTI-DOLE Interim Guidelines?

(a) All work areas and frequently handled objects such as door knobs and handles shall be cleaned and disinfected regularly, at least once every two (2) hours;

(b) All washrooms and toilers shall have sufficient clean water and soap; (c) Sanitizers shall be made available in corridors, conference areas, elevators,

stairways and areas where workers pass; (d) Workers, whether in office workstations or in operations area, should be able

to always practice physical distancing, meaning at the minimum one (1) meter radius space between workers;

(e) Eating in communal areas is discouraged; and (f) Canteens and kitchens should be cleaned and disinfected regularly.

3. Are there any mandatory notification or reporting requirements for employers

when an employee is suspected to be COVID-19-infected? Yes. The Occupational Safety and Health Officer of the company shall report employees who are (a) symptomatic (b) asymptomatic with history of travel to China, and (c) asymptomatic with history of exposure, to the Municipal Health Officer of City Health Officer for verification and initial investigation. (DOH Memorandum 2020-0056 dated 05 February 2020, Item II.C) Employers are also required to provide DOLE through its Regional Office copy furnished DOH, monthly reporting of illness, diseases and injuries utilizing the DOLE Work Accident/Illness Report Form. (DTI-DOLE Interim Guidelines, Item XI)

4. What are the steps to be taken by the employer when an employee is suspected of having COVID-19? In the event that a worker is suspected of having COVID-19, the employer shall:

(a) Provide the worker with a face mask to prevent the risk of spreading the infection;

(b) Immediately isolate the worker in a separate well ventilated room in the workplace, away from the workers;

(c) Refer the worker to the company healthcare provider if there is any or to the nearest hospital for evaluation and proper management if the history, signs and symptoms are consistent with COVID-19.

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(d) Report the employee to the DOH by calling the numbers 8-711-1001 and 8-711-1002;

(e) Ensure the implementation of DOH-recommendations on the management and transport of suspected case of COVID-19;

(f) Observe respiratory precautions when taking care of patients with flu or flu-like illness; and

(g) Decontaminate the work area with appropriate disinfectant (e.g. chlorine bleaching solution and 1:100 phenol based disinfectant). (DOH Memorandum 2020-0056 and DOLE Labor Advisory No 4 series of 2020)

5. Can employers require employees who exhibit COVID-19 to undergo mandatory

quarantine? Yes. Under Labor Advisory 4 series of 2020, employers may serve quarantine orders to employees for reasons related to COVID-19.

6. Are employers required to provide all employees with personal protective equipment? Yes. Employers shall provide the appropriate face masks for workers. Employers and workers shall wear face masks at all times and remove the same only when eating/drinking. Should cloth masks be used, the washable type shall be worn and additional filter material such as tissue papers inside the masks may be added. (DTI-DOLE Interim Guidelines, Item B.1.a.i)

7. Can employers and/or building administrators require the employees to provide health information and history prior to entrance in buildings or workplaces? Yes. All employers and workers are required to accomplish the daily health symptoms questionnaire and submit to the guard or designated officer prior to entry. (DTI-DOLE Interim Guidelines, Item B1.a.ii)

8. Can employers and/or building administrators refuse entry to workers who exhibit COVID-19 symptoms? Yes. Any personnel with temperature >37.5, even after a 5 minute rest, or if their response to the health questionnaire needs further evaluation by the clinic staff, the person shall be isolated in an area identified by the company and not allowed to enter the premises. (DTI-DOLE Interim Guidelines, Item B.1.a.iii)

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9. Are vulnerable employees allowed not to physically report to work?

Yes. Employers must provide alternative work arrangements to the elderly, individuals with underlying conditions and pregnant women for the duration of the COVID-19 health event. (DOH Administrative Order 2020-015 entitled Guidelines on the Risk-Based Public Health Standards for COVID-19 Mitigation)

10. Can an employee refuse to report for work out of fear of being infected? Yes. Under Labor Advisory 1, series of 2020, employees who fail or refuse to work by reason of imminent danger resulting from natural or man-made calamity shall not be exposed to or subject to any administrative sanction. Under Presidential Proclamation No. 922, the Philippines shall remain under a State of Public Health Emergency throughout the Philippines until the proclamation is lifted or withdrawn by the President. We note, however, that under the DTI-DOLE Interim Guidelines Item VII, workplace with imminent danger situations are where workers are evidently at risk of infection as in health-care and other frontline services.

11. Can employers require COVID-19 Testing? Yes. Employers may test workers for COVID-19 using testing kits the employers procured. DOH protocols shall be followed for the testing of workers. However, the employers shall first formulate a COVID-19 testing policy that is agreed to by the employees and in conformity with DOH protocols. (DTI-DOLE Interim Guidelines, Item VIII).

