For employers still working to manage COVID-19 in the workplace, the Occupational Safety and Health Administration (OSHA) has provided some guidelines to help strengthen your policies and procedures. The guidance, Protecting Workers: Guidance on Mitigating and Preventing the Spread of COVID-19 in the Workplace, reiterates that employers should implement a COVID-19 Prevention Program. If you are creating a COVID-19 prevention program, or beefing up the one you have, OSHA suggests you include these key elements:
1. Make A Plan: As OSHA notes, the most effective programs will engage workers and their representatives in both the development and implementation of the program. If you don't have one already, assign a workplace coordinator, who is responsible for COVID-19 issues.
Also, once you have a plan in place, train workers on COVID-19 policies and procedures, including an effective communication system (for both reporting and notifying workers of exposures). Further, provide guidance on screening and testing. Your plan also needs to protect workers from retaliation. To that end, do not distinguish between workers who are vaccinated and those who are not.
Of course, make sure you stay on top of recording and reporting COVID-19 infections and deaths. See our previous alert. Finally, don't forget to consider application of other OSHA standards
2. Identify Exposure Points and Limit Spread: Identify where and how workers might be exposed to COVID-19 at work. Identify specific measures to limit the spread of COVID-19 in the workplace, such as isolating and sending home infected or potentially infected employees, physical distancing, physical barriers, face coverings or other personal protective equipment (PPE), improving ventilation, encouraging good hygiene, and routine cleaning and disinfecting. Note that these decisions should be in line with the hierarchy of controls: engineering controls, administrative policies, and PPE.
Be sure to instruct infected or potentially infected workers to stay home. Moreover, perform enhanced cleaning and disinfecting when infected or potentially infected persons have been in the facility. Also, consider additional protections for higher risk workers. If possible, make the vaccine available at no cost to employees.
In all decisions, minimize the negative impact of quarantine or isolation on workers. For instance, where possible, allow telework or work in an isolated area, or allow use of paid sick leave.
As a reminder, OSHA also suggests implementing the following key measures for limiting the spread of COVID-19 in the workplace:
- Eliminate the hazard by separating and sending home infected or potentially infected people.
- Implement physical distancing in all communal work areas.
- Install barriers where physical distancing cannot be maintained.
- Require the use of face coverings.
- Improve ventilation, where possible.
- Use other PPE when necessary.
- Provide the supplies necessary for good hygiene.
- Perform routine cleaning and disinfection.
Please contact Sharonda Fancher or Ashley Strittmatter for assistance.