www.calodging.com May/June 2020 11 performing similar jobs. Further, hotels should be mindful of the effect that adjusting exempt salaries will have on their exempt status and consider when and how to return exempt workers who were reclassified to non- exempt to their prior exempt status. SBA Loan Concerns. Finally, hotels will need to analyze the impact of recalling workers using loan proceeds obtained through the federal government or other government benefits. Ensuring a Safe Place Workplace Safety and Operational Considerations Hotels must take a multi-faceted approach to safety that takes into consideration both employee and guest safety. Below are some of the key safety measures hotels should consider: Taking employee temperatures upon arrival to work. Physical distancing between guests and/or employees. Installing touchless hand sanitizer dispensers at key guest and employee entrances and high contact areas. Front and back of house signage containing health and hygiene reminders. Instruction and training to employees about correct hygiene and frequent handwashing with soap. Training on appropriate PPE, such as masks and gloves, for employees based on their role and responsibilities in adherence to California and local guidelines. Training for all employees on COVID-19 safety and sanitation protocols with more comprehensive training for teams with more frequent guest contact, such as housekeeping, food and beverage, and hotel operations and security. Increase frequency of cleaning and sanitizing in all public spaces with an emphasis on surfaces with frequent contact, such as check-in counters, bell desks, elevators, door handles, room keys and locks, ATMs, stair handrails, dining surfaces and seating areas, and public bathrooms. Wash all bedding and laundry in accordance with CDC guidelines. Use EPA-approved disinfectants to clean guest rooms with a focus toward high-touch items, such as remote controls, toilet seats and handles, door and furniture handles, water faucet handles, nightstands, telephones, and alarm clocks. Don’t Forget Your Families First Coronavirus Response Act (FFCRA) Obligations Paid Sick Leave (EPSL) and Emergency FMLA (EFMLA) Hotels hiring/recalling workers must be mindful of eligibility requirements and obligations to provide workers with EPSL and EFMLA as the FFCRA remains in effect through December 31, 2020. This obligation to provide emergency leave does not end simply because the curve has flattened, and businesses have re-opened. Further, hotels must be mindful of how the EPSL and EFMLA interact with the California Family Rights Act as well as California and local paid sick leave laws. Post-COVID-19 HR Compliance Considerations With a new post-COVID-19 world comes new compliance considerations, including an updated handbook with policies addressing the FFCRA as well as changes to timekeeping, travel policies, attendance, bonuses, furlough, reinstatement of pay, and accommodations, as well as training on any new or modified policies. Hotels should also ensure they display the required FFCRA posters Additional Resources The issues above are by no means an exhaustive list. Please contact Fisher Phillips for more information about return-to-work resources, including a detailed back-to- business checklist.