12. What are the minimum objectives and strategies required by the DOH in the development of policies and/or guidelines on mitigation of COVID-19?

(a) Increase physical and mental resilience; (b) Reduce transmission; (c) Reduce contact; and (d) Reduce duration of infection. (DOH Administrative Order 2020-015)

13. What are the minimum public health standards in the workplace required by the

DOH?

Under EO 112, adopting the Omnibus Guidelines on the Implementation of Community Quarantine in the Philippines issued by the Inter-Agency Task Force (IATF), minimum public health standards shall be complied with at all times for the

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duration of the ECQ and GCQ. The minimum public health standards under DOH Administrative Order 2020-015 are the following:

(a) Practice respiratory etiquette at all times. Use tissue or the inner portion of the

elbow to cover the nose and mouth when sneezing/coughing. Practice proper disposal of tissue after use.

(b) Employers must provide mental and psychosocial support such as but not limited to providing mindfulness activities/sessions, in-house counseling sessions, online counseling, and support groups to its employees.

(c) Employers must provide temporary accommodations to employees, if necessary.

(d) Employers must provide alternative arrangements to the elderly, individuals with underlying conditions and pregnant women for the duration of COVID-19 health event.

(e) Provision of temporary accommodations to employees, if necessary. (f) Employers must ensure daily monitoring and availability of hand soaps,

sanitizers and other disinfectants in restrooms and in all entrances and facilities.

(g) Employers must place foot baths in all entrances and ensure routine cleaning of frequently touched surfaces and objects and routine cleaning and replacement of disinfectants solutions in foot baths.

(h) Employers must allocate appropriate PPEs to employees on duty, depending on the nature work and contact with the general public. Health or asymptomatic individuals shall use cloth face masks.

(i) Employers must limit face to face meetings as much as possible and adopt work from home arrangements. Employers should also allow flexible dining policy in the work space/cubicle during lunch break or limit the number of individuals who can eat in the pantry at a given time.

(j) Employers must suspend office meetings, conferences and other large gatherings.

(k) Employers must subject all employees to temperature checks prior to entering the building/office spaces and proper referral to appropriate facility for symptomatic employees. Employers must also monitor all employees daily to ensure proper detection of symptoms.

These standards should also be incorporated in the COVID-19 policies the employers are required to develop under the DOLE-DTI Interim Guidelines.

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14. Which industries are allowed to operate under the GCQ?

A. Category 1 Industries (fully operational):

(a) Agriculture, fishery and forestry industries; (b) Food manufacturing and food supply chain business, including food retail

establishments such as supermarkets, grocery stores, and food preparation establishments insofar as take-out and delivery services;

(c) Food delivery services; (d) Health-related establishments; (e) Logistics sector; (f) Information technology; (g) Telecommunications companies; and (h) Media industry.

B. Category II and III Industries (fifty percent [50%] operational capacity):

(a) Mining and other manufacturing industry; (b) Export-oriented industry; (c) Electronic commerce companies; (d) Delivery, repair and maintenance services; (e) Housing and offices services; (f) Financial services; (g) Business process outsourcing; (h) Legal and accounting, and auditing services; (i) Professional, scientific, technical and other non-leisure services; (j) Barber shops, salons, and other personal care services; and (k) Other non-leisure wholesale and retail establishment.

15. Who are allowed to transit to and from ECQ and GCQ areas?

(a) Health workers; (b) Government officials and government frontline personnel; (c) Those travelling for medical or humanitarian reasons; (d) Persons transiting to the airport for travel abroad; (e) Workers in permitted establishments and persons providing essential goods

and services and public utilities; (f) Essential skeleton workforce; (g) Repatriated overseas Filipino workers and non-OFWs returning to their

residences; and

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(h) Other persons transported through the efforts of the national government upon conduct of the necessary quarantine protocols and in concurrence with the receiving local government units. (Omnibus Guidelines on the Implementation of Community Quarantine in the Philippines, Section 4)

16. What are the other key differences between ECQ and GCQ under EO112?

Enhanced Community Quarantine

General Community Quarantine

Mass gatherings are prohibited. Mass gatherings are prohibited.

Mass public transport is suspended. Mass public transport facilities shall operate at a reduced capacity.

Only construction workers accredited by the DPWH to work on facilities identified for purposes of quarantine and isolation are allowed.

Essential public and private construction projects such as but not limited to sewerage, water services facilities and digital works and health facilities, and priority projects shall be allowed to operate in accordance with DPWH guidelines.

