Legal recommendations and Dubai regulations on how to test, treat, prevent and mitigate Covid-19 infections or effects

Considering  the  necessity  to  comply  with  on-going  regulations  and  clients’  anxiety  when attempting  to  gather  summarized  data,  we  put  together  a  short  brief  of  regulations  and guidance regarding good practices to adopt in case of Covid-19 infection or risk of infection for  individuals  and  companies  and  so  to  prevent  the  spread.  We  also  considered  further recommendations.  

I. Guideline for Employees in case of Infection or Risk of Infection (Dubai Health Authority)

If  an individual  shows  Covid-19  symptoms (coughing), he/she should self-quarantine and obtain a doctor’s opinion as to whether a test is necessary/recommended or not. 

A. Self-Quarantine 

  1. If  there  is  a  company  labour  camp  available,  quarantine  of  the  employee  should happen in a secured area that is set only for the purpose of the quarantine.  
  2.  If  there  is  no  company  labour  camp,  but  if  the  employee  has  his/her  own accommodation with an isolated room, the employee should isolate him/herself (the isolated room should have its own bathroom).  
  3. If  there  is  no  company  labour  camp  and  employee  has  no  accommodation  where he/she can isolate him/herself, the employee needs to contact DHA in order to get to a quarantine facility of DHA.  

B. Symptoms Check by a Doctor (prior testing)

Prior testing, any person who has mild symptoms (coughing, no fever, none of the symptoms described below)  should get an appointment at  any clinic/hospital  or, for a lower cost, at Doctor  for  Every  Citizen  Services  (with  one  of  the  doctor  at  given  date  and  time,  from  a public/governmental  clinic/hospital).  Appointment  at  Doctor  for  Every  Citizen  Services  is organized  either  via  DHA  Smart  App  or  by  calling  800342  or  by  booking  online www.dubaihealthbooking.com. If the doctor recommends testing, the person should follow the procedure for being tested. 

However, any person who has high symptoms (fever higher 38 degree, chills, muscle pain, runny  nose,  soar  throat,  cough,  shortness  of  breath,  nausea  or  vomiting,  headache  and abdominal pain), can book an appointment for testing immediately and go directly to private clinics or (if the private clinic refuse admission) to Al Badaa Medical Center or Al Khawaneej Medical Center. Ramadan Timing: 8:30am to 6:30pm. Last registration is at 5:30pm. Normal timing from 8am to 10pm. Last registration is at 9:30pm. Appointment is organized either via DHA Smart App or by calling 800342 or by booking online www.dubaihealthbooking.com. 

C. Testing

1. Appointment

In all cases, an appointment should be made. In Dubai, the appointment can be done through the  DHA  Smart  App  (to  be  downloaded)  or  by  calling  800342  or  by  booking  online www.dubaihealthbooking.com.  

2. Test centers

The normal Governmental facilities are at Al Nasser Club and Shabab Al Ali. For high symptom, Al Badaa Medical Center or Al Khawaneej Medical Center are opened. 
 
Drive Through Centers (under Abu Dhabi Health Authority) at Al Khawaneej and Mina Rashid are open.  

3. Costs

For any individual aged 60 or below 12, or who is pregnant, or who is qualified as people of determination or those who have chronic disease (hyper blood pressure, diabetes, chronic eczema,  any  serious  respiratory  disease,  arthrosis  rheumatism),  if  they  have  symptoms (normal coughing, no high temperature), the test is free of costs.   
Any person who has been referred by a public or private doctor can get tested for free. 
 Any other person shall pay the testing fees.  
 At the drive through centers, the testing fee is AED 370 plus administration fee (Call Center 8001717 for appointment). 

D. Treatment

In case an individual tested positive has high symptoms (fever higher 38 degree, chills, muscle pain, runny nose, sore throat, cough, shortness breath, nausea or vomiting, headache and abdominal pain) the person needs to go Al Quoz Fitness Center (all the expats, except GCC nationals)  where  the  person  may  be  sent  to  another  facility.  For  GCC  nationals  and  UAE nationals, they must go to Rashadiya Medical Center. All must go by themselves, in their own car; in they do not have their own car or cannot drive, they can call DHA, which will send transportation. Afterward,  the patient is  supposed to be  treated either in the facility or in another private or public clinic/hospital. 

E.  Further Recommendations.  
 
The situation is likely to further evolve. Hence, we recommend companies to regularly check updates from the UAE Government and from the municipality where they operate; thereafter, we  recommend  updating  employees  with  such  information  in  an  easy-to-read format. For companies who have labourers, we strongly recommend putting extra efforts so to make sure the health and safety regulations are well understood and executed. 

