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OSHA Provides Guidance for Employers on Preparing Workplaces for COVID-19

March 23, 2020Alerts

The U.S. Department of Labor, Occupational Safety and Health Administration (OSHA), has issued guidance for employers to reduce the impact of the COVID-19 virus on businesses, workers, customers and the public. Under the Occupational Safety and Health Act, employers are required to provide their employees with a workplace free from recognized hazards likely to cause death or serious physical harm.

Generally, OSHA recommends that employers review the risks that face their workers and implement plans to mitigate those risks where possible, including flexible work policies, implementing an infectious disease response plan, encouraging self-reporting of illness and requiring ill workers to remain home. Employers should also implement policies to share information regarding COVID-19 and available medical resources with workers.

OSHA recommends that all employers take the following steps to reduce their workers’ risk of exposure to COVID-19:

Develop an infectious disease preparedness and response plan.

Stay up-to-date on federal, state and local guidance. Consider how workers may be exposed to COVID-19, non-occupational risk factors and workers’ individual risk factors. Employers should develop contingency plans for increased worker absenteeism, the need for social distancing and streamlining essential operations.

Prepare to implement basic infection prevention measures.

Employers should consider implementing practices such as encouraging proper hygiene like handwashing, encouraging ill workers to stay home, considering flexible worksite or work hour policies, and discouraging sharing of phones, desks and equipment.

Develop policies and procedures for efficient identification and isolation of sick individuals.

Encourage workers to self-monitor for COVID-19 signs and symptoms. Ask workers to report when they are sick or experiencing COVID-19 symptoms and, where appropriate, implement procedures to isolate ill workers.

Develop, implement and inform workers of workplace flexibilities and protections.

Encourage sick workers to remain home and, where possible, implement policies that allow for flexibility in the workplace to allow workers to care for family members and themselves in the case of illness. Work with insurance companies and state and local agencies to provide information on medical care available to workers.

Implement workplace controls, specifically, engineering controls, administrative controls, and use of personal protective equipment (PPE).

The level of controls to be implemented depends on the level of the workers’ risk of exposure, but may include the following:

Low Risk (workers who do not have frequent contact with the general public)
Employers should monitor public health communications and work with employees to designate an effective means of communicating that information. No additional engineering controls or PPE controls, beyond those regularly employed, are necessary.

Medium Risk (workers with ongoing community contact such as high-volume retail in areas experiencing ongoing community transmission)
Where possible, install physical barriers such as sneeze guards, consider offering face masks to ill employees and customers, ask sick customers to minimize contact, limit customer and public access, consider strategies to limit face-to-face contact, and communicate the availability of medical screening for workers (e.g., on-site nurse; telemedicine services). PPE for workers should be chosen based on work task and consideration of function, fit, availability, decontamination ability, disposal, and cost.

High Risk and Very High Risk (workers, such as those in the healthcare industries, with high potential exposure to known or suspected sources of COVID-19)
Ensure that the proper air-handling systems are installed, designate isolation rooms, and take special precautions as appropriate. Healthcare facilities should follow existing guidelines and develop policies to reduce exposure, consider offering enhanced medical monitoring of employees, and provide job specific training. Provide hand sanitizer and necessary PPE, which may include gloves, gowns, face shields, goggles, and a face mask or respirator.

As always, employers should continue to follow existing OSHA standards. Although there is no COVID-19 specific standard, existing OSHA standards that may apply or provide a framework for employers to prevent exposure include:

  • OSHA’s PPE standards, requiring use of gloves, eye and face protection, and respiratory protection.
  • The OSH Act general duty clause, requiring employers to provide workers “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.”
  • OSHA’s bloodborne pathogens standard.

Download the full text of the guidance.

The OSHA COVID-19 webpage provides additional information specifically for workers and employers.