Government agencies and instrumentalities may operate under skeleton workforce unless a different operational capacity is provided.

Government agencies may be fully operational or under alternative work arrangements, including but not limited to work from home, compressed work week, staggered working hours, and creation of skeletal workforces.

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Part 2: New Normal Bill

17. What is the status of the New Normal Bill?

The New Normal Bill was filed on 27 April 2020 and is still pending for deliberation before the House of Representatives. If passed into law, the New Normal Bill will be in effect for a period of three (3) years or for a shorter period, upon official declaration of the President issued upon recommendation of the IATF that that COVID-19 has been contained or eradicated.

18. What are the guidelines that need to be observed under the “New Normal”?

Under the New Normal Bill, the Universal and Mandatory Safety Measures are as follows:

(a) the mandatory wearing of masks in public places and workplaces and the institution of appropriate penalties for violations thereof;

(b) the availability of hand washing/sanitizing stations in places frequented by the public or those in high-touch areas;

(c) mandatory physical and social distancing measured at least one (1) but preferably two (2) meters between individuals in all public spaces;

(d) mandatory temperature checks in all enclosed and semi-enclosed areas and if possible, including open areas in the locality where two or more people shall be gathered;

(e) the procurement of and/or establishment as well as causing the authorization for use of COVID-19 testing (including rapid and antibodies testing) kits, personal protective equipment, or testing laboratories or facilities towards the mass-testing of the population including the establishment of drive-through, phone-in, and other contactless modes of testing individuals for the COVID-19 virus;

(f) contact-tracing systems for individuals who have been confirmed positive for the COVID-19 virus;

(g) the placement of relevant on-site signages and online information materials bearing reminders to practice physical distancing, regular handwashing and sanitizing, medical and health information, updates on local cases and initiatives of the government as well as directions to the appropriate handwashing and sanitizing stations, testing stations or facilities, quarantine facilities, and other such information;

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(h) the implementation, monitoring, and maintenance of a planned schedule for pedestrians traveling to and from their respective workplaces in coordination with private sector entities within the local government’s territorial jurisdiction and if possible or applicable, the chartering of various means of transporting residents and workers to and from their respective destinations;

(i) establishment and proper management of government-operated quarantine facilities in partnership with health authorities for individuals mandated by the IATF and/or the DOH regulations to undergo mandatory quarantine and cannot undergo the same at their respective places of residence;

(j) establishment of various forms of electronic/digital governance (e-governance) mechanisms in coordination with other national government agencies and the private sector;

(k) continuous profiling and monitoring of residents; and (l) continuous implementation of existing measures in dealing with residents or

any other individual in the locality who has been confirmed positive for COVID-19 by authorized testing/medical facilities.

19. Are there specific protocols and/or measures for private sector workplaces under

the New Normal Bill?

Yes, in addition to the Universal and Mandatory Safety Measures and subject to prevailing guidelines of the World Health Organization and of the DOH, all private sector entities (including non-profit organizations, charities, and the like) should implement the following protocols and/or measures:

(a) New Normal Workforce and Workplace Management Plan which must be submitted, published and distributed to employees and to the local government unit which exercises territorial jurisdiction over their workplace prior to resumption of operations; provided that essential business operations which have remained open and operational with a skeletal workforce during the ECQ period shall no longer be required unless they shall increase the number of personnel and workforce in which case the same Plan shall be required of them. The New Normal Workforce and Workplace Management Plan shall detail, among others:

i. the total number of employees in the specific workplace/ office/branch covered by the plan;

ii. the overall strategy for the reporting of the workforce (which may be on rotational, staggered, tele-commuting, remote/work-from-home basis) including the relevant time specifications and periods as well number of workforce ingress and egress (time-in/timeout);

iii. the total number of workers at any given time in the workplace/office on a daily basis;

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iv. if applicable, the number of workers per area of space and the spacing mechanisms to be implemented in compliance with physical distancing protocols;

v. the mechanisms for maintaining personal hygiene and cleanliness among the employees and in workstations/areas including the availability of handwashing or hand sanitizing implements;

vi. the physical changes in space management introduced (or to be introduced) in the workplaces to protect employees and implement physical distancing such as plastic barriers between customers and personnel or between and among customers or other individuals within the workplace;

vii. the signages, reminders, and other information installed or posted in key areas of the workplace to serve as constant reminders for workers to practice the mandatory safety behavior and actions;

viii. the mechanisms for maintaining physical distancing in communally shared areas in the workplace (i.e. cafeterias, restrooms, conference rooms, etc.) including safeguards (which may mean, the prohibition) of sharing of tools, implements, utensils, equipment, and supplies;

ix. the physical and personal protective equipment provided or to be provided by the private entity to their respective employees in order to inclusively implement the Universal Safety Measures;

x. the mechanisms for managing employees exhibiting symptoms and/or confirmed to have tested positive for COVID-19 including the company/business unit’s system for contact tracing from within and among other employees; and

xi. other relevant information that may be determined and included in the Implementing Rules and Regulations of the New Normal Bill;

