Last week, Massachusetts Governor, Charlie Baker announced a four-phase reopening strategy for the Commonwealth. Each of the four phases (called “Start,” “Cautious,” “Vigilant,” and “New Normal”) will see gradual reopening of additional industries with lessening restrictions as warranted by data on testing, new cases, and deaths attributable to COVID-19.

Today, details of the “Start” phase were released.  The first industries allowed to reopen will be manufacturing, construction, and places of worship, which can resume operations immediately, with restrictions.  Industry-specific safety standards for each of these three industries have been released.  These are in addition to the safety standards applicable to all employers, which were announced last week.  Beginning on May 25, hair salons and barbershops will be allowed to reopen, and “non-essential” retailers will be able to offer curbside pickup.  Office buildings outside Boston will be able to reopen at 25% capacity, while offices in the city will not be allowed to reopen until June 1.

The safety standards for manufacturing businesses require employers to reengineer workstations to maximize distance between employees and to install physical partitions separating work areas that cannot be spaced out.  All employees must wear face coverings and practice social distancing.  Lunch breaks should be staggered, and cafeterias may only offer packaged food.  Enhanced hygiene and cleaning practices are required.  Employers must provide training to employees about procedures and encourage employees who are sick or vulnerable to COVID-19 to stay home.  Employers must also log all employees and visitors to their facilities in order to facilitate contact tracing.

The safety standards for the construction industry recommend social distancing of at least six feet between work crews.  Where social distancing is not possible, employers must provide workers with PPE including face coverings, gloves, and eye protection.  Enhanced hygiene and cleaning procedures are mandated.  Prior to each shift, employees will need to self-certify that they do not have a temperature in excess 100.3 degrees, that they have not been in close contact with anyone diagnosed with COVID-19, and that they have not be directed to self-isolate.  Contractors must designate a COVID-19 Officer who will be responsible for certifying on a daily basis that requirements are being followed.

The safety standards for places of worship limit gatherings to no more than 40% of building capacity.  Participants who do not reside together must keep at least six feet apart, and all participants must wear face coverings while in the building.  Pre- and post-worship gatherings, like coffee hours, are prohibited, but food pantries may continue to operate.  Child care may not be offered.  Enhanced hygiene and cleaning procedures are mandated.

All employers will need to prepare a COVID-19 Control Plan (the government has provided a Control Plan template that employers may use in preparing their own plans), and all employers must self-certify that they are in compliance (a sample Compliance Attestation Poster has been provided).

The Governor indicated that the “Start” phase will last approximately three weeks, depending upon the data.  A listing of industry sectors expected to be opened in the subsequent phases was also released today.