ClickSafety is joining the effort in communicating our industry knowledge to provide current information appropriate to assist in slowing the spread of the COVID-19 virus in the workplace. As the impacts of this pandemic continue to develop, sources of information are being shared constantly, every day and certainly the world of occupational health and safety is not immune.
In these uncertain times, organizations are scrambling to do what is necessary to follow federal, state, local, tribal, and/or territorial (SLTT) guidance and recommendations as well as implement best management practices to keep their employees (and families) healthy and safe. OSHA has taken steps to advise employers how to best manage the COVID-19 pandemic and prepare for others which may arise in the future. These recommendations include:
- Developing a comprehensive Infection and Disease Preparedness Program that plans for contingencies and addresses the following:
- Sources of worker exposure
- Completing employee risk assessments utilizing the four risk levels of the COVID-19 Occupational Risk Pyramid
- Implementing the Hierarchy of Controls
- Engineering Controls
- Increased ventilation
- Physical barriers
- Administrative Controls
- Employee Training
- Use of virtual communication
- Alternating days and shifts (to reduce worker population)
- Personal Protective Equipment
- Respirators (e.g. N95, other filtering face-piece types)
- Eye and Face protection (e.g. Face shields)
- Continuance of essential operations with increased absenteeism
- Engineering Controls
- Development of flexible business policies during pandemic emergencies
- Sick leave is consistent with public health guidance
- Halt requirement for “doctors notes” upon return to work
- Accommodate the need for employees to care for sick family members
- Providing adequate training regarding business practices, policies and workplace controls
- Working with insurance providers and health agencies to provide updated information and education about the pandemic
- Continued compliance with the OSHA General Duty Clause through providing every worker with “employment and a place of employment, which are free from recognized hazards that are causing or are likely to cause death or serious physical harm.”
In addition to issuing the Guidance on preparing workplaces for COVID-19, OSHA has also implemented a temporary enforcement halt on respiratory fit testing requirements and related enforcement specifically targeted at healthcare employees. This enforcement halt is in effect from March 14, 2020 until further notice. It reduces fit testing requirements from quantitative (machine measurement) to qualitative (relies on scent of smell or taste for detection) for N95 respirators. OSHA field offices also have the choice to refrain from citing an employer for violations of select fit testing requirements.
OSHA is also reminding employers that COVID-19 is not exempt from injury and illness reporting, as regulated under 29 CFR 1904 Subpart E. Employees who contract COVID-19 at work, must be recorded on OSHA Form 300 (Log of Work-related injuries and illnesses). While common colds and flu are generally exempt from recordkeeping requirements even if contracted at work, COVID-19 is not exempt and is classified as a recordable illness. For further information regarding determination of work-relatedness, OSHA guidance is found in 29 CFR 1904.5
As businesses across the nation begin to alter their way of doing business to minimize the spread of COVID-19, which includes construction projects in many SLTT jurisdictions, many in the business community are coming together and taking steps to protect those still in occupational settings which expose them to COVID-19 by donating materials including PPE such as N95 respirators.
As we are all aware, the COVID-19 pandemic is continuing to make an enormous impact on the United States. The unprecedented steps OSHA is making to assist employers in complying with regulatory requirements while balancing work tasks and keeping employees safe are significant. However, many organizations are finding themselves unprepared for the consequences of this pandemic on their operations and their employees. As a result, it is important for organizations to focus their efforts on current COVID-19 response efforts and to plan for the possibility of future pandemics by creating and implementing effective Infection and Disease Preparedness Programs which wouldn’t be complete without comprehensive worker training and education.
Our safety experts are monitoring developments closely and will provide information as we get it on the latest regulatory changes. We also have two new online courses to help your team navigate these challenging times.
- N-95 and Other Filtering Facepiece Respirators Awareness for All Industries
- Handwashing and Illness Prevention in the Workplace for All Industries
For additional information regarding the regulatory updates in response to COVID-19, including assigning appropriate worker training and suggestions for ways to navigate through this pandemic and help keep your employees safe, contact ClickSafety today.
Note: The views and opinions in this blog are those of the author and do not necessarily reflect the official policies or positions of OSHA, the CDC or other organizations. Statements in this blog do not comprise medical or legal advice and are subject to change, particularly with respect to evolving public health issues and related guidance. We advise all readers to carefully monitor developments and advice of OSHA, CDC, WHO, and other public health experts and officials.
Source: OSHA. Guidance on preparing workplaces for COVID-19, Guidance on preparing workplaces for COVID-19 (2020).
OSHA. (2020, March 14). DOL Issues Temporary Enforcement Guidance for Respiratory Fit Testing in the Healthcare Industry. Retrieved March 17, 2020, from https://www.osha.gov/news/newsreleases/national/03142020