OSHA Guidance on COVID-19

OSHA recently released Guidance on Preparing Workplaces for COVID 19 (OSHA 3990-03).  The guidance helps facilities better navigate steps to reduce the risk of exposure and classify jobs as lower exposure risk (caution), medium exposure risk, and high or very high exposure risk.  In what is most certainly an unprecedented time for your facility, EHS workers need to understand how to protect the health and safety of their workforce and how to lead their teams through new and uncertain times.  

What is COVID-19?

Coronavirus Disease 19 (COVID-19) is a respiratory disease that is caused by the SARS-CoV-2 virus.  It has spread throughout the world and is impacting our daily lives including trade, travel, tourism, food supplies, financial markets and, of course, health and safety in the workplace. 

Approaches to Planning and Response

OSHA recommends that employers who have already planned for influenza pandemics update their plans to address the specific exposure risks, sources of exposure, routes of transmission and other unique characteristics of SARS-CoV-2 compared to pandemic influenza viruses. For employers who have not prepared for pandemic events, employers should prepare themselves and their workforce as far in advance as possible in order to avoid a lack of continuity planning and cascading failures due to insufficient resources or ill prepared workers. 

When developing an Infectious Disease Preparedness and Response Plan, some key items to consider include:

• Monitor federal, state, local, tribal and/or territorial health agencies recommendations. 
• Follow these recommendations regarding development of contingency plans for things such as increased rates or worker absenteeism or need for sick-leave, the need for social distancing, staggered work shifts, downsizing operations, delivery, work-from-home or other exposure-reducing measures. 
• Be prepared for declarations that may cause your business to need to cease operations for workers who have contact with the public or each other due to shelter-in-place orders (this is especially critical for businesses who operate in a non-essential capacity). 
• Define and classify the risk.
• What are the symptoms?
• Symptoms of COVID-19 can be mild to severe and typically include fever, cough, and shortness of breath.  Some people infected with the virus report other non-respiratory symptoms.  Others, meanwhile, have experienced no symptoms or are asymptomatic.  Symptoms may appear in as few as 2 days or up to 14 days after exposure according to the CDC. 
• What are the sources?
• The first human cases of COVID-19 likely resulted from infected animals, however, the virus is currently spreading person-to-person.  
• What are the routes of transmission?
• Primary - Between people who are in close proximity to one another (within about 6 feet). 
• Primary - Through respiratory droplets produced when an infected person sneezes or coughs.  
• Secondary - Through contact with a surface or object that has SARS-CoV-2 on it if the person then touches their own mouth, nose, or possibly tier eyes. 
• Where, how and to what sources of COVID-19 might workers be exposed?
• Consider the general public, customers, coworkers, sick individuals, non-occupational risk factors at home and in community settings, and workers' individual risk factors. 
• What controls are necessary to address these risks?  These will be specific to each workplace and environment.  Some questions to consider are: 
• What PPE can be used to mitigate the risk?
• What administrative controls can be employed to mitigate the risk?
• What engineering controls can be employed to mitigate the risk?
• What work practice controls (or procedures) can be implemented to mitigate the risk?
• Train workers
• All workers should be trained on the symptoms, sources, routes of transmission and exposure risks associated with COVID-19 as well as your company's response plan and procedures related to mitigating exposure and risk.  Additionally, workers should be trained on the proper use of PPE and workplace hygiene practices to ensure the safety of your workforce. 
• Prepare for workplace impacts 
• Some of the impacts identified in the OSHA report include:
• Absenteeism
• Change in patterns of commerce
• Interrupted supply/delivery
• Follow the General Tips for Infection Prevention 
• Promote frequent hand washing with soap and water.  
• Encourage workers to stay at home if they are not feeling well.
• Encourage respiratory etiquette (such as covering coughs and sneezes). 
• Provide staff, customers and the public with tissues and trash receptacles. 
• Discourage workers from using other workers' phones, desks, etc. whenever possible. 
• Maintain housekeeping practices including disinfecting surfaces.  
• OSHA Recommends: "Employers should consult information on Environmental Protection Agency (EPA)-approved disinfectant labels with claims against emerging viral pathogens.  Products with EPA-approved emerging viral pathogens claims are expected to be effective against SARS-CoV-2 based on data for harder to kill viruses."
