Health, Safety, & Security Questions of the Week

How To Determine If A Home Office Injury Is Covered By Workers’ Compensation

Image of a man with a broken leg working from a home office

HR Question:

Our company has agreed to allow employees to work a hybrid schedule, allowing them to work from home on multiple days during the week. Although this has been very well received by employees, we have seen an increase in the number of injuries from employees working from home. How do I know if a home office injury is covered by workers’ compensation, and how do I handle these claims?

HR Answer:

The Bureau of Labor Statistics announced that in 2020, private industry employers reported 2.7 million nonfatal workplace injuries and illnesses. Although down from 2.8 million in 2019, workplace injuries are still an expensive and difficult issue for employers, and with the increase in the number of employees telecommuting and working from home or alternate locations, this task has some additional unique challenges.

What is a compensable injury under workers’ compensation?

In many instances, it is easy to determine if an injury is covered by workers’ compensation. The key words in determining coverage under workers’ compensation are: “arising out of (what they were doing) and in the course of (where were they – time, place, etc.) employment.” Cutting your finger opening a box at work is an easy example of a covered injury. Injuries from a home office are not always as easy to determine coverage. Overall, injuries and illnesses that occur while an employee is working at home are considered work-related (and thus compensable) if the illness or injury occurs while the employee is performing work for pay in the home or alternate workspace and the injury or illness is directly related to the performance of work. If the employee is completing a work task and they can prove they were working in the interest of their employer when they got hurt or injured, it is typically a covered event.

One important note is that employers must also consider the “personal comfort doctrine.” This legal term states that certain personal activities for the employee’s comfort (bathroom breaks, eating/drinking) are deemed necessary and are considered part of an employee’s work activity. According to the personal comfort doctrine, tripping over the dog and breaking your leg while walking to the bathroom at home during work hours could be covered under workers’ compensation. This doctrine, along with the overall lack of witnesses and the inability to control the work environment, can lead to frustration regarding workers’ compensation claims outside of the traditional workplace.

For additional support, OSHA provides instruction on compliance and guidance on interpreting the work-relatedness of injuries resulting from telecommuting.

What can employers do to protect your organization and your employees?

We recommend taking the following steps to establish expectations for safe remote work environments, as well as what to do if you receive an injury claim from a remote worker:

  1. Create a work-from-home policy that includes the requirement to maintain a professional, well-kept, and safe work environment. Include home safety audits.
  2. Require employees to report any work-related injuries or illness immediately to their manager or safety official.
  3. If an injury occurs, obtain a report of the accident and be sure to include a written statement from the employee. The report should include exactly what the person was doing at the time of the injury. How, when, and where the injury occurred should be detailed in the report. Cumulative injuries and slips, trips, and falls are the most commonly reported home injuries, therefore, getting these details is important.
  4. Ask the employee to take pictures of the work area where the injury occurred as well as of their injury, if possible.
  5. Provide all of the pertinent information to your workers’ compensation carrier or administrator, and let them make the assessment as to work-relatedness. Include legal counsel if necessary.

Overall, treat all workplace injuries the same, regardless of where they occurred. Claims must be actively managed from the time they are reported. Employee safety and health should be a priority for all employers, regardless of an employee’s work location. Actively managing these claims is one step in assuring their well-being and the well-being of the company.

Thank you to Patti Dunham, MBA, MA, SPHR, SHRM-SCP, Director of HR Solutions for contributing to this HR Question of the Week.

Strategic HR understands your concerns with the well-being of your employees as well as your organization. We offer expertise in health, safety, and security to cover any need you may have ranging from creating workplace safety policies to developing a business resumption plan for handling unexpected emergencies. Please visit our Health, Safety & Security page for more information.

Three Ways HR Can Serve as Cybersecurity Defenders

Image of computer circuit boards symbolizing cybersecurity

HR Question:

Why should cybersecurity be a priority for HR professionals? Isn’t that IT’s job?

HR Answer:

Hackers look for more than just passwords and bank information. They can hold personal information hostage like social security numbers, share private health information, or share the results of someone’s less-than-satisfactory performance review with the public.

Human error is often one of the key weaknesses that hackers and cybersecurity criminals will try to exploit in their assaults. As HR professionals and business leaders, it’s up to you to build in defenses amongst your team members to protect the business and the sensitive information it has on your employees.

Implement a Clear Cybersecurity Policy

One of the first lines of defense that HR professionals can put in place is a strong cybersecurity policy. Policies that cover topics such as information sharing and the appropriate use of social media, remote devices, wi-fi, and VPNs can help educate your team members on safe technology practices and put definable consequences (beyond the potential danger of information exposure and distribution) around the misuse of company technology and information.

By partnering with your organization’s IT department, HR can include policies that support employee privacy and the company’s security, such as regularly updating passwords, guidelines to follow in the case of suspected security breaches, reporting procedures, and more.

Foster a Cybersecurity Savvy Culture

You know the phrase, “you have to walk the walk to talk the talk”? Or better yet – “leading by example.” The same concepts apply to how your HR department approaches cybersecurity when fostering your company culture. Without HR putting the same emphasis and care behind IT policies and priorities, these goals may fall flat before reaching the finish line.

As such, there are four ways to help encourage your employees to be aware of potential security risks:

  • Check phishing reports quarterly to see what’s trending and what’s changing with how the common scams operate.
  • Always be sure to double- and triple-check who’s asking you for information. Attackers are becoming more and more intuitive in how they reach out to you. It doesn’t matter whether it’s your mother, your boss, or your best friend who emailed you, check where the email came from and be certain before you respond.
  • Ensure that common behaviors, such as reusing passwords or using unprotected wi-fi networks, aren’t encouraged, practiced, or overlooked.
  • Never let your guard down. This is probably one of the most important things to remember. It’s not easy to do, but phishing is only a problem if it succeeds. And phishing will succeed. We’re all human and we will make mistakes. It’s these mistakes that attackers capitalize on.

Remember these four rules, and you’ll be much safer and prepared to deal with any phishing scams that come your way.

Include Cybersecurity in Regular HR Audits

As a part of your HR audits, which should be conducted on a regular basis, it’s important to include cybersecurity features in your regular process. Double-checking things such as password security, ensuring all software is updated, and making sure that policies are up-to-date based on popular apps and technology trends can help to keep your company’s and your employees’ information safe and secure.

Special thanks to Samantha Kelly for contributing to this edition of our HR Question of the Week. 

Visit our colleagues at Clark Schaefer Hackett to learn how they can support your cybersecurity needs, or check out our Health, Safety, and Security page to see how we can help develop processes, procedures, and programs to protect your team. 

How Do We Create An Emergency Preparedness Plan?

HR Question:

We don’t have a formalized emergency preparedness plan, and I think we should probably have one, right? What should we include?

HR Answer:

You’re right. Every employer needs an emergency action plan for many reasons, including to be compliant with the Occupational Safety & Health Administration (OSHA) 29 CFR 1020.38(a) requirement. Beyond the mandate, every employer should want to protect their employees from harm to the best of their ability, as emergencies can be unpredictable, scary, and have impacts beyond your business to the community around you – such as the recent explosion at a Northern Kentucky chemical plant. And finally, if you do not protect employees and they are harmed, they may come back with a lawsuit, as was the case after the recent tornados destroyed a local factory in Mayfield, Kentucky.

Emergency action planning doesn’t have to be hard. You should have a written policy to address a variety of potential emergency situations such as a fire, tornado, hurricane, chemical spill or explosion, active shooter, and major illness or pandemic. When prepping Emergency Response Plans, it’s important that you anticipate the variety of emergencies you might face. Consider the risks that your organization may be exposed to, even if they’ve never happened before, and make a list. Create a separate plan for each separate emergency. After all, how you respond to a flood may be very different than how you would respond to a tornado.

From there, it’s important that you prepare your teams. Clearly communicate these plans to all employees at all locations annually and be sure to practice them on a regular basis. At a minimum, the strongest emergency response plans should include:

  • A way of making an immediate announcement of an emergency to employees (e.g., PA system, phones, text, etc.)
  • Response procedures including emergency escape routes and safe shelter-in-place designated areas (post these routes/locations at common points in the building)
  • Identification of a safety officer and/or employees who may remain to perform critical operations before they evacuate/shelter-in-place (depending on the severity of the emergency) and what those operations are
  • Accounting for all employees after evacuating or emergency has concluded
  • Rescue and medical duties for employees
  • Names or job titles of persons who should be notified of the situation

The beginning of a new year is a great time to remind your employees of your emergency action plans and practice them for a variety of situations. Some resources available to assist in developing plans include:

Special thanks to Lorrie Diaz, MS, for contributing to this HR Question of the Week! 

It’s not negative thinking to plan for a devastating event that could harm employees or impact your company’s ability to function – in fact, it’s a good business practice. Bad things happen, but it’s how we prepare for and recover from a disastrous event that often leads to success or failure. Visit our Health, Safety & Security page to learn more about how we can help you with your emergency preparedness needs.

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Can I Ask if My Employees Are Vaccinated?

Can we ask if our employees are vaccinated? Isn’t this a HIPAA violation or an illegal inquiry under the ADA or somehow confidential information?

Employers can ask for proof of vaccination unless there is a state or local law or order to the contrary.*

When an employer is requesting or reviewing medical information in its capacity as an employer, as it would be when asking about an employee’s vaccination status, it is considered to be an employment record. In such cases, HIPAA would not apply to the employer. The Americans with Disabilities Act (ADA) will govern the collection and storage of this information.

The Equal Employment Opportunity Commission (EEOC), which enforces the ADA, has stated that asking about vaccination is not a disability-related inquiry, though it could turn into one if you ask follow-up questions about why the employee is not vaccinated. Asking a yes or no question, or requesting to see the employee’s vaccination card, does not violate any federal laws or require proof that the inquiry is job-related.

