QUESTION
We have followed many of the suggestions in your Business Continuity Checklist,
especially the parts that deal with the pandemic response. We purchased your
Business Continuity Plan.
The problem we now have relates not to the present but the future. Specifically, we are worried about the possibility of a second COVID-19 wave. Our compliance people are grappling with how to handle a second wave.
Our question is, what do we do now about preparing for the second wave of COVID-19?
The problem we now have relates not to the present but the future. Specifically, we are worried about the possibility of a second COVID-19 wave. Our compliance people are grappling with how to handle a second wave.
Our question is, what do we do now about preparing for the second wave of COVID-19?
ANSWER
I am grateful that you are using the Business Continuity Plan Checklist
and Workbook, Includes Pandemic Response. As you know, the Checklist is free and
provided as a courtesy to enable companies to manage business continuity. It
has a large section that deals specifically with pandemic responses in general
and the COVID-19 pandemic in particular. It also contains numerous resources
and references. We are the only compliance firm in the country that has
published such a helpful tool, which is now on Update # 7, consisting of 208
pages. You can download it HERE. Update # 8 will be published shortly.
Thank you for buying the Business Continuity Plan (“BCP”). Yesterday we
notified media and our subscribers about our Business Continuity and Pandemic
Response Plan, which we decided to offer at a deeply reduced rate to make it
affordable to most companies. Even still, how could companies afford not to buy
it, considering their very survival depends on business continuity? Waiting is
really not an option. Our BCP is extensive, detailed, and dynamic. And we even
provide a walkthrough of the document with one of our subject matter experts at
no additional fee. You can order it HERE.
For the first wave response, I have outlined operational issues as well as pandemic challenges. For some recent posts, go HERE, HERE, HERE, HERE, and HERE.
Your question is important. I do not want to be the bearer of bad
tidings, but the second wave could be worse than the first – and, realistically,
we are not out of the first. As I write, some states are seeing a record number
of hospitalizations, and a few are reaching maximum capacity in their ICU
units. Thousands are becoming infected every month. Currently, the
United States has 2.2 million confirmed cases; 16,500 are now critical;
and over 118,000 have died to date.[i]
There have been about 27 million tests done in a population of 330 million, or
only 8%, with 1.2 million active cases and over 931,000 recovering cases. There
is insufficient educating; insufficient testing; insufficient contact tracing;
insufficient wearing of masks; and insufficient social distancing.
Even if a person has no symptoms, that person can spread the disease. The
CDC estimates that 40% of transmissions happen before people feel sick.[ii]
I have seen studies that show upwards of 4-5 people can become infected by
contact with persons who did not think they had the disease. Whether testing is
done or not done, the infection rate is not changing. One has nothing to do
with the other. However, testing tells us the epidemiological factors involved
in the rapid geographic spread of the disease and the measures needed to
contain it. Not testing at a high rate is tantamount to denying the ever-increasing risk.
Surely, denying the presence of a catastrophic plague is the worst form
of response.
Over 40 million people have filed for initial unemployment. Everyone
wants the economy to improve, but, in the long run, it just can’t improve
without good hygiene being pervasively practiced.
Here’s a simple algorithm for
wearing a face mask for those people who think they don’t need to wear a face:
Wearing a face mask leads to less asymptomatic viral spread,
which leads to more of the economy opening sooner.
Delay the response; delay the revitalized economy.
We should be clear about what is meant by “asymptomatic spread.” The
asymptomatic spread is a condition where the transmission is by people who do
not have symptoms and will not get symptoms from their infection. But those
infected carriers could still get others infected. Also, there is “pre-symptomatic
spread.” The pre-symptomatic spread is a condition where the transmission is by
people who don’t look or feel sick but will eventually get symptoms later.
Obviously, they too can infect others without knowing it.
Pandemics usually occur in waves. Infections spike, peak, plateau, and
even recede – but the infection rebounds again later. This process may happen
several times. It is the pattern of the pandemics in 1918-1919 with Spanish flu,
1957-58 with the H2N2 virus, and 2009-2010 with the swine flu.
I have written previously that the second wave of a pandemic is often
worse than the first. I understand that people want to return to “normal,” but
that simply cannot happen at this time. The CDC predicts that there could be
upwards of 200,000 deaths caused by COVID-19 by the fourth quarter.[iii]
Given that Federal authorities have mostly left it to the states to effectuate
good hygiene orders, and many states maintain that they will not shut down a
second time – although some states never shut down at all in this first wave –
the reduction of infections and deaths seem as far away as ever. After all,
when a state runs out of ICU beds, it really has no other choice, ethically
speaking, but to shut down.
