Resuming Work and Business Operations in Shanghai (Updated to May 31, 2022)

After two-months of city-wide lockdown, the reported daily COVID-19 cases in Shanghai is decreasing steadily, and the Shanghai government has put various measures in place to guide its citizens to exit the lockdown gradually. It is expected that from June 1 to the end of June, Shanghai will reopen its business fully.

During the last few days of May, the government cancelled various restrictions and conditions that apply to resuming business operations. In this article, we will summarize the governmental policies on work and business resumption that has been published so far and discuss necessary preparation work for companies to resume work and business operations.

On May 29, the Shanghai government unveiled its Shanghai Action Plan to Accelerate Recovery and Revitalization of the Economy (Action Plan), including 50 measures and covering eight areas. In particular, the Action Plan proposed to eliminate unreasonable restrictions on enterprises' resumption of work, production and business. Under the Action Plan, from June 1, the requirement to be on the whitelist and apply for government approval to resume business will be lifted. On the same day, the Shanghai government also eased the requirements for nucleic acid test reports to enter public venues and to take public transportation. The test results will be valid for 72 hours from June 1, versus 48 hours previously.

On May 30, the Shanghai government issued the Announcement on Citywide Resumption of Access to and from Residential Communities, Operations of Public Transport and Motor Vehicle Traffic from June 1. Starting from 00:00 on June 1, residents outside of medium and high-risk areas and closed and controlled areas enter and leave their compounds; public transportation including bus and rail transport will resume basic operations and private cars are allowed to go back onto the roads.

However, currently there is still some confusion in the implementation of the above relief measures at the microlevel, ie, whether all the previous restrictions imposed on companies during the lockdown are lifted. It’s likely that subdistrict administration and commercial property management offices are still contemplating the required process and detailed documentation required for businesses to resume work in June. Meanwhile, companies may refer to the third edition of Guidelines for Epidemic Prevention and Control for Industrial Enterprises in Shanghai (Guidelines), which no longer requires the requirement of closed-loop management as in the previous editions. We set out some key points of the Guidelines below.  

Site and office management

Employers are required to manage its workplace in classified zones and areas. For instance, employers should divide the site and office into different separated areas and among the different areas, such as the entrances, meeting rooms, canteens, dormitories, restrooms, waste disposal spaces and public spaces, differentiated management measures should be implemented, minimizing the personnel flow and contact in different zones and areas.

Employers also have responsibility to carry out cleaning and disinfection operations, either by themselves or through a third party service provider, to ensure the resumption of work is carried out in a safe manner.

Last but not least, safe distancing measures such as advocacy of video and telephone conferences and avoidance of large personal meetings, are highly encouraged.

Personnel management

• Personnel register: An employer is required to register all personnel in the workplace, including its employees (both full-time and part-time), dispatched workers, secondees, interns and other personnel who enter the workplace for temporary purposes, etc., and make sure all the personnel follow the pandemic control and work safety measures.
• Pandemic control measures: Employers are required to maintainhigh-frequency health screenings and post the venue code or install digital sentry in the office areas. There are requirements for nucleic acid tests and antigen self-tests for the on-site staff but the actual implementation could vary among the different locations. A designated person should compile the daily health status of all personnel. If an employee is found having common symptoms of COVID-19, such as fever, dry cough and fatigue, the employee should be placed in temporary isolation spaces. Employers should also have adequate reserves of pandemic prevention materials, including antigen self-test kits, protective masks, clothing and glasses, disinfectant alcohol, hand sanitizers, infrared and thermal-imaging thermometers and disposable medical gloves.
• Security trainings and EAP programs: Employers are advised to conduct security training for the onsite workforce and provide EAP programs to ensure the physical and mental health of employees.

There are other requirements that an employer should be aware of such as the formulation of a contingency plan and management of logistics which we will not elaborate on in this article. Bearing in mind that the Guidelines merely serve as the general guidance on the municipal level, employers should consult the local districts or subdistricts for further clarification and instruction of how local businesses can resume work and production as well as some sector-specific guidelines.

With the government easing the strict measures, we would recommend employers to kick off the preparation process of resuming the work and business in advance.