Finally, just because employees think that something is or should be private or confidential doesn’t mean they can’t be required to share it with their employer. Social Security numbers, birth dates, and home addresses are all pieces of information an employee may not want to advertise, but sharing is necessary and required for work. Vaccination status is similar. However, all of this information, once gathered, should not be shared by the employer with third parties, except on a need-to-know basis.

*It appears that some governors may attempt to prevent certain entities from requiring “immunity passports” (e.g., proof of vaccination) through an executive order (EO), though as of July 31, none of the EOs already issued appear to apply to private businesses and their employees. Also note that if there is a law in place that prevents treating vaccinated and unvaccinated employees differently (like in Montana), you may be able to ask, but not take any action based on the response.

Should we keep a record of who is vaccinated or make copies of vaccination cards? If we do, how long should we keep that information?

If you’re asking about vaccination status, you’ll want to keep some kind of record (so you don’t have to ask multiple times), but how you do this is up to you, unless state or local law has imposed specific recordkeeping requirements. You may want to keep something simple like a spreadsheet with the employee’s name and a simple “yes” or “no” in the vaccination column. If you’d prefer to make a copy of their vaccination card, that should be kept with other employee medical information, separate from their personnel file. Per OSHA, these records should be kept for 30 years.

If we keep a record of who is vaccinated, can we share it with managers who will be required to enforce policies based on that information, such as masking and social distancing?

Yes. We recommend not sharing this information any more widely than necessary. While anonymized information is okay to share (e.g., “80% of our employees are vaccinated”), each employee’s vaccination status should be treated as confidential, even if the fact that they are wearing a mask to work seems to reveal their status publicly. Obviously, managers will need this information if they are expected to enforce vaccination-dependent policies, and employers should train them on how they should be enforcing the policies and how and when to escalate issues to HR or a higher level of management.

Special thanks to the HR Support Center for providing this edition of our HR Question of the Week. 

For further COVID-19-related resources, check out our COVID-19 Employer Resources page or contact us for direct assistance. 

This article does not, and is not intended to, constitute legal advice.  Information and content presented herein is for general informational purposes only and readers are strongly encouraged to contact their attorney to obtain advice with respect to any legal matter.  Only your individual attorney can provide assurances that the information contained herein is applicable or appropriate to your particular situation or legal jurisdiction.

How Can HR Professionals Reduce Workplace Violence?

HR Question:

How can we reduce workplace violence?

HR Answer:

The numbers are staggering and undeniable. According to SHRM’s 2019 study, 48% of HR professionals reported some type of workplace violence incident in their organization. The U.S. Bureau of Labor Statistics also reported in the same year there were 888,220 events or exposures involving injury or illness.  Of those, 20,870 were assaults in the workplace.  Even worse, 454 of those assaults were fatalities.

Workplace violence has always been on the radar for HR professionals at some level. They are the first to encourage the involvement of an Employee Assistance Program (EAP); they regularly coach supervisors on having difficult conversations with employees; and often, they serve as sounding boards for employees when they are distraught or concerned.  Through actions and behaviors, they work to create cultures of engagement, awareness, and even compassion and grace when faced with difficult employee relations issues regularly. Despite all of these efforts, it is sometimes not enough.

What else can be done beyond the EAP to help reduce and prevent workplace violence incidents?

Proper planning and assessment can help to identify risks.

With proper planning and worksite assessment, employers can identify ways to limit potential exposure, reducing the likelihood of incidents occurring. The Occupational Safety and Health Administration promotes a well-written and practiced workplace violence prevention program. But to truly be effective, programs like this need to contain engineering controls and administrative controls in addition to training.

The National Institute for Occupational Safety and Health (NIOSH) has developed specific guidelines to assist with violence prevention in a variety of work environments.  Some helpful engineering controls include bright lighting, silent alarms for front desk/access points, video surveillance, access control, and door locks/badge systems throughout the building to limit the access points.

When creating your plan, remember to work with your local firefighters and/or police to get specific direction or even a complete evaluation of your worksite preparedness plan.  There are also many paid professionals and consultants that will help write and/or review your plan specifically for your organization. In this situation, one size does not fit all, so be sure to get some expert advice in creating and training on a proper plan.

Encourage open communication – If you see something, say something.

Encourage open communication with employees, as raising and addressing concerns today can protect someone tomorrow. Create a culture where employees are free to voice their issues in a healthy manner and foster respect within the workplace.  Remember to take all staff communications seriously.  Even the smallest event can trigger individuals, so properly plan all messages and their delivery, especially if you are implementing any type of change.

Ask employees about safety concerns.

Be involved.  Ask questions.  Ask employees if they feel safe and what could be done to create a safer environment.  Ask them how they are doing.  Ask them what concerns or issues they have (and follow up).  Focus on early detection of potential issues. HR professionals can play an important role by asking questions and being involved with the goal of early intervention and prevention of workplace incidents.

Leverage technology to identify and address incidents quickly.

New technology is quickly becoming helpful in ways we could have never imagined.  A few examples include the following tools out in the market today.

Response technologies can be used to quickly activate the need for first responders.  There are tools with location and geofencing that allow responders to pinpoint the actual spot where an event is reported.  Active shooter research tells us that in many cases there is a very short window to intervene. Having location accuracy helps improve the chances of an effective and timely response.

Digital technology tools continue to evolve in this space. There are apps, for example, that organizations can provide to employees that allow for confidential reporting of workplace concerns.  Think “Ethics Line” gone mobile.  These tools allow employees to report concerns – confidentially – and in real-time. The employee report can even include uploaded photos, video, or audio of the behaviors or events they are concerned about or have witnessed, assisting with a future investigation if necessary.

Acoustic gunshot detection is another type of technology that has been implemented in some worksites. These types of systems automatically detect the sound and then tie it to the company’s security systems. It can then sound an alarm, notify the security team, and even dispatch help… long before someone onsite can even discern if the noise was a gunshot or make a call for help.

More sophisticated security programs and camera systems can also assist with potentially violent situations.  Old camera systems are reactive, sometimes only activating when a commotion activates the camera.  New systems today are proactive, using facial recognition.  The systems can send signals if an unauthorized person enters a building or even if someone is carrying a weapon onto the worksite.

As the number of incidents continues to grow, HR professionals and business leaders need to prepare their worksites in ways they have never done before.  It is important to remember that the culture we create, the programs we provide, and the tools and technology we implement can help to calm a potentially violent situation you did not expect.  Human Resources can take an active role “beyond an EAP referral” to prepare the workplace, staff, and employees to handle these unpredictable situations and even potentially save lives.

Special thanks to Patti Dunham, MBA, MA, SPHR, SHRM-SCP for contributing to this edition of our HR Question of the Week!

In 2019, Strategic HR and MYCA Learning partnered together to support organizations in their search for essential training in accessible ways, resulting in the creation of our Active Shooter Preparation e-Learning Course. Geared toward preparing and protecting our communities should they face the unthinkable, this fifteen-minute course seeks to educate participants on how to be aware, how to assess their surroundings, and how to make a plan. 

What Should Ohio Employers Know About Marijuana in the Workplace?

As an Ohio employer, can you help me understand how marijuana legalization fits into our employment policies?

You are not alone in trying to navigate the everchanging state of marijuana legalization. A growing number of states have either passed laws, or are considering legislation, to ease restrictions on employees’ use of marijuana for medicinal or recreational reasons. So, employers that need or want to continue testing or disciplining for marijuana use must know the applicable state and federal laws, including the court decisions that interpret those rules.

Medical marijuana was legalized in Ohio in September 2016, and retail sales began on January 16, 2019, when the first four licensed dispensaries opened for business.  As of February 1, 2020, reports 48 of the 57 licensed dispensaries are operating. So, it is important that you know your rights as an Ohio employer regarding medical marijuana.

Below, we will walk you through some commonly held perceptions and workplace scenarios to help your Ohio-based company evaluate how marijuana legalization impacts your employment policies.

True or False: Medical marijuana users have job protections in Ohio due to state disability discrimination laws.

Answer: False. Presently, there is nothing in Ohio’s medical marijuana law that prohibits or limits an employer’s right to drug test employees for marijuana, require a drug free workplace, or impose discipline or discharge an employee violating an employer’s policies The law protects the employer’s right to fire or discipline any employee found to be using medical marijuana. The statute also states that it will not interfere “with any federal restrictions on employment” related to the use of medical marijuana in the workplace. All marijuana use, whether for medical or recreational use, is still illegal under federal law. It is listed as a Schedule I drug under the Controlled Substances Act, which means that it is deemed to have no medical value and a high potential for abuse.

True or False: If an employee has a medical condition that requires the use of medical marijuana, I must accommodate the employee.

Answer: False. In outlining employers’ rights, Ohio’s Revised Code 3796.28 states that an employee has no specific protections. Under the law, you do not have to accommodate an employee’s need to use the substance. An employer has the right to not hire an employee based on medical marijuana use, possession, or distribution. The law does not allow a cause of action against an employer if an employee believes he or she was discriminated against due to medical marijuana use. An employer is allowed to have a zero-tolerance drug free policy in place, with or without special accommodations for those who use medical marijuana.

True or False: My company has its headquarters in Ohio but has locations in other states. Even if the laws in those states provide workplace protections for medical marijuana users, our employees in those states who use medical marijuana may be disciplined, fired, or not hired.