• Develop Policies and Procedures for the Prompt Identification and Isolation of Sick People (If Appropriate) 
• Develop, Implement, and Communicate About Workplace Flexibilities and Protections 
• Ensure that employees know its ok to stay home if they are sick. 
• Ensure that sick leave policies are flexible and consistent with public health guidance and that they have been communicated to all employees. 
• Discuss the important of sick employees staying home with contract or staffing companies. 
• Recognize that employees may need to stay at home to care for sick family members and maintain flexible policies to accommodate this. 
• Be mindful of workers' concerns about pay, leave, safety, health and other issues that may arise during the COVID-19 outbreak. 
• Work with insurance companies and state agencies to provide information about medical care to employees. 
• Offer remote work or work-from-home flexibility (if possible for your business). 
• Implement Workplace Controls
• Workplace controls will vary greatly by business.  A few examples are included below:
• Engineering Controls - Examples: Installing high efficiency air filters, increasing ventilation, installing sneeze guards or drive-through windows. 
• Administrative Controls - Examples: Encouraging sick workers to stay at home, minimizing contact, establishing alternative work schedules or offering work-from-home flexibilities, discontinuing non-essential travel. 
• Safe Work Practices - Examples: Requiring regular hand washing, posting hand washing signs in restrooms, establishing a cleaning/sanitation schedule. 
• Personal Protective Equipment (PPE) - Examples: Face masks, gloves, respirators. 
• Note that per OSHA regulations, all PPE must be:
• Selected based upon the hazard to the worker. 
• Properly fitted and periodically retrofitted, as applicable.
• Consistently and properly worn when required. 
• Regularly inspected, maintained, and replaced as necessary. 
• Properly removed, cleaned, and stored or disposed of, as applicable, to avoid contamination of self, others, or the environment.   
• Follow existing OSHA standards. 
• Classify Worker Exposure 
• To help employers determine appropriate precautions, OSHA has divided job tasks into four risk exposure levels: Very High, High, Medium and Lower risk. The OSHA guidance provides specific information on how to protect workers in each exposure classification including suggested administrative controls, engineering controls, safe work practices, and personal protective equipment. 
• Very High Exposure Risk - Healthcare workers performing aerosol-generating procedures on known or suspected COVID-19 patients, healthcare or laboratory personnel collecting or handling specimens from known or suspected COVID-19 patients, morgue workers performing autopsies on the bodies of people who are known to have, or suspected of having COVID-19 at the time of their death. 
• High Exposure Risk - Healthcare delivery and support staff exposed to known or suspected COVID-19 patients, medical transport workers moving known or suspected COVID-19 patients in enclosed vehicles, mortuary workers involved in preparing the bodies of people who are known to have, or suspected of having COVID-19 at the time of their death. 
• Medium Exposure Risk - Include jobs that require frequent and/or close contact (within 6 feet) with people who may be infected with COVID-19 but who are not known or suspected COVID-19 patients.  According to OSHA, in areas without ongoing community transmission, workers in this risk group may have frequent contact with travelers who may return from international locations iwth widespread COVID-19 transmission.  In areas where there is ongoing community transmission, workers in this category may have contact with the general public. 
• Lower Exposure Risk - Include jobs that do not require contact with people known to be, or suspected of being, infected with COVID-19 nor frequent contact with (within 6 feet) the general public. 

 


In closing, OSHA's Guidance on Preparing Workplaces for COVID-19 provides essential guidelines for better responding to the current pandemic that we are experiencing.  In a time that is both unknown and stressful to your workforce, bring clarity, organization and order to your business by implementing and communicating an Infectious Disease Preparedness and Response Plan and policies that protect worker health and safety.  The COVID-19 outbreak has caught many of us off-guard, however, now is the perfect time to test your existing plan and make improvements or formalize a plan to be better prepared and ensure business continuity during the ongoing COVID-19 pandemic.




To read the full report, see https://www.osha.gov/Publications/OSHA3990.pdf




For more information:

Occupational Safety and Health Administration: www.osha.gov

Centers for Disease Control and Prevention: www.cdc.gov

National Institute for Occupational Safety and Health: www.cdc.gov/niosh