(b) For private entities resuming their operations and requiring the physical

presence of their employees subject to their workforce and workplace management plan, to provide shuttle or transportation services under the conditions applicable to public transportation service providers (see Question No. 22 below), if possible;

(c) In Food Service Workplaces (restaurants, cafes, fastfoods, etc.):

i. Resume operations with take-out/delivery service only and gradually re-introduce dine-ins;

ii. Cut back on food items and temporarily discontinue buffets and salad bar service;

iii. Create more spaces in the dining area and maintain two-meter distances between tables when dine-in service resumes;

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iv. Provide disposable (non-shared) menu booklets; v. Provide alcohol-based wipes for patrons and/or touchless soap

dispensers in wash areas; vi. Promote contactless service for dine-in patrons; vii. Provide disposable cutlery and wash non-disposable cutlery with

effective soap solutions on warm water; viii. Mark spacing distances in food centers with queue lines; and

ix. Frequently disinfect common spaces.

(d) In Commercial Stores and Centers (Banks, Boutiques, Groceries, Supermarkets, Shopping Malls, etc.):

i. Establish a maximum number of people inside the store/shop/center/ mall at any given time and limit entry/ingress points;

ii. Promote online transactions and shopping services; iii. Implement cashless and/or contact-less sales and customer

service; and iv. Frequently sanitize/disinfect items for sale and other high-touch

objects in the store/shop;

(e) In Offices in Buildings (Call Centers, Standard Offices): i. Limit the number of people who use elevators; ii. Put markers on carpets and other flooring materials to create visual

boundaries around desks, plexiglass shields between desks that face each other and signs that direct walking traffic in a single direction;

iii. Tape off areas to promote physical and social distancing – especially in elevators;

iv. Put more vending machines instead of opening cafeterias; v. Discourage physical meetings and implement online/livestream

methods of communication; and vi. As much as possible, all employees entering a building or an area

to report for work shall be subjected to a thermal/temperature scan prior to being allowed entry whereas employees whose recorded body temperature render them suspect for symptoms of COVID-19 shall be asked to undergo the necessary quarantine or subjected to the appropriate healthcare in coordination with authorized medical facilities and/or advise;

(f) In Salons, Parlors, and Spas, upon the resumption of operation, where person-

to-person contract is unavoidable: i. Frequent handwashing and sanitizing of salon tools used;

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ii. Mandatory use of face mask and gloves; iii. Apply best cleaning and disinfection practices in the facility

repeatedly; and iv. Implement protocols and policies on sick employees and clients

with flu-like symptoms and have fungal infections;

(g) In Construction Sites, Factories, and Related Industrial Workplaces Workstations:

i. Adjust on-site and production schedules; ii. Conduct consultative dialogues between owners, managers,

supervisors, and construction workers and agree on collaboratively determined work and/or production schedules;

iii. Provide mechanisms for work-site mobility and transportation; iv. Limit the use of co-workers’ tools and equipment; and v. Monitor and implement individualized shifts for the use of

equipment, vehicles, tools, and other construction materials;

(h) In Schools, Colleges, Universities, and Other Learning/Training Institutions:* i. Integrate online classes in the curriculum and promote creative

ways of student learning and engagement without physical contact and/or reporting to the classroom;

ii. Provide staggered school days and smaller class sizes if and when on-site classes resume;

iii. Implement changes to assemblies, physical education, and recess if and when on-site classes resume;

iv. Establish floor plans conducive to physical distancing; and v. Provide daily temperature checks for students and staff, as well as

weekly health check-ups.

*Note: Subject to consultation with the Department of Education (DepEd) and the Commission on Higher Education (CHED), all classes and school activities, including sports, athletics, cultural, and academic meets, exhibitions, and/or competitions as well as extra-curricular field/exposure trips and exchanges shall remain suspended until further notice without prejudice to the academic freedom and levels of autonomy enjoyed by institutions of higher learning in the governance of their own academic affairs (i.e. grading status, promotion and retention mechanisms, etc.); provided that no student shall be unreasonably penalized for their inability to participate in online means of learning due to issues in connectivity or availability of gadgets or equipment. Public and private education institutions including private and public colleges and universities shall prioritize the establishment of online platforms of learning, instruction, and evaluation.