Answer: False. Thirty-three states and Washington, D.C., have legalized medical marijuana use, and 10 states have approved both medical and recreational use. Registered medicinal users—or “cardholders”—in some states other than Ohio may have job protections. For example, beginning in 2020, employers in Nevada and New York City cannot consider positive pre-employment marijuana screens. However, some exceptions apply, particularly for safety-sensitive positions. Consider research published last year by the National Institute on Drug Abuse where they found that employees who tested positive for cannabis had: 55 percent more industrial incidents, 85 percent more injuries and 75 percent greater absenteeism compared to those who tested negative.

State statutes with nondiscrimination provisions for medicinal use typically exclude jobs that require drug testing under federal law. For example, certain commercial motor vehicle operators would be excluded from job protections because the Department of Transportation requires them to pass drug and alcohol screens.

While Ohio law provides employers with employment rights on the topic of medical marijuana use, HR professionals must remain vigilant to ensure that your company does not act irresponsibly or apply policies in a discriminatory manner. Make sure that your drug-testing practices and drug-free workplace policy fall within the parameters of the laws in the states in which your company operates. You may find it helpful to consult your legal counsel to ensure that you understand and comply with the federal, state and local laws that may apply to your organization.

Strategic HR knows that keeping abreast of workplace compliance issues and deadlines can be daunting, especially when the laws keep changing. We can help you by offering resources to help you identify and mitigate compliance issues and by making sure you are informed of changes and reacting in a timely manner. Our HR Audit will help your organization identify trouble spots in your HR function. Visit our HR Audit page to learn more about this helpful service.

Does My Company Need an AED?

AED’s have been mentioned in safety demos and tutorials that I have attended. Does my company need one of these devices? If so, what type of training is needed in order to use it?


The safety and well-being of your employees and anyone who visits your place of employment should be top of mind for all organizations. There are many tools and resources that can help with your organization’s first-aid and emergency preparedness, including an AED.

What is an AED?

An AED is an Automated External Defibrillator, which is a portable device that measures the heart’s activity and can deliver an electric shock in order to correct the rhythm of the heart. It can also restore a heartbeat if the heart suddenly stops.  An AED is meant to be placed in high traffic locations, and it is designed to be extremely simple for users to operate in times of an emergency.

According to the American Heart Association, there are roughly 350,000 cardiac arrests outside of a hospital setting each year. Cardiac arrest is when a person’s heart stops beating, and blood will stop flowing to the brain, lungs, and other important parts of the body. The person will typically lose consciousness very quickly, and they will die if normal heart function is not restored. Time is crucial in these instances since permanent tissue damage can occur within three to five minutes of loss of blood flow.  For every minute the body goes without oxygen, the chances of death increase by 10%. Over 90% of patients that receive a shock from an AED within the first minute of arrest survive.

A study recently published by JAMA Surgery showed that the average response time for emergency medical personnel was roughly seven minutes. This time could increase up to 14 minutes for rural areas. This study drives home the fact that the general public can play a critical role in saving lives if they are trained on the basic skills and tools to help those in their community until medical professionals can arrive. Having an AED in your workplace can play an important role in your company’s emergency preparedness and saving lives.

Where can I find an AED?

There are multiple resources that can help a company pick out the best plan for their AED purchase, placement, maintenance, and training. Make sure to ask the manufacturer or seller about the intended use, storage options, maintenance and training requirements for any AED being considered for purchase. Contact multiple reputable vendors to find the best option for your company.

What type of training does my team need for an AED?

AEDs are designed to be as simple and user-friendly as possible. They often have voice and visual aides to help in their function. Although emergency training is not required in many states, it is encouraged. AED storage and display is also an important factor to consider. According to the American Heart Association, over half of employees do not know where they can find an AED in their workplace. Create an awareness plan to ensure employees know where to find the AED in the case of an emergency. It is commonly recommended to place the AED near the entrance of your building so employees, as well as non-employees, see the device when they enter the building. It is a best practice to have the device marked with a brightly colored “AED” sign.

There are multiple national nonprofit organizations, including the Red Cross and the American Heart Association, that provide online and onsite training to prepare your employees for how to use AED devices. Many local first responder organizations, like fire departments and police departments, can help provide training as well. Be sure to reach out and find the best fit for your organization. Also consider factors such as the size of the company, the costs of the training, the timing of training, and how to create an ongoing training program to keep people up to date in the future.


Strategic HR understands your concerns with the well-being of your employees. We offer expertise in health, safety and security to cover any need you may have from analyzing your safety programs to making sure you are OSHA compliant to proactively ensuring employee wellness. Please visit our Health, Safety & Security page for more information on any of these services.



Workplace Wearable Technology Safety


Should your workplace use wearable technology to enhance employee safety and health?


Before determining the usefulness of wearable technology in the workplace, it is important to first identify it.  So, what is wearable technology?  Wearables can include any type of “smart” personal device.  In our everyday lives, we think fitness trackers and smart watches.  In the workplace, that definition expands to include all types of “James Bond-esque” type equipment.  EHS wearable tech could include such things as:

  • Devices with radio-frequency identification (RFID) used to determine someone’s location;
  • Devices that conduct any type of measurement gathering – air quality for example;
  • Hard hats with sensors;
  • Glasses with displays;
  • And really any other device that provide information to assist in the safety, health, and well being of employees in the workplace.

Health and Safety professionals continue to expand their use of these items and are intrigued at the potential of these items to reduce workplace accidents and injuries and promote safety.  While using such equipment, employees could be alerted to potentially hazardous conditions.  For example, employees could be alerted if they are lifting an item that is too heavy or they are using unsafe movements.  In the event of catastrophic events such as fires or explosions, RFID equipment could allow employers to locate staff who may be trapped.  The devices could also prevent injuries by providing job activity simulation for difficult tasks, allowing time to practice and avoid potentially harmful mistakes.  Using wearable technology, employers may be able to predict hazardous situations and enhance accident prevention measures.

With all of this great opportunity, why not move forward with these initiatives?  There are a few things to consider.  The first being cost.  Wearable technology varies in price from a simple $40 fitness tracker to $5,000 smartglasses and beyond.  An ROI must be considered when investing in this type of equipment, keeping in mind the value of worker safety.  The second consideration is worker privacy.  In 2017, National Institute of Safety and Health published a white paper regarding the ethics of the use of wearable sensors.  The study reviewed the delicate balance between safety and the obvious concern, worker privacy.  NIOSH suggests that employers be transparent on what data is being collected / observed, how the data is being used, and allow for employees to opt out of a program.

Technology is great!  Consider cost, use, and benefit before implementation and be sure and clearly communicate with staff if you decide to take the dive into the world of wearable tech in the workplace.


Strategic HR understands your concerns with the safety and well-being of your employees. We offer expertise in health, safety and security to cover any need you may have from analyzing your safety programs to making sure your policies and procedures are compliant and protect your staff. Please visit our Health, Safety & Security page for more information on any of these services.

What to Do About Workplace Bullying (And How to Prevent It)


Do you know the signs of workplace bullying?


Can you believe that approximately 2 out of every 5 people have been bullied at work? (1)

About 50 percent of those bullied have had stress-related, health problems as a result.

Workplace bullying—whether verbal, psychological, physical, or online—can be very destructive for any culture. It’s extremely damaging to morale, productivity, safety, and the health and well-being of all your workers…not just the ones involved with the bullying! (1)

One thing is for sure: this kind of treatment is not acceptable, not deserved, and any kind of behavior that resembles bullying shouldn’t be happening in any work environment.

Let’s take a closer look at some of the signs of workplace bullying, and what you can do to work against it becoming an issue in your company.

Do You Know the Signs of Workplace Bullying?

What is workplace bullying? It can take many forms, but according to the Workplace Bullying Institute, workplace bullying is any kind of treatment that is repetitive and abusive in nature. That can be threatening, humiliating, intimidating, or any combination of those. It can also include forms of verbal abuse, in some cases.

It’s a kind of mistreatment that can not only can impact someone’s health, but it can also prevent them from getting work done. Obviously, that’s a significant issue!

You may be surprised to learn who is a workplace bully.

It’s not necessarily someone who yells or intimidates or humiliates; that’s the kind of bully we think of in most cases, but it doesn’t have to look like that. Keep in mind that sometimes the signs of bullying are not that “loud.” Bullying can be more discreet, and can be more difficult to identify than just someone who is perceived as a “jerk.”

Do You Know Someone Being Bullied at Work Today?

According to the Workplace Bullying Institute, here are examples of experiences at work that could suggest you, or someone you know, is being bullied:

  •      Impromptu meetings are held where the sole point of the meeting is to humiliate someone
  •      The work is never good enough for the boss
  •      People have been told to stop talking or to “ignore” someone else
  •      People feel it is okay to scream or yell in someone’s face
  •      HR or coworkers agree the person is a problem, but no one ever does anything about it
  •      Your request to change to another boss/division is denied….with no reason
  •      When confronting the tormentor to stop the abusive conduct, you/someone else is accused of harassment or you/someone else is ignored

Sadly, often times the person who is being tormented is being targeted because they are perceived as a threat of some kind. The Workplace Bullying Institute’s research on the so-called “targets” of bullying saw that often times, the targets are a company veteran and/or the most skilled person in the workgroup (2).

And what if you feel YOU are the one being bullied? According to the Workplace Bullying Institute, here are a few signs you may be bullied at work:

  •      You almost feel sick or do feel sick before going to work
  •      Your family or loved ones think you are obsessed with work at home
  •      You have changes in health like blood pressure or other recent changes in health
  •      Paid time off feels like it is for mental health breaks
  •      You feel ashamed about what is happening at work, so much so that you don’t tell your partner about the interactions you are having with that person
  •      You start to believe that you were the one that provoked the cruelty (2, 3, 4)

How to Prevent Workplace Bullying

Many HR and safety managers, understandably want to prevent workplace bullying. They also want to be able to put an end to it if they suspect it may be an issue already.