Yet a second wave is coming. And that means a second shut down is
possible. For instance, Japan has had to shut down geographical areas of
resurgence. Other countries have been shutting down, where resurgence has
occurred. There are now surging spikes in several states, and ICU units are
reaching capacity. Because COVID-19 has a lengthy incubation period, to wit, 3
to 14 days (with symptoms often appearing within 4-5 days after exposure), during
that first 72 hours, a person can transmit the virus to others.
Let’s view our current circumstances as being in the first wave, one
that has not ended, but reduced somewhat in parts of the country, plateaued in
other parts, and surging in other parts at an astonishing speed. Let’s also
assume that the second wave is coming in the fourth quarter 2020. Given that
situation, we can do two things: (1) maintain now as much good hygiene as
possible in our pandemic response to the first wave; and (2) prepare carefully for
the second wave.
So, what lessons have we learned thus far? And what should you do in
preparation for the second wave of the COVID-19 pandemic? I will outline the
action items you should be considering and implementing.
1. Preparation
Anticipate the continuation of first wave hygienic activities. Get a
sense of how your organization is responding to the current pandemic challenges
and how much time remains before the second wave hits.
2. Proactive
Do not let your organization become the victim of denial. Be proactive.
Determine the strengths and weaknesses of the current pandemic response. Refine
the actions taken and document them.
3. Business Continuity Plan
Be sure that you view the Business Continuity Plan as a dynamic
document that will change over time. It is not a fixed, unchanging set of
procedures, but will need to change in response to real-world challenges.
4. Communication - Internal
Maintain on-going communications between management and employees. Use
various media to communicate news, testing criteria, and revised guidelines. Be
sure to fact check and correct misinformed information provided by any sources
that are not credentialed scientists and doctors trained in relevant fields.
5. Communication – External
Synchronize internal (within the organization) and external (outside
the organization) news, procedures, announcements, and actions.
6. Absenteeism
Use these four criteria to minimize and monitor absentee employees: (1)
essential to report to the workplace; (2) essential but can work remotely; (3)
non-essential but can work remotely; and (4) non-essential and not necessary to
work remotely.
7. Crisis Management
Periodically assemble a crisis management team consisting of senior
management, department heads, business line leaders, and internal
administrative staff (i.e., HR, IT, legal, finance, compliance). Document the meetings
and discuss ways and means to stay current with challenges to business
continuity.
8. Geography
If the organization is multistate, geographic challenges present themselves.
Each remote branch office or regional vector should have a reporting chain to
senior management for business continuity and pandemic response concerns. The Business
Continuity Plan should take remote offices and regions into consideration.
9. Drills
Implement exercises to test various realistic scenarios. The COVID-19
virus is a “long tail” virus,[iv]
so doing scenario exercises will keep the organization in a state of readiness
and functioning in a safe environment.
10. Recovery
Be willing to transition to a more recovered
posture, if events allow for recovery. The recovery state is part of business
continuity, but not without pitfalls. Recovery does not just mean business-as-usual.
It means ensuring that the crisis may be past, though it is not a time to let
down your guard.
Some crises do cease to exist, and, to that extent, the organization
may still remain with periodic testing. However, some crises do not cease to
exist: only the current risk of them happening has been reduced. Pandemics are the
latter case. Do not be caught blind-sided by relaxing your pandemic response to
the point that you end up making the same mistakes in the next wave.
Jonathan Foxx, Ph.D., MBA
Chairman & Managing DirectorLenders Compliance Group
[i] As
of 6/19/20 at 7:33AM (EST) Coronavirus Resources Center, Dashboard, Johns Hopkins University and Medicine, See https://coronavirus.jhu.edu/map.html
[ii] COVID-19
Pandemic Planning Scenarios, https://www.cdc.gov/coronavirus/2019-ncov/hcp/planning-scenarios.html
[iii] US
could see 200,000 coronavirus deaths by September, Woods, Amanda, June 11,
2020, NY Post
[iv] A
“long tail risk” is one that, from a risk point of view, is “between the start
of the exposure and the manifestation of loss or damage resulting from the
exposure.” International Chamber of Commerce https://iccwbo.org/publication/long-tail-risks