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20. What guidelines are provided in the pending bill on the handling of sick

employees? The New Normal Bill provides for the adoption of Employee Case Management Protocol prescribing that: (a) All employees who report any form of sickness, symptomatic of COVID-19 or not,

shall not be allowed nor required to report for work; (b) All employees under monitoring and under investigation for exhibiting symptoms

of COVID-19 shall be absolutely prohibited from reporting to work until they can provide a clearance from an authorized medical or health facility; and

(c) The employer or supervisor/manager of the employee who has tested positive for COVID-19 shall be primarily responsible for instituting vigorous contact tracing of the other employees who have come into contact with the employee who tested positive and shall be made to report the same to the relevant government authorities.

21. Will gatherings be allowed under New Normal Bill?

Gatherings will be allowed but shall be highly regulated. Privately-organized gatherings in privately-managed spaces shall be highly regulated and shall be dispersed by the local government unit after determination that the Universal and Mandatory Safety Measures are not observed. Penalties and/or fines shall be imposed on violators according to ordinances enacted by the local government unit. In government-managed public spaces (such as public markets, parks, plazas, covered courts, promenades, gymnasiums, arenas, cockpits, amusement and recreation centers), gatherings as well as the flow of people shall be highly regulated and subject to the guidelines onset and upon issuance of the new normal permit by the local government unit, if necessary; provided that activities of agencies of the national government and/or their provincial or regional divisions for the distribution of all forms of public assistance or the facilitation thereof shall in no way be impeded nor be required a permit; provided further, that gatherings under this category shall observe the Universal and Mandatory Safety Measures; and provided finally, that local government units shall provide national, regional, and provincial agencies and/or their attached offices assistance to carry out their activities requiring the presence or participation of a significant number of the population.

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22. Will public transportation be available post-ECQ?

Under the New Normal Bill, some public transportation will be available. The operation of motorcycle taxis, however, shall remain suspended. For operational public transportation, the government shall monitor the implementation of the Universal and Mandatory Safety Measures in queuing/ticketing lines, queuing/ticketing areas/offices, as well as the interiors of the vehicles and their respective passengers/drivers/conductors. Contact-less payment mechanisms and other such practices that will minimize the risk of transmission shall be implemented. Passengers shall be required to wash their hands or sanitize prior to boarding the vehicle and be seated a seat apart and be at all times in face masks. In transportation hubs, the responsible agencies and/or authorities shall consider special measures such as: (i) the establishment of public health corridors in airports and ports; (ii) the mandatory taking of body temperatures for all arriving and departing passengers; (iii) the mandatory quarantine (home or in an authorized government facility) of all arriving passengers and the maintenance of a database of information for contact tracing; (iv) the thorough sanitizing and disinfection of all arriving and departing vessels; (v) if possible, the mandatory regular testing of all employees, personnel, staff, and crew attached to vessels and or have assisted passengers; and (vi) if possible and available, the rapid testing of arriving and departing passengers.

23. What acts or omissions are punishable under the New Normal Bill?

The New Normal Bill penalizes the following acts or omissions of private individuals: (a) Failure to wear mask while in pubic place shall be issued citation tickets with

corresponding One Thousand Pesos (PhP1,000.00) fine or render 1-day mandatory community service;

(b) Failure of any owner and possessor of privately-owned public places and establishments, and any event organizer of any social gathering to comply with the provisions on the management of spaces;

(c) Failure of any private corporation to implement and monitor the proper implementation of management of public transport;

(d) Failure of the Administrators, Directors, Principals and Head of Local Schools and other Learning Institutions to comply with the Monitoring of Schools and Learning Institutions and other issuances, circulars, memorandum and directives of Department of Education and Commission on Higher Education in relation to the holding of classes during COVID-19 pandemic situation;

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(e) Failure of the business owner, employer, supervisor/manager or any person in charge to implement and monitor the proper implementation of Workplace-Specific Protocols and Measures;

(f) Failure of any owner, general manager, supervising officer or any officer in charge of the submission of “The New Normal Workforce and Workplace Management Plan” of all private commercial, industrial entities to submit the management plan within the period required; and

(g) Failure of the employer, supervisor/manager or any person in charge to abide by the Employee Case Management Protocols.

The penalty for the above offenses is imprisonment of two (2) months or a fine of not less than One Thousand Pesos (PhP1,000.00) but not more than Fifty Thousand Pesos (PhP50,000.00), or both.

Disclaimer and Limitations — This advisory is intended to provide general guidance to clients of PJS Law only, based on laws and issuances as of the date stated above. Please confirm with our lawyers for possible updates or contact pjs@pjslaw.com if you have clarifications or other concerns.