The answer to how this can be done: company culture. Let’s take a closer look at what you can do to shut it down.

1. Take steps to make sure workers know what workplace bullying is.

If it’s identifiable behavior, that means it can be appropriately called out. Don’t be blinded by high performers or the person who is doing well in their job; believe it or not, these people can still be bullies. Get clear on what is—and what is not—acceptable behavior in your company.

2. Train your people on how to shut it down, on the spot.

Do workers know how they can respond to a bully if they deal with one, directly or indirectly? And do they just let this mistreatment happen without addressing it, right then and there, if they witness it? Don’t assume all your staff know the right way to deal with someone, in-the-moment, who may be toxic (3, 4).

Also be sure employees feel equipped and empowered enough to say something if they see it happening. That may require ongoing training, which can be well worth the investment. Give workers some sort of space or tool that can allow them to report what they are seeing.

3. Create a script to manage any bullying incidents.

If you are going to sit down and have a conversation with someone you suspect may be a bully, have a script readily available to help address the issue. You want to be as prepared as possible to put an end to any bad behavior.

Mark Murphy, a Forbes Contributor, suggests the following four-part script:

  •      Establish a candid context
  •      Describe the recent issue
  •      Share how that is going to change/needs to change (based on the policies of the company)
  •      Offer a choice to change behavior based on that HR policy (3)

This gives someone the option to adapt their behavior and to stop the mistreatment of others. If they come up with excuses or are unwilling to commit to change, do what it takes to remove them from the environment.

4. Dig for the full story.

Last, have metrics in place that can help tell the whole story about the workplace climate. Identifying and knowing about bullying is part of the solution, but you also want to know why it’s really happening—so you can fix that issue, too.

That’s where a platform like iReportSource can be helpful so you can see unbiased, actionable data points and stats that tell you more about the whole story.

What Else to Know About Workplace Bullying

A company’s culture is always in flux, and you’re never going to be completely immune to any and all bullying. But despite how a company culture is always going to be evolving, you can still do your best to create a stable environment where norms, values, and acceptable behavior is clear (1).

Learn More about iReportSource’s Dashboard

Our analytics dashboard will show you everything you need to be completely confident: from ROI, cost savings, the number of safety trainings completed and much more about the ongoing state of your culture—and that is all with the click of a button.

Are you ready to use data for better decision-making in your company? Learn more today.



A special thanks to iReportSource for sharing their insights on safety in the workplace. For more information on iReportSource, contact Christi Brown at or 513-549-3459. iReportSource allows you to avoid complacency and manage risk, all while helping you to reinforce behavior-based safety practices.

Strategic HR understands your concerns with the well-being of your employees. We offer expertise in health, safety and security to cover any need you may have from analyzing your safety programs to making sure you are OSHA compliant to proactively ensuring employee wellness. Please visit our Health, Safety & Security page for more information on any of these services.


Why Continuous Background Checks Are Now Trending

2018 was filled with a series of events that led many employers to question: Is one initial background screening at the point of hire really enough? Movements like #MeToo triggered concerns about the character of their existing workforce. In addition, a long list of questionable employee actions continues to make the news. As a precaution, many employers have started to implement routine background checks to monitor existing employees for any red flags.

“Continuous background checks are not a bad idea and can be useful in many scenarios. We often see companies conduct yearly checks on their employee’s license as well as additional screenings on education or credit when promotions occur.”

Signet Screening President Matt Messersmith


Continuous screening involves periodic background checks on current employees to identify issues that can occur after a worker is hired.

Continuous background checks aren’t new to the pre-screening employment industry. For some employees, such as healthcare professionals, re-screening every six months is the standard process. But, as technology advances, other industries are deciding to jump on the bandwagon – and so far, success rates appear to be high.

The Chicago Public Schools (CPS) is one such example in the educational field. Nearly 130 CPS employees have been “terminated, recommended for dismissal, or have resigned amid scrutiny” after a review of background checks performed on CPS staff, according to The Chicago Tribune.


1. Security in your brand

Your company’s brand is extremely valuable and can be easily tarnished. Avoid taking any unnecessary risks and be proactive with continuous screening.

2. Confidence in your employees

An initial screening is just a snapshot in time. Just as every employer wants to have confidence in the performance of their employees, they also want to have confidence in their character. Reaffirm your confidence in hires with a continual screening process.

3. Ensure a standard is maintained

Every company has an initial standard that employees must attain to get their foot in the door. But six months later, is your company still holding that standard? If continuous screening isn’t in place, you could be settling for less than you planned. With continuous screening, you can be confident that your company standard is honored.

Thank you to Matt Messersmith, President/CEO, Signet Screening, for sharing your expertise on background checks. Make Signet Screening your hiring partner. By doing so, you will get accurate, timely information about a candidate’s history and insight into their abilities which helps you make better, more informed hiring decisions. Their background screening services include federal, state and local criminal checks, education and employment verification, drug screens, motor vehicle reports, registrations and social media searches. They will work closely with you to design the optimum screening and hiring process that best fits your needs. 

Matt can reached at or (513) 330-6695.

Impact of Inclement Weather on Employees


With the cold months and potential for bad weather, I’m concerned about the possibility of weather impeding our employees’ ability to get to work. What workplace practices and policies do we need to consider?


Great Question, and kudos to you for proactively thinking about potential challenges for your employees and the business. As we move into these colder months with inclement weather, there are a few things that you should consider ahead of time that will help you, your employees, and organization.

By discussing the issue with your management, you can determine what their expectations are for employees should inclement weather impact the employees’ abilities to get to work. You’ll want to talk with your management about:

  • How do they want to handle employees coming to work when the weather may be bad? Are you encouraging employees to be present or is it acceptable to work from home?
  • What will they use to determine if the office would be closed? Consider the level of the weather emergency declared for the county you are located in as well as surrounding counties and how that impacts your decision to close the office.
  • How will they notify employees whether the office is closed or start of day is delayed?
  • Will they allow employees to work remotely on “snow days” and do you have the appropriate processes / connections in place to assure they are productive?

Additionally, you’ll want to be prepared to discuss some key issues with your management, specifically how pay is impacted. Things to consider include:

  • For non-exempt employees, the company is not required to pay the employees. Companies have the choice of:
    • Paying them for the day, even if they don’t work.
    • Not paying them – as long as they conduct no work. This includes quick emails or texts to the non-exempt employee for a “quick question”. If you are asking them a “quick question”, you must pay them for the time worked.
    • Paying them Paid Time Off / Vacation – either requiring them to take it or allowing them to choose PTO or not be paid for the day.
  • For exempt employees, if the company closes, the employee must be paid their regular salary. You may require them to use accrued Paid Time Off / Vacation during a closure, IF you have a policy in place and/or that has been past practice.  If the exempt employee does not have enough accrued time to cover the closure, you are still required to pay them and allow them to go “negative” with their balance.

Keep in mind that PTO is generally voluntarily chosen by the employee, and then is approved or denied by the employer based on business needs. The employer can make it mandatory for employees to use PTO for hours not worked due to missing work due to weather. Again, PTO policies should be stated in a company handbook to avoid any misunderstandings around when employees can use PTO.

Finally, following this discussion with management, we recommend that you formally document the plan into an Inclement Weather Policy and add it to your employee handbook, or at a minimum, notify your employees of your expectations.

If you need assistance in creating a severe weather policy for your workplace, Strategic HR can help you. Contact Us to learn more about how we can help you with this policy or any other policies for your employee handbook.

Do Injury Prevention Programs Really Work?


We’ve experienced an increase in work-related injuries this year.  Do injury prevention programs really work?


The answer is a resounding YES! Quality onsite injury prevention programs accomplish over a 50% reduction in musculoskeletal recordable injuries and the associated cost along with a 30% reduction in non-work-related musculoskeletal issues.

This is a key point as you begin to look at the various injury prevention programs because many employers do not realize the level of impact preventative measures could have on their business.  Injury prevention programs return a significant ROI in many different industries and with employers of all sizes.  The value of an injury prevention program extends way beyond the dollars and cents impacting the lives of your employees and changing the culture of your organization.

There are some actionable steps that can be taken to identify if your organization may be a good environment for an injury prevention program, but it starts with a commitment at the leadership level.  Start by investigating the questions below and consider your responses:

  • Evaluate OSHA logs and look at the frequency of your musculoskeletal injuries or sprains and strains. What is the % of your recordable injuries that fall into these categories (Contusions, sprain/strain, slip, trip or fall)?
  • Look with an outsider’s eye at the culture of your organization and try to be objective. Is there a focus on early reporting without consequences?  Are there other programs in place such as ergonomics teams, safety teams or cross functional groups that look at injury prevention opportunities?
  • Do you have a significant number of employees out for non-work related musculoskeletal issues? Does this create strain on your workforce in any way?
  • Do you have a high amount of injuries with newly hired employees?
  • Evaluate your operations for work that is physical and or repetitive. Do you have one or both?

If you answered yes to these questions above or if you feel like you would like to change any of your answers, an Onsite Injury Prevention program may be perfect for you.  Injury prevention programs are best operated through third party companies whose interest totally aligns with one of preventing employees from becoming patients.  Furthermore, a quality injury prevention program should focus on the leading versus lagging indicators to an injury.   The best programs focus on ergonomics, human movement patterns and early intervention for minor soreness’s in the space where work is occurring or “on the floor”.

A properly infused program can be magical for organizations and can have a significant impact on bottom lines, injury rates as well as employee morale and retention.  Don’t let preconceived notions about programs not working or being too expensive stop you!

