COVID-19: How to reconcile business continuity and worker protection?

Having a Business Continuity Plan (BCP) would have enabled many companies to cope much better with the crisis linked to the COVID-19.

Indeed, the Business Continuity Plan (BCP) makes it possible to anticipate problems likely the disorganisation of the company's usual organisation and the adjustments to be made to deal with them.

Faced with the 5th wave, the resumption of the epidemic and in order to limit the risk of exposure of employees to COVID-19, the French Ministry of Labour updated on 30 December 2021 the national protocol for ensuring the health and safety of employees in companies. This protocol is essential for companies which have a health and social obligation to protect their employees as well as their external public (customers, service providers, partners, etc.).

This new version of the protocol is applicable from 3 January 2022.

The main changes in the revised protocol concern the reinforcement of the respect of barrier measures and the wearing of masks (general public filtration higher than 90% or surgical masks) in all enclosed collective places and the use of remote work when it is possible, for a minimum of 3 days per week, for jobs that allow it.

These measures must be combined with hygiene measures, barrier measures, cleaning, ventilation and airing of premises, implementation of a prevention policy and management of the flow of people.

Companies are thus forced to reorganise their activities.

A new risk assessment must be included in the Single Occupational Risk Assessment Document (DUERP) and the Business Continuity Plan (BCP) must be updated.

Single Occupational Risk Assessment Document (DUERP)

The Single Occupational Risk Assessment Document is compulsory in all companies as soon as the first employee is hired and is part of the company's general obligation to ensure the safety and protect the health of its employees. It must list the occupational risks incurred by workers and the resulting prevention and protection measures.

The steps involved in preparing the DUERP include the following:

  • Preparation of the risk assessment
  • Identification of risks
  • Risk analysis
  • Risk assessment
  • Proposal of prevention actions

How to initiate the risk management process?

  • Define the problem and/or the risk issue, including relevant assumptions identifying the risk potential
  • Gather background information and/or data on the potential hazard, damage or impact on human health
  • Identify a responsible person and allocate the necessary resources
  • Specify the timeline, deliverables and level of decision making appropriate to the potential risk management process

The Single Occupational Risk Assessment Document must be updated in the following cases:

  • At least once a year
  • At the time of any decision to modify working conditions or affecting the health or safety of employees
  • When additional information relevant to the assessment of a risk in a work unit is encountered (e.g. pandemic due to COVID-19)

Business Continuity Plan (BCP)

This plan consists of listing all the measures aimed at ensuring, according to various crisis scenarios, the maintenance of the company's essential activity while preserving the health and safety of employees.

Points to consider in a Business Continuity Plan :

  • Identification of possible disturbances.
  • Setting up a crisis unit
  • Evaluation of the impact of the event on the activity
  • Identification of the measures to be put in place
  • Activation of the Business Continuity Plan
  • Restoration of the affected system
  • Operations to resume activity
  • Procedures for returning to a normal situation and closing the business continuity plan

The Business Continuity Plan implemented must be validated by tests and exercises and updated according to the results obtained. These exercises should ensure that the BCP meets the requirements of the company's business. It is useful to share the new BCP procedures with employees. It can also be attached to the Single Occupational Risk Assessment Document.

Sources :

  • Service
  • Code de la Santé Publique (France Health Code)
  • Bonnes Pratiques de Fabrication (GMP)
  • CH Q9 (Quality risk management)