In the last few days, uncertainty has increased among companies in India that want to resume business operations because they have been classified as offering essential goods or services or are preparing for the “post-lockdown” period. The reason for this is a passage in an order issued by the Indian Ministry of Home Affairs (MHA) that if an employee falls ill with Covid-19, the employer and the directors there could possibly be held personally liable. Indian newspapers are now running horror scenarios about possible prison sentences for managers.
We personally interpret this passage to mean that it is primarily addressed to those companies/directors who do not care about the welfare of their own staff and, while approving of any health risk, allow employees to return to work unprotected and hastily.
Labour Protection under Covid19 Conditions
Therefore, we recommend that your company develops a detailed concept for the concrete implementation of the hygiene & clearance rules as well as the technical control measures for your sites in India. In our estimation, documentation that you have carefully addressed the issue of “Labour Protection under Covid19 Conditions” and, if necessary, consulted a qualified expert is essential. It may not be sufficient to assign the task to your management alone if there is a risk that essential measures will be missed due to lack of knowledge.
Organisational and technical measures
The measures will include not only instructions on how to operate, but also organisational and technical measures. Some examples: if necessary, building alterations in the office or on the premises, specific configurations of air conditions, temperature measurement of the entire staff, systematic disinfection, information material in local languages, etc.
We have already been approached by several companies who asked us for recommendations for the development of feasible solutions at their own Indian location. Therefore, in the last few days we have been thinking about a “Second-Party-Audit-Solution” with access to competent local experts from technical as well as hygiene-specific areas, covering all locations in India.
Objectives from our point of view would be:
- Determination of conformity of your measures with the official requirements (as a minimum “basic step”),
- If required: Support in the development and documentation of individual measures according to the “Best Practice” principle
- In case of need: Support in identifying technically feasible solutions, such as continuous fever measurement via digitally documented thermography systems.
Mr. Volker Klosowski, who has been supporting Asian companies and governmental institutions (e.g. Taiwanese customs at Taipei international airport) on several occasions since 2009 during pandemics (including bird flu), has the professional expertise for such coordination. He has helped to plan and implement appropriate organizational concepts and technical instruments.