A special thanks to Tom Ernst, PT, MPT, OCS, COMT with Oxford Physical Therapy, a client of Strategic HR, for responding to this question for us.  If you are evaluating your business for an onsite injury prevention program, we’d encourage you to reach out to Tom to learn more about Oxford at Work. Tom can be reached at or 859-240-4761.  Oxford at Work’s goal is “Keeping your employees from becoming patients.” To learn more, check out this video (password: 50%reduction).

Strategic HR is an outsourced HR management firm that works with many businesses of all sizes and industries. We all have similar needs across the HR spectrum and in general in running our businesses.  Please keep Strategic HR in mind as a strategic partner for your business. We are just an email ( or phone call away (513-697-9855).



Emergency Response Plans: Preparing for Emergencies & Natural Disasters

HR Question:

Do we need an emergency response plan?

HR Answer:

Would your team members know how to react if there was a tornado? What about a fire or an active shooter? These questions matter because emergency response plans are becoming more critical than ever. Emergency response plans should include the actions that need to be taken, should certain situations occur as well as what to do following the emergency or disaster.

Often, companies may talk about this in terms of a business continuity plan, or having an enterprise resource management plan. Whatever it’s called, it’s important to have so that there are guidelines for how to best respond. “It’s just a way of thinking about what happens after the firetrucks leave, after the tornado rolls through, or after that emergency happens: What are workers going to do?” says Karen Hamel, CSP, WACH, a regulatory compliance specialist and technical writer at New Pig Corp. (New Pig Corp specializes in workplace safety and spill containment products.)

“Part of that is, of course, being prepared for the emergency itself. It’s important to make sure that you have Emergency Response Plans for what the insurance doesn’t cover, too,” she says.

Hamel shares 4 planning tips that can assist leaders with emergency planning and prevention:

Tips for preparing Emergency Response Plans

#1: Predict What Kind of Emergencies Could Happen

Whether it be a natural disaster or a business attack, take the time consider what kind of risks your company has, even if they’ve never happened before. It’s not acceptable to say, “We never thought that would happen.”

“It can be looking at what happened in your facility or looking at the nature of your facility,” explains Hamel. “If you’re a chemical facility and you deal with a lot of hazardous chemicals, how can they affect your employees? How can they impact the environment? If you’re dealing with a lot of flammable products, if you had an explosion, what would the result of that be?

“Look at both natural hazards as well as the manmade ones to determine what might happen at your facility so that you can properly plan and have the equipment, the people, the training that you need to deal with whatever your particular emergencies are.”

Action steps: “The Federal Emergency Management Agency (FEMA), the American Red Cross and other organizations offer free information that can help you become aware of disasters and emergencies you may face. They also offer templates to help facilities begin planning,” says Hamel.

#2: Prepare Your People

After you’ve considered what could happen, start preparing employees. Procedures and drills are important to ensure everyone knows what to do at the time. But also make sure you have the resources that you’ll need after.

“If you have a call center, for example, it could be establishing a different call center. Or, it could be establishing a way for some of your employees to work from home so that you still have the capability of taking customers’ calls, and being ready for those sorts of emergencies if they do happen,” says Hamel.

Action steps: Planning also needs to include your communicate plan. How will you communicate with employees, families, outside responders, mutual aid groups, stockholders, vendors, customers and the media? “Maintaining organizational charts with contact information can seem like a never-ending task, but it is a critical element of emergency planning.”

#3: Focus on Protecting Lives

Life safety is a key principle of every emergency response, and the logistics you have in place need to be able to align with your plan to protect your people (and property). “Make sure that when there is that crisis or emergency, that people and property are taken care of.”

The list is long, but that can include:

  • Making sure there is shelter place for employees for certain disasters
  • Knowledge and plans of response duties
  • Evacuation plans
  • Steps to make sure people are accounted for after an emergency
  • Back-up power systems

Action steps: Just like standard operating procedures you have, detail the steps to be taken to perform work tasks safely. These emergency response plans need to outline and make visible what procedures the company expects employees to follow when anything out of the ordinary happens.

#4: Be Sure You Practice  

“Practice” comes down to training and making sure that people have the tools that they need to do their jobs. And, make sure that they know how to use the tools.

Making sure workers have the confidence and the ability to use whatever tools, resources, supplies are on-site is going to make things go smoother in case of an emergency.

“This is about just making sure that people know what’s expected of them. It can help avoid a lot of chaos, and it can help keep everybody be a lot safer when a response is needed.”

Action steps: Don’t neglect training or drills and do you best to make sure workers have the right attitude about practicing.  “Training and drills do take time, but they give everyone the chance to get things right before they are in a critical situation. They also can identify plan shortcomings so that they can be corrected before an emergency. Allow time after drills for everyone to comment on what worked, as well as areas where people may need further training,” says Hamel.

A special thanks to iReportSource for sharing their insights on safety in the workplace and the importance of having Emergency Response Plans. For more information on iReportSource call 513-442-8595. iReportSource allows you to avoid complacency and manage risk, all while helping you to reinforce behavior-based safety practices.


It’s not negative thinking to plan for a devastating event that could harm employees or impact your company’s ability to function – in fact it’s a good business practice. Bad things happen, but it’s how we prepare for and recover from a disastrous event that often leads to success or failure. Strategic HR has a variety of resources to help you prepare for such emergencies. Visit our Health, Safety & Security page to learn more about how we can help you with your Emergency Response Plans OR pick up our Emergency Preparedness Toolkit and do-it-yourself.

Managing Workers’ Compensation and Claims


I just took over responsibility for managing workers’ compensation claims at my company. Where do I start?


If you are new to the responsibilities of managing the workers’ compensation process, it can be overwhelming. There are responsibilities that both the employer and employee have in the process. Compliance laws vary from state to state, so make sure that you are familiar with your state requirements. Compliance is very important, but it’s far from the only thing that matters when it comes to true operational excellence.

It takes an integrated risk management strategy to ensure your organization is performing safely, efficiently and profitably. When proactive measures are implemented consistently, accountability is shared across the entire organization. And, when this is combined with a transparent process for when an injury occurs, an organization can achieve operational excellence, improve results, improve employee engagement, and the company reputation will also benefit.

The Basics

Outline Your Policies

As a first step, outline the process and expectations at your company for what happens when an injury occurs at work, medical care for the injured, a process for completing the claims such as:

  • First Report of Injury
  • Accident investigation
  • Time away from work
  • Accommodations
  • Return-to-work process
  • Training requirements
  • Communication methods and frequency
  • Employee responsibilities
  • Preventing injuries

Build a Consistent Process

Once outlined, you need a uniform and consistent process for executing these policies and procedures. Many companies have had challenges with managing workers’ compensation claims as traditionally the forms to be completed have been paper-based and then emailed or shared on an intranet. Many companies are moving away from this due to the challenges of consistency of information, accuracy, timeliness, siloed information, and using incident reporting and safety software for data collection to solve these challenges.

Simply put, using technology to track the data and information, that is—makes it more easily accessible and it helps to make your programs more effective. These systems help you get the reporting and insights that you need quickly and easily to make improvements and understand your most vulnerable areas.

Prevent Injuries In The First Place

Much like healthcare’s focus on preventive care, Environmental Health & Safety has been adopting processes to prevent incidents. If you keep workers safe, you will have fewer accidents and reduce your workers’ comp exposure. This is the secret to being successful in your role in handling workers’ compensation responsibilities.

A safe workplace includes basics such as:

  • Providing and using proper equipment and personal safety gear
  • Identifying potential hazards regularly and resolving them quickly
  • Reporting and addressing unsafe conditions
  • Providing health and safety training on safe work practices
  • A process to report and investigate accidents

Not only is proper equipment, training and processes important, but establishing a culture that has a commitment to health and safety is key. This includes creating a supportive work environment that makes everyone accountable for safety and accident prevention.

As the owner of the process, it’s important that you ensure that all supervisors and/or managers know that they are responsible for the safety of employees under their direction as they can take an active part in preventing injuries.

Not only is injury prevention important for the health and viability of your employees, but it saves substantial costs – both direct and indirect. Costs of managing workers’ compensation claims are not only the direct costs of sick and/or disability pay, but the indirect costs associated with lost productivity, replacement costs, and overtime.

Technology Can Help

With anything, in order to make an overwhelming process successful, you need to provide the right tools. Easy to use software, like iReportSource, allow your workers to collect information in the field on a proactive and reactive basis. The ability to complete safety audits, site inspections and/or allowing workers in the field to submit safety suggestions in a real-time manner will help reinforce a culture of safety accountability as it’s simple to see who, when and what was submitted. And what’s easier than a few taps on a mobile phone?

Your role in managing workers’ compensation is critical to the success of the business. Don’t let the compliance and day-to-day requirements overwhelm you. It can be intimidating in the beginning, but there are plenty of tools, like iReportSource that can help you be successful.

The barrier to operational excellence in safety and workers’ compensation is lower than ever. What’s stopping you?

A special thanks to iReportSource for sharing their insights on safety in the workplace. For more information on iReportSource contact Nancy Koors at or 513-442-8595. iReportSource allows you to avoid complacency and manage risk, all while helping you to reinforce behavior-based safety practices.


Strategic HR understands your concerns with the well-being of your employees. We offer expertise in health, safety and security to cover any need you may have from analyzing your safety programs to making sure you are OSHA compliant to proactively ensuring employee wellness. Please visit our Health, Safety & Security page for more information on any of these services.

What Does It Mean To Be a Partially Exempt Industry Under OSHA?


According to our company’s NAICS code it says we’re a Partially Exempt Industry. Do we have to complete the OSHA Form 300A each year?


If your North American Industry Classification System (NAICS) code classifies you as a Partially Exempt Industry, it is not necessary to complete OSHA injury and illness records (including the OSHA Form 300A). Unless you are asked in writing to do so by OSHA, the Bureau of Labor Statistics (BLS), or a state agency operating under the authority of OSHA or the BLS. 