II. Guideline for Companies in case of Infection or Risk of Infection (Dubai Health Authority)

A.  Discharge of Employees and next Steps 
 
If the employee of a company has been tested positive and went through quarantine or went to the hospital, then, 14 days after quarantine or after hospital discharged, the employee shall perform a second test of Covid-19 prior discharge. For 48 hours after this test, the employee shall still self-quarantine. After this 48 hour period, a third test shall be done. If both tests are negative, the person can go back to normal life and the employer is not obliged to take special measure for this employee.  

If 2nd  test shows negative but the 3 rd  test shows positive, the person must stay in quarantine for 14 days. Same if 2nd  test shows positive. 

B.  Contact between Employees 

If an employee has been tested positive, all the other employees who have been in contacts with him/her have to self-quarantine themselves for 14 days. If they develop the symptoms, they shall call 800342 and give information about the patient with EID if possible. DHA will then advise what to do. 
 
If an employee has been in contact with somebody outside of work who was tested positive, the employee should self-quarantine. If symptoms same as above. 
 
If employee has symptoms, the employee must organize him/herself as per guideline shown above. 

C.  Further Recommendations 
 
Some of our clients with large warehouses were obliged and monitored by Dubai Health Authority to conduct special cleansing process after some of their employees had been tested positive. Hence, we recommend companies that have employees who tested positive  to contact Dubai Health Authority for specific guidance.  

III. Health and Safety Requirements for Re-opening (Dubai Municipality) 
 
The rules for health and public safety in Dubai varies from one sector to another and it would be  ineffective  to  summarize  them  or  confusing  to  try  finding  common  standards  or obligations.  
 
The list is thereby: https://www.dm.gov.ae/en/Business/HealthAndPublicSafety/Pages/default.aspx  
 
Here below is the content of one circular that relate to rules to comply with prior reopening of factories and manufacturing sector (which applies to offices, except items 10, 14 and 15): 

1.  Increase the frequency of cleaning and disinfection during operation and focus on the 
followings:  
•  Offices, information area and washrooms 
•  Doors and stairs handle 
•  Waiting chairs and tables 
•  Human working and manufacturing areas 
2.  Document all cleaning and disinfection operations including list of used disinfectants 
3.  Performing and intense cleaning and disinfection process during working hours and after working hours including all commons areas. 
4.  Availability of hand sanitizers at different areas  
5.  Staff and visitors should wear personal protective equipment such as gloves and face masks  during  duty  and  ensure  changing  them  frequently  to  prevent  cross-contamination 
6.  Measuring temperature of staff and visitors twice a day, one of them before entering the factory 
7.  All workers and those showing symptoms should not come to work 
8.  Provide instructions for maintaining 2 meters social distancing 
9.  Educate on all steps to take from entry exit in the factory in all languages. 
10. Sterilize  all  boxes  and  covering  materials  before  and  after  wrapping  and  before delivering good 
11. Identify  the  isolation  area  for  emergency  use  and  train  the  employees  about  the response procedures 
12. Train all staffs at manufacturing sector on Covid-19 and requirements and procedures to be followed 
13. Commitment to the allowed working hours 
14. Compliance with all precautionary measures for the manufactories labour camp 
15. Compliance  with  all  published  circulars  related  to  the  manufacturers  sectors  and labour camps and transport of labours. 

IV. Further Crisis Management Recommendations 
 
We recommend three main set of actions.  
 
All crisis management actions and protocols should be continued, including but not limited to the executive and multi-disciplinary weekly meetings and resulting actions plan, monitoring of the pandemics and Governments (country/regional/global) action plans and drawing of an associated business forecast, continuing the feasibility studies of the adjusted business plans and, when adopted, to implement them and document the implementation. 
 
On a management liability level, we recommend management team to document the actions that have been taken and/or that are planned to be taken in such a manner that reports can be submitted timely to the shareholders or subsidiary controlling teams. Various companies’ management have put  together mitigating actions plans  that may even  have proven to  be successful but may not have complied with corporate policies or decision making process, or that may not have been documented so to justify this action plan rather than another, with pros and cons thoroughly explained. 
 
On a (LLC) partner liability level, in most circumstances, the legal risks are quite limited or inexistent  unless  substantial  and disproportionate dividends have been distributed to partner(s)  after  the first Governmental measures restricting business were taken.  We recommend prior the distribution of any dividend to ensure  that all bankruptcy related regulations and laws are complied with.   

Date: 17 May 2020 
ASTRUC & CO. 
 
Disclaimer. This newsletter shall not be considered as legal advices and recipients should consult their legal advisors or the competent 
authorities in order to obtain complete and up to date information. The Dubai Health Authority related information was collected from 
Dubai Health Authority itself during various interviews conducted from 10 to 13 May 2020. 

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