OSHA Guidance on Preparing Workplaces for COVID-19

On April 3, 2020 the Occupational Health and Safety Administration (OSHA) released the “Guidance on Preparing Workplaces for COVID-19” (Guidance) in order to help employers and workers identifying risks and appropriate controls to address any COVID-19 work related issues. This Guidance is not a standard nor a regulation, however it gives very useful preventing and protection measures to implement against SARS-CoV-2 (the virus that causes COVID-19) and can assist employers to comply with the OSHA General Duty Clause, a “catch-all” standard that requires any employers to provide their employees with a workplace free from any recognized hazard (like COVID-19) likely to cause death or serious physical harm. The Guidance is a “live” document, since it can be updated as new data and information on COVID-19 become available. The Guidance provides the following information and recommendations:

1. How a COVID-19 outbreak could affect workplace

As a result of the COVID19 outbreak (which can be an extended event in absence of a vaccine), workplaces can experience may experience:

  • Absenteeism. Workers can be sick or need to take care of sick family members, etc..
    • Change in pattern of commerce. Consumers may change spending patterns
    • Interrupted supply/deliveries.

2. Steps that all employees can take to reduce workers’ risk of exposure to SARS-CoV-2

The following steps can be taken by any employer to reduce exposure to SARS-COV-2 in their workplace:

  • Develop an infectious disease preparedness and response program. This plan shall address the level of risk related to job tasks and working environment, and consider where, how, and what sources of SARS-CoV-2 employees can be exposed to, in order to implement control measures to address those risks.
  • Prepare to implement basic infection prevention measures. Protecting workers shall be achieved through good hygiene and infection control practices, such as frequent and thorough hand washing, respiratory etiquette, flexible worksites and work hours and discourage workers from using other workers’ desks, offices or any equipment.
  • Develop policies and procedure for prompt identification and isolation of sick people, if appropriate. Employersshould also inform and encourage employees to self monitoring for sign and symptoms of COVID-19.
  • Develop, implement and communicate about workplaces flexibilities and protections. Employers should actively encourage sick employees to stay home and maintain flexible policies to allow so, and provide adequate training education and informational material about safety, health but also pay, leave and other issue that may arise.
  • Implement Workplace controls. Complying the “hierarchy of controls”, employers, when hazards cannot be removed, (as substitution in this case is not feasible), should implement the following control measures to COVID-19:
    • Engineering Controls, such as high-efficiency filters, increasing ventilation, installing physical barrier,
    • Administrative Controls/Work Safe Practices, such as encouraging sick workers to stay home, implementing telework (when feasible) and alternated shifts, develop emergency communications plans and provide up-to-date training, provide appropriate cleaning/disinfecting resources.
    • Personal Protective Equipment. Normally engineering and administrative controls are considered more effective, PPE are needed to protect (but also prevent in this case) from exposure to SARS-CoV-2. PPE includes: gloves, goggles, face shields, respiratory protection. During the COVID-19 outbreak, recommendation for PPE may change depending on tasks and jobs performed. For respiratory protection, however, NIOSH recommends the use of a of N95 mask minimum or, if not available, other respirators providing better protection.

3. Classifying worker exposure to SARS-CoV-2

To help employers determine appropriate precautions, OSHA divides jobs into 4 risk exposure levels as follows:

A. Very high exposure risk. Healthcare workers performing aerosol generating procedures, laboratory personnel collecting/handling specimens from known or suspected COVID-19 patients, morgue workers performing autopsies.

B. High exposure risk. Healthcare delivery and support staff and medical transport workers exposed known or suspected COVID-19 patients, morgue workers preparing bodies of people who are known or suspected to have COVID-19 at the time of their death.

C. Medium exposure risk. Workers requiring frequent and/or close contact with (i.e., within 6 feet of) people who may be infected with SARS-CoV-2, but who are not known or suspected COVID-19 patients. In areas without ongoing community transmission, workers in this risk group may have frequent contact with travelers who may return from international locations with widespread COVID-19 transmission. with the general public.

D. Low exposure risk (caution). Jobs that do not require contact with people known to be, or suspected of being, infected with SARS-CoV-2 nor frequent close contact with (i.e., within 6 feet of) the general public. Workers in this category have minimal occupational contact with the public and other coworkers.

For each level OSHA has determined specific control measures (e.g. combination of controls as discussed above). OSHA believes that most American workers will likely fall in the lower exposure risk (caution) or medium exposure risk levels.

Walden works closely with all our clients in order to keep them inform of all health and safety regulatory compliances and continuously seeking updates on COVID-19 environmental, health and safety regulations and recommendations as well as on all other EH&S topics. If you have any questions about this OSHA Guidance and all specific recommendations contained therein, please contact Walden Environmental Engineering for a free consultation.

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