SHRM’s article “Am I Exempt from OSHA’s Recordkeeping Requirements” notes that there are two exceptions to OSHA’s recordkeeping requirements.

  1. First, businesses with 10 or fewer employees must keep these records only if the agency specifically requires them to do so. Businesses with 10 or fewer employees throughout the previous calendar year do not need to complete recordkeeping forms. Keep in mind that if there are more than 10 employees at any time during that calendar year, the employer may come under the requirement. When counting employees, business owners must include full-time, part-time, temporary and seasonal workers.
  2. The second exemption is for establishments classified in certain industries. For example, restaurants, banks, and medical offices do not have to complete the forms. For a complete list see the OSHA List of Partially Exempt Industries.

Please note that all employers, including those partially exempt by reason of company size or industry classification, must report to OSHA any workplace incident that results in a fatality, in-patient hospitalization, amputation, or loss of an eye. Make reports to the local OSHA office or to 1-800-321-OSHA within eight hours of when managers become aware of the incident.

Strategic HR understands your concerns with the well-being of your employees. We offer expertise in health, safety and security to cover any need you may have from analyzing your safety programs to making sure you are OSHA compliant to proactively ensuring employee wellness. Please visit our Health, Safety and Security page for more information on any of these services.


Are Evacuation Drills Mandatory to Meet OSHA Training Requirements?

Image of Workplace Safety Manual, along with work tools

Updated June 2022

HR Question:

According to the OSHA Training Requirements, is it mandatory that I conduct practice evacuation drills as part of my company’s annual training?

HR Answer:

The Occupational Safety and Health Administration (OSHA) does not require employers to conduct drills at a certain frequency. However, it is recommended as part of a comprehensive Emergency Action Plan, which is required. OSHA standard 29 CFR 1910.38(a) outlines the requirement for written documentation, planning, and training for workplace emergencies, and as an employer, preparing for the ‘worst case’ is something you should want to do. In today’s world where we’ve seen an increase in active shooter incidents, unpredictable weather patterns, and wildfires, emergency preparedness will allow you and your employees to have a plan in place should you be impacted by some type of potentially hazardous situation.

How to Prepare Employees for Workplace Emergencies

Employers should consider evacuation plans as one small part of the required Emergency Action Plan and use them as the opportunity to practice. The drills could include evacuation due to a fire, chemical leak, or even a shelter in place in the event of an external chemical emergency.

OSHA’s Evacuation and Procedures e-tool provides step-by-step guidance to help you prepare your workplace for potential emergencies. In addition, this OSHA Workplace Emergencies Factsheet provides an outline of what is required. Once you have a plan in place, OSHA recommends that you review the plan with employees and hold practice drills “as often as necessary.” It is also advised to include outside resources such as fire and police departments when possible. OSHA recommends that after each drill you assess the effectiveness of the drill (and the plan) and make adjustments as needed.

How to Meet OSHA Training Requirements

Workplace safety training will vary depending on the type of business. Here are some important points to consider when deciding what types of training your employees need to meet OSHA Training Requirements and Standards:

  •  Educate your employees about the types of emergencies that may occur and train them in the proper course of action.
  • The size of your workplace and workforce, processes used, materials handled, and the availability of onsite or outside resources will determine your training requirements.
  • Be sure all your employees understand the function and elements of your emergency action plan, including types of potential emergencies, reporting procedures, alarm systems, evacuation plans, and shutdown procedures.
  • Discuss any special hazards you may have onsite such as flammable materials, toxic chemicals, radioactive sources, or water-reactive substances.
  • Clearly communicate to your employees who will be in charge during an emergency to minimize confusion.

It is a good idea to keep a record of all safety and health training. Documentation can also supply an answer to one of the first questions an incident investigator will ask: “Did the employee receive adequate training to do the job?”

Emergency Action Plan Resources

OSHA has a number of outstanding resources to assist you in your planning process for an Emergency Action Plan, as well as all of the required OSHA standards. Free resources to help you with your safety training plans can be found in OSHA’s Training Resources and this updated booklet which outlines all of OSHA’s training-related requirements in one document.

Keep in mind that although drills are not required, a well-developed emergency plan with proper training (including drills) will result in fewer injuries and less confusion and chaos during an emergency. A well-organized response will help you, your employees, and your business to be in the best position to effectively handle an emergency.

Thank you to Patti Dunham, MBA, MA, SPHR, SHRM-SCP for updating this HR Question of the Week.


Are you overdue on harassment or other annual training?  Does your current training curriculum need to be refreshed to reflect changes in company policy or legal requirements?  Strategic HR has the expertise and resources to help.  Visit our Training and Development page to learn more or Submit a Training Request.

House Bill 523: The New Law that Legalizes Medical Marijuana


As an Ohio company, I am confused about what changes, if any, I need to make as a result of the implementation of House Bill 523, the new law that legalizes medical marijuana on September 6, 2016.  Does this mean my drug free workplace policies are no longer valid?


No, this does not mean your drug free workplace policies are no longer valid.

Employers are still free to have drug free workplace policies and now is the time to look at your policy and make sure it can withstand the change.  Some legal counsels are recommending that policies be updated to state specifically that medical marijuana is prohibited under the policy.  If you make the change, be sure to distribute and explain the policy and have employees sign off on the acknowledgement.

With such a policy in place, employers may still have the right to discharge employees who fail a drug screen, even if it was due to the use of medical marijuana.  The discharge would be considered ‘just cause’ making them ineligible for unemployment.  In addition, an employee may not be eligible for workers’ compensation for their injury if their injury was the result of being under the influence of marijuana.

Be sure to make sure your policy is up to date and all employees are treated equally under the policy. (For the nitty gritty details, click here)

Do you struggle with doing what is right for your company and right for your employees when it comes to creating a Drug Free Workplace? Sometimes the “right” solution isn’t always easily identified. Strategic HR understands your dilemma of being between a rock and a hard place. We can provide you with best practices, policies and training when it comes to creating a Drug Free Workplace or any needs concerning the Health, Safety and Security of your workforce. Please visit our Health, Safety & Security or Training page for more information on any of these services.

What is a powered industrial truck according to OSHA? Do you need proper training?


Our Warehouse Manager just got a new piece of equipment that I would describe as a type of pallet-jack. When I questioned him about training on the equipment, he said that because an employee does not sit on the piece of equipment to operate it, so there was no required training under OSHA. Is that true? What is the definition of a powered industrial truck according to OSHA?


Actually, the Warehouse Manager is incorrect. When most people think of required OSHA standards for that type of equipment, they think of lift trucks. OSHA’s standard for “Powered Industrial Trucks” , however, is much broader than that. OSHA defines a powered industrial truck as “Any mobile power-propelled truck used to carry, push, pull, lift, stack or tier materials. Powered industrial trucks can be ridden or controlled by a walking operator.” The standard does designate and say that earth moving and over the road haulage trucks are not included in the definition. Equipment that was designed to move earth but has been modified to accept forks are also not included. Your Warehouse Manager better get his policy in order and start training under the standard.

See OSHA’s Q&A on the standard here:

Accidents happen! But they’re called accidents because they weren’t anticipated. Once the accident does occur it’s up to employers to make sure accidents don’t repeat themselves. Strategic HR has the tools and knowledge needed to help you break the cycle of accidents in the workplace. We offer expertise in everything from safety audits to writing safety manuals and procedures.

For more information on how we can keep your employees safe please visit our Health, Safety & Security page.

OSHA 300-A Log


I know I am supposed to take my OSHA 300-A log down on April 30.  How long do I have to keep it after I take it down?


You are correct!  The log can come down on April 30, but according to OSHA Standard – 29 CFR -1904.33(a), employers must save their OSHA 300 Log, the Form 300-A (annual summary), and the Form 301 Incident Report forms for 5 (five) years. The stored OSHA 300 Logs must be updated by the employer to include any newly discovered recordable injuries or illnesses…even after the log had been posted.

Have you had a safety audit recently? Do you know which OSHA forms you are required to complete? A safe environment plays a key role in keeping a company Healthy, Safe and Secure. Strategic HR has the expertise you need to ensure your policies and practices are keeping your workers, and customers, safe. Visit our Health, Safety and Security page to learn more about how we can assist you or contact us now at

Obesity in the Workplace


According to SHRM’s 2014 Global HR Trends Report, obesity is on the rise in the U.S. and worldwide. If current trends continue, more than 50% of the U.S. adult population will be obese by 2030. The growing number of employees and candidates who are obese concern me as an employer because I have heard that they are deemed as having a disability.  Is that true?  What does that mean to me as the HR Manager?


Yes, under the ADAA, the courts have expanded the legal definition of when obesity constitutes a disability. Employees are no longer required to establish that their obesity is due to another physiological condition or disorder. Obesity alone – whether morbid, severe, or simple obesity – can cause sufficient impairment that a person can be deemed as “disabled”.  Morbid obesity is defined as a body mass index (BMI) of 40 or higher; severe obesity is a BMI of 35-39.9 and simple obesity is a BMI of 30-34.9. Under the new amendments, the EEOC states that basic obesity alone can sufficiently impact life activities like bending, walking and transportation and it could now be treated as a physical impairment.  As in most potentially legal situations, each situation is unique and should be looked at carefully before taking any action.

As an HR Manager, the bottom line is that there are many more potentially disabled employees in the workplace. Employees who may be entitled to nondiscrimination protection and potentially reasonable accommodations if necessary.  Keep in mind, accommodations can be simple.  Things such as a large ergonomic chair, seat belt extenders for industrial equipment, or even allowing an employee to use a scooter.  Bottom line, be sure to treat obese employees as any other potentially disabled employee in the workplace and work with the employee to determine if an appropriate accommodation is necessary and can be made.

