OSHA Training for Re-opening During COVID

As New York State continues its phased re-opening of the economy, companies are required to develop and implement a plan for safe re-opening, with an affirmation to the State that the plan will be followed. Companies must ensure they are following proper protocols during re-opening during the on-going COVID-19 pandemic, with an emphasis on employee and customer safety.  The re-opening template developed by the State for different company types such as offices, construction sites, restaurants, etc. is available on the New York Forward web page and focuses on exposure and ways to reduce transmission of the virus.  Refer to Walden’s other COVID related blogs for additional information on New York’s re-opening guidelines.

OSHA recently released its “Guidance on Returning to Work”, which contains one glaring difference from the State’s guidance: OSHA also calls for employee training to ensure worker safety regarding COVID-19.  Under OSHA’s General Duty Clause [Section 5(a) (1)], employers are required “to provide their employees with a workplace free from recognized hazards likely to cause death or serious physical harm”.  Thus, OSHA requires companies to ensure that their workers are not exposed to hazards or dangers in the work place.  COVID-19 represents a risk to employees; therefore, with regards to hazard assessment and training, simply following the NY Forward template may leave companies exposed to OSHA liability and potential enforcement actions.

A hazard assessment consists of the following factors, which require careful consideration when developing and implementing re-opening plans with a focus on workplace safety:

  • Collect existing information about workplace hazards
  • Inspect the workplace for safety hazards
  • Identify health hazards
  • Conduct incident investigations
  • Identify hazards associated with emergency and non-routine situations
  • Characterize the nature of identified hazards, identify interim control measures, and prioritize the hazards for control

The training aspect of the re-opening plan should focus on employee understanding of COVID-19 related risks, how to properly clean and sanitize work areas, how to properly wear a mask and other safety items, social distancing practices, etc.  The goal of the training should be to protect workers and prevent the spread of the virus in the workplace.  Training sessions covering COVID-specific topics need to be provided to all employees and documentation of such training sessions must be maintained in the company’s employee file.

Walden Can Help

Walden’s health and safety professionals can help you to develop a re-opening plan, implement the required procedures, perform a hazards assessment, and administer safety training to your employees.  For further information, please reach out to one of Walden’s experts today at 516-624-7200.

Thank you and stay safe.

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