Strategic HR understands your concerns with the safety and well-being of your employees. We offer expertise in health, safety and security to cover any need you may have from analyzing your safety programs to making sure your policies and procedures are compliant and protect your staff. Please visit our Health, Safety & Security page for more information on any of these services.

Rating Employees On Safety


How do we rate employees on safety?


Rating employees on safety starts by having an organization whose norms, beliefs, attitudes,and practices are concerned with minimizing exposure of employees to workplace hazards.Having an effective Safety Incentive Programs can definitely help and, although all are not alike,it is important to consider some of these basic elements:

  • Identify the objective – Determine why you want to establish the program. It could be to decrease workers’ compensation premiums by reducing the number of worker injuries, or your goal may simply be to reinforce general safety principles.
  • Select participants – Decide which employees need to participate in the program to achieve the long-term goal.
  • Establish a theme – Having a focus reminds participants of the goal you want your employees to achieve.
  • Select appropriate prizes with increasing value – Prizes don’t have to be expensive, but they should have meaning. Prizes that reinforce the contest theme can be very effective; for example, safety glasses, work shoes, hard hats, etc. Give prizes based upon the company’s safety record (i.e., 1,000 accident free days, 50,000 hours worked without lost-time accident, etc.).
  • Determine the program’s length – It should be intermittent and last for a specified period of time. If carrying out a program idea will require a prolonged period, you might consider having several short contests. This will maintain employee interest and allow managers to stress various safety issues.
  • Communicate the goal – It is important that the program is fun and relevant to the work experience of all participating employees. Also, make recognition for working safely more significant than the value of the prize.

Have you had a safety audit recently? Do you know which OSHA forms you are required to complete? A safe environment plays a key role in keeping a company Healthy, Safe and Secure. Strategic HR has the expertise you need to ensure your policies and practices are keeping your workers, and customers, safe. Visit our Health, Safety and Security Page to learn more about how we can assist you.

Who’s Using Your EAP


We just implemented an Employee Assistance Program. What do I need to know about EAP use in order to better share this new resource with employees?


Although depression is a primary reason employees call their Employee Assistance Program (EAP), many other services are available. In addition to personal and family counseling, most programs cover substance abuse, grief support, child care, elder care, financial education and legal assistance.

ComPsych, a leading provider in Employee Assistance Programs, recently analyzed data from the millions of calls they handle each year. The published results were quite interesting.

The top four types of EAP calls were:

  1. Psychological (mental and emotional) 41.7%
  2. Partner/relationships 19.9%
  3. Family/child (behavioral issues) 14.3%
  4. Stress/anxiety 10.5%

Though women callers still outnumber men (61 versus 39 percent), the percentage of men accessing EAP and work-life services has gradually but steadily risen over the past decade. Though fewer men call assistance lines, more men called for help with relationship issues than women (22 versus 18 percent). Furthermore, men were almost five times as likely to call about alcohol and chemical dependency issues.

Why are these statistics important? Because most employees won’t even think to use your EAP until they are in the middle of a crisis. By understanding your audience and their concerns, you can tailor your communications to meet their particular needs. Ask your provider for data on the EAP services most used by your employees. Then create a targeted, year-round communications plan to help employees understand the types of support they can receive and how to take action when they are ready.

How can you promote your EAP?

  • Display posters promoting the most-used services, focusing on one issue at a time. If possible, ask your provider to use images of people who reflect your audience. For example, are they blue-collar workers? What’s their age range and ethnicity? Always highlight the phone number and website so employees know where to go for help. And be sure to change the posters frequently, since different services are needed at different times.
  • Dedicate a portion of your benefits website to your EAP. List all the services available (putting the most-used at the top of the list) and provide simple instructions on how to get help. Emphasize that all services are provided by a third party who protects their privacy and never shares personal information with the company.
  • Promote your benefits website through a direct link on the home page of your intranet.
  • Cross-promote EAP services by featuring a variety of stories in your company newsletter, enrollment materials or postcards. Remember, spouses and other family members may not realize assistance is available, so include EAP information in materials sent to homes.
  • If a location suffers a natural disaster, such as a hurricane or tornado, actively promote your EAP services. If possible, have representatives from your provider available on site to assist employees and their families through the aftermath.

Statistics show both men and women are taking advantage of a variety of valuable EAP services. By understanding who’s using your EAP and why, you can create a targeted, year-round communications plan that increases awareness, acceptance and usage of your plan.

A special thanks to Elizabeth Borton, President of Write On Target, for sharing her expertise with us. Sign-up on her website at to receive future communication blogs at Or, you can contact her with questions at or 937.436.4565 at extension 28.

Strategic HR understands your concerns with the well-being of your employees. We offer expertise in health, safety and security to cover any need you may have from analyzing your safety programs to making sure you are OSHA compliant to proactively ensuring employee wellness. Please visit our Health, Safety & Security page for more information on any of these services.

Accidents in the Workplace


We seem to be experiencing a flare up in minor workplace accidents. What are some steps we can take to raise safety awareness and reduce the number of incidents?


It happens to many organizations…it is easy to take safety for granted and that is when the bottom falls out and accidents start to rear their ugly head. With a recent outbreak of accidents, be sure you are doing a complete accident investigation and determine if there are any trends in the accidents that are occurring. The accidents may have the same root cause which you can nip quickly and effectively. In addition to the actual accident review, the best recommendation is to GET YOUR TEAM INVOLVED! You can’t maintain a safe environment alone. A great way to ‘revive’ the safety culture is to get others active in the process. Those involved will become engaged and energized in helping you and perhaps even drive safety activities and suggestions. Use your safety team to review current safety policies, create new safety programs and training, and come up with new safety incentives and recognition awards. This team could also conduct safety audits as well as review current training programs to identify what doesn’t “work” or identify things that may not even be covered. When creating this new safety-focused team be sure to involve established employees as well as new hires. Newly hired employees are an especially important part of the team because they may bring ideas from other organizations AND they see things in the workplace through fresh eyes. What we become used to seeing every day, someone from the outside can see through. They may be more apt at picking out potential danger or safety concerns. In some cases allowing a fresh set of eyes review the situation may be all that is needed to create effective solutions.

Accidents happen! But they’re called accidents because they weren’t anticipated. Once the accident does occur it’s up to employers to make sure accidents don’t repeat themselves. Strategic HR has the tools and knowledge needed to help you break the cycle of accidents in the workplace. We offer expertise in everything from safety audits to writing safety manuals and procedures. For more information on how we can keep your employees safe please visit our Health, Safety & Security page.

How To Handle Expired Prescription Drug Use In The Workplace?

Updated July 29, 2020

HR Question:

We recently had a situation where a longtime employee, with no prior incidences, took an expired prescription drug that was inhibiting her performance. After her drug test, she tested positive with it in her system and the script was older than one year. What should I do?

HR Answer:

This is certainly a tricky situation, and you are not alone in dealing with this challenge. A recent National Safety Council survey reports that more than 70% of employers have been impacted by prescription drugs, yet only 19% feel extremely prepared to deal with prescription drug misuse.

As you begin to assess your next steps, here are some things to consider:


What does your Drug Free Workplace Policy say? Typically, an acceptable deviation of a positive drug test is supplying a valid prescription from an attending physician. In this situation, the employee does not appear to have that if the drug was expired. What does your policy say about the consequences of a positive test? Take the opportunity to assess if you’ve covered as many conceivable scenarios as possible – from an expired prescription to innocently taking a family member’s prescription in an unusual circumstance.


This is why Drug Free Workplace training is so critical. Such training should inform employees and managers of exactly these types of situations and potential consequences so this scenario can be avoided. What does your policy say about training? Have you adhered to that?


What are the consequences of making an exception? If you make an exception for this individual, are you willing to make an exception the next time it happens to another employee (perhaps a lower performing employee)? Does making an exception impact the effectiveness of your Drug Free Workplace program?


Contact your Medical Review Officer (MRO) or find one that is familiar with your industry to gain some advice, as they are the experts. They will be able to assess whether or not the positive drug test is justified by the prescription or not, shedding some light on the next steps to take.

Unfortunately, there is no easy answer in this situation. It is vitally important that you remain unbiased, fair, and that you do what’s best for your company. Carefully consider the impact of your decision on future situations that may arise.


Providing a Drug Free Workplace Policy and Training are incredibly important when it comes to the safety and security of your workplace and employees. Strategic HR can provide you with best practices, policies, and training when it comes to creating a Drug Free Workplace or any other needs concerning the Health, Safety and Security of your workforce. Contact us to learn more about how we can help to develop your Drug Free Workplace Policy and Customized Training or view our Online Drug Free Workplace Training.  

Good Samaritan Law


If an employee tries to medically help someone during a medical emergency are they or our company liable if something should go wrong?


If you work in Ohio you are covered by something called the “Good Samaritan” law that protects bystanders who provide emergency aid from financial liability if there is an unintended injury or wrongful death. This law is meant to protect those providing emergency care at the scene of an emergency and does not apply to care provided to someone already in a medical facility. Nor does it protect someone if they expect payment for the treatment (such as from an insurance company). Stated best, the law is designed to let people do the right thing without fear of being sued.

To see the details of Ohio Good Samaritan laws  visit the ORC website.

An injury in the workplace is no laughing matter and Strategic HR understands your concerns with the well-being of your employees. We offer expertise in health, safety and security to cover any need you may have from reviewing your safety procedures to helping you with employee wellness initiatives. Please visit our Health, Safety & Security page for more information on how we can assist you with Health, Safety and Security.

Image of our Wheel of HR Services, with a focus on Employee Relations.

How do we deal with employee body odor?


We have an employee with strong body odor and other staff feel it is making them ill at work. How do we address such a sensitive topic?


Addressing personal care issues that affect others at work can be difficult conversations to have. Keep in mind the offending employee may not be aware that they have an odor problem, they may have a medical condition, or it may be the result of customs or cultures. Regardless, to keep harmony among your staff the situation needs to be addressed in a sensitive manner.

Be sure to take the employee to a private area to speak. It is also important to be clear in the reason for the conversation, but also be sensitive to the embarrassment it might cause the employee to have such a personal a discussion with their manager or human resources. The most direct route is best. State the problem, “It has been brought to my attention that you have a strong body odor”, and ask a follow up question to allow them the opportunity to share any possible reasons for the situation, “Do you have a health condition or a custom that might be contributing to excessive body odor?” If a health condition is present you will need to determine if there is an issue under the American’s with Disabilities Act (ADA) that will need to be accommodated in some way. If the cause is determined to be due to hygiene issues, the employee should be coached to work on their hygiene, focusing on the connection to the health and well being of themselves and others around them. If there is a company policy addressing appearance and cleanliness, this can be referenced as a guideline for the employee to follow and to emphasize the connection of the discussion to company policy versus a personal attack.

In any case, be considerate and handle the issue with discretion. This can be one of the toughest HR conversations you may have and in most instances it is just as hard for the receiver.

Having healthy employees is a key reason for developing a company wellness program, but also give consideration to the cost savings. Not only does a healthy workforce impact costs related to ever increasing health care expenses, but also impacts other expenses that are being trimmed as the economy necessitates a tightening of the belt in all areas of the company. Visit our Health, Safety & Security page to learn how we can assist you with issues surrounding the health and safety of your workforce.

How To Conduct A Safety Audit


I have a safety committee comprised of all new members. We need to conduct a safety audit of our facility. How should we structure our audit?


The most important part of a safety and health audit is to make some specific decisions early on. Questions must be answered such as:

  1. Who is going to do the audit? Are you going to do it internally or involve an external party? If internal, who is involved specifically – HR? A team of safety and healthy experts in a committee?
  2. What are you actually going to audit – a part of safety and health in the organization or all aspects? If you are interested in doing a full audit, it is best to pick a specific area to work on – one at a time. Pick a monthly task to audit specifically (e.g. hazardous communication standard, lock out/tag out, emergency evacuation, etc.) and focus on that as an audit topic each month. Focusing on one topic will allow you to dig deeply into the standard and ensure compliance at all levels.

Once you are ready to audit and you know who and what is going to be a part of the audit, you need a clear checklist or questionnaire to use to audit each of the various aspects. In general, the audit should include the following items:

  • Determine what requirements you are supposed to meet – look at all areas of legislations including state and federal.
  • Assess whether or not you are meeting those legal requirements.
  • Review your documents to ensure you have good documentation as well as best practices in place in recordkeeping.
  • Identify any areas of risk in the workplace and determine how the organization attempts to minimize those risks.
  • Identify strengths and weaknesses in your safety procedures.
  • Recommend areas of improvements necessary for compliance and best practices.
  • Document the implementation of those recommendations to ensure they do not become a legal liability in the future.

Once you have these pieces in place you are ready to audit – good luck!

Do you worry about doing what is right for your company and right for your employees while being legally compliant? Strategic HR understands your concerns with the well-being of your employees and the legal compliance of your organization. Conducting an audit of your Health and Safety function is a key component to making sure you are compliant. Let us help you with your audit using our tried and true practices. Please visit our Health, Safety & Security page or Legal Compliance page for more information on any of these services.


What is a Safety Audit?

Updated July 2021

HR Question:

My manager is concerned about our company’s ability to pass a safety inspection and wants us to do an audit. What is a safety audit?

HR Answer:

Safety audits (known more formally as health and safety audits) are routine, comprehensive reviews geared towards gauging the efficiency, effectiveness, and legality of a company’s safety management programs. Audits assess a company’s compliance to applicable regulations or codes as well as the identification of unsafe conditions in the workplace. Audits also provide an evaluation of workplace adherence to Occupational Safety and Health Administration (OSHA) standards relating to workplace and worker safety. There are also DOT regulations that need to be met if they apply to your company’s line of work. Keep in mind that safety audits are meant to check the effectiveness of various programs, but they do not take the place of regular facility inspections, which should be done on a much more frequent basis as facility rules dictate.

When conducting a safety (or OSHA) audit there are two things to evaluate: compliance and safety. When reviewing compliance it is important to evaluate how the company handles conformance to the prescribed codes or standards, recordkeeping, and training of employees. When assessing safety, the objective is to identify unsafe work conditions, rather than unsafe acts or behaviors. And with the addition of COVID-19 safety precautions and regulations, employers have an additional layer of guidance to adhere to in order to keep their employees safe.

There is no “one size fits all” approach to health and safety audits. Audits must be customized to the type of industry, size of the company or location being audited, applicable local, state, and federal laws and any other company-specific factors that might affect the safety and health of your workforce.

Have you had a safety audit recently? Do you know which OSHA forms you are required to complete? Strategic HR has the expertise you need to ensure your policies and practices are keeping your workers, customers, and visitors safe. Visit our Health, Safety & Security page to learn more about how we can assist you with workplace safety.

Work Related Injuries from a Home Office


I have “virtual” employees who don’t spend all their work time in the office. How do I know if an employee’s injury is work related if they work out of their home?


This is one of the big challenges that employers face when they allow their employees the opportunity to work from home. Overall, injuries and illness that occur while an employee is working at home is considered work related (and thus compensable) if the illness or injury occurs while the employee is performing work for pay in the home and the injury or illness is directly related to the performance of work. These type of injuries cannot be related to the general home environment (i.e faulty wiring, tripping on the carpet) but rather must be related to the performance of work.

What is a compensable injury? One might be an injury to a finger that was slammed in a filing cabinet drawer while filing papers for work. Another could be an injury to the foot due to a dropped heavy box (assuming the box was for work purposes and contained work materials). Proving how some of these injuries occurred in the home is a challenge because there is a lack of witnesses, and there is the inability to control the work environment to ensure adequate safety and housekeeping to prevent injuries. Creating policies for your employees to ensure they keep a professional, well-kept and safe work environment at home, as well as requiring them to report any work related injuries or illness immediately, is essential.

Strategic HR understands your concerns with the well-being of your employees. We offer expertise in health, safety and security to cover any need you may have from creating a communicable disease policy to developing a business resumption plan for handling unexpected emergencies. Please visit our Health, Safety & Security page for more information.

Ensuring Safety in the Workplace


We seem to be experiencing a flare up in minor workplace accidents. What are some steps we can take to raise safety awareness and reduce the number of incidents?


The most important thing to do is to look around and see what you are doing and determine what has changed in the recent past to cause this flare up. Sometimes the cause is easy to identify, but many times not. Overall, there are a number of things employers can get involved in to ensure their organization moves toward a ‘safety culture’, one where safety is valued and resulting in an improved safety record.

  • Create a safety culture from the top down. Safety should be discussed  at the very beginning of employment from recruitment to job descriptions to background checks and reference checks. Start talking safety early and always in your workplace.
  • Be sure your employees know they are partners with the organization in the safety effort. Safety is NOT just for the employer to do. It must be a team effort with cooperation of the employees and employer to be successful.
  • Create involved safety programs to involve employees in that effort.
    • Create safety committees that are employee based.
    • Make safety training a priority in your organization and talk about it (even if briefly) in all meetings.
  • Investigate all accidents and near misses in your organization to determine their cause and to avoid future accidents.
  • Conduct self audits. Have employee teams do audits on different areas of the workplace to review for hazardous conditions.
  • Recognize and reward the safety successes.

These types of activities will ensure a safety culture and ultimately improve the safety record of your organization.

Have you had a safety audit recently? Do you know which OSHA forms you are required to complete? A safe environment plays a key role in keeping a company Healthy, Safe and Secure. Strategic HR has the expertise you need to ensure your policies and practices are keeping your workers, and customers, safe. Visit our Health, Safety and Security page to learn more about how we can assist you.

How to Handle Bed Bugs at Work

HR Question:

An employee has indicated that she has bed bugs in her apartment building. How should we handle bed bugs at work? What responsibility do we have as an employer towards our other employees?

HR Answer:

The first step is to communicate with your employees measures that they can take to prevent exposure, or if exposure has occurred, minimize the risk that the bed bugs will be transported to work. Under the OSHA general duty standard, an employer has an obligation to provide a safe work environment free of hazards that may cause physical harm. If it is determined that there are bed bugs in your workplace, you should take immediate action to eradicate the infestation (typically by calling an exterminator). There may also be obligations of notification and recordkeeping if hazardous chemicals are used to rectify the situation. If an employee has indicated that he or she has been exposed, you can request that the employee stay home until the problem has been taken care of on their end. Keep in mind, an exempt employee may be required to be paid for time away from work that is less than a full day.

Every situation should be taken on its own merit. In addition to OSHA, there are a number of different issues that should be considered: Family and Medical Leave (if the employee has been exposed and needs to deal with the exposure), Workers’ Compensation (if the employee is exposed at work), and the Fair Labor Standards Act (determining if you have to pay for time missed from work). We do recommend consulting with an attorney before any adverse action is taken resulting from bed bug exposure.

You may find additional information on the Centers for Disease Control and Prevention website.

Strategic HR understands your concerns with the well-being of your employees. We offer expertise in health, safety, and security to cover any need you may have from analyzing your safety programs to making sure you are OSHA compliant to proactively ensuring employee wellness. Please visit our Health, Safety & Security page for more information on any of these services.