OSHA Guidance: Coronavirus Disease (COVID-19) Risk Advisory

March 20, 2020

The following is an overview of OSHA’s approach to Coronavirus Disease (COVID-19).

COVID-19 has presented the world with its first pandemic known to be caused by the emergence of a new coronavirus. The World Health Organization declared COVID-19 a pandemic on March 11, 2020, and employers have looked for guidance as this new virus spread on a global scale due to the global economy and lack of pre-existing immunity.

OSHA (Occupational Safety and Health Administration) the CDC (Centers for Disease Control), NIOSH (National Institute for Occupational Safety and Health) among others have answered the call and provided resources to mitigate COVID-19 risks to employees and impact to businesses. The following is an overview of those resources and the currently accepted best practices.

Pandemic Planning

First and foremost, OSHA recommends developing a pandemic plan to reduce the impact of a virus outbreak on businesses, workers, customers, and the public. Businesses with formalized influenza plans are ahead of the curve and can quickly adapt those plans to address the COVID-19 virus. Employers who have yet to develop a plan will still benefit from the process and should prepare themselves and their employees in advance if conditions should become more severe.

The plan should begin with an assessment to determine the level of risk associated with their business processes, employees, and job duties that may place their workers in contact with the virus. Although there are no COVID-19 specific federal OSHA guidelines, the OSHA and CDC websites provide guidance for employers to conduct assessments and develop pandemic plans.

California-based companies in the healthcare sector have California’s state-run OSHA program to thank for keeping them ahead of the curve by developing a virus prevention standard for healthcare workers. This standard can be adapted and used as a framework and resource for all types of employers. The pandemic plan should identify the means of controlling the virus to protect the employees, the business, and the community.

The control methodology should follow the standard hierarchy of controls and require engineering controls to be implemented first, administrative controls second, and work practice controls such as personal protective equipment (PPE) last. Control measures will vary based on the environment and will often be a combination of different measures.

Control Measures

The following list provides some example control measures which may be applicable to your organization:

  • Engineering controls such as installing high-efficiency air filters, increasing ventilation rates, or installing physical barriers, such as clear plastic sneeze guards.
  • Implementing basic infection control measures: hand washing, require sick workers to stay home, encourage employees to cover their coughs/sneezes, routine cleaning and disinfecting.
  • Increasing social distancing by staggering breaks/lunches, encouraging employees to work from home, creating flexible work hours, creating additional shifts, or increasing the physical distance between employees.
  • Developing policies and procedures for prompt identification and isolation of sick people.
  • Training employees to recognize the signs, symptoms of the virus and precautions they should take to prevent infection. Prompt reporting of any potential infection will help slow the spread of the virus.
  • Identifying an isolation area for infected/potentially infected individuals within the worksite or home, to limit contact with other workers or family members.
  • Discontinuing non-essential travel.
  • Providing resources and a work environment promoting personal hygiene: tissues, no-touch trash cans, hand soap, alcohol-based hand rubs containing at least 60 percent alcohol, disinfectants, and disposable towels for workers to clean their work surfaces.
  • Using personal protective equipment such as gloves, goggles, face shields, face masks, and respiratory protection, when appropriate and in accordance with OSHA PPE and respiratory protection standards.

This list is a sample of what may be done to prevent the spread of COVID-19 within your organization. Please see OSHA’s Guidance Document on Preparing Workplaces for COVID-19 (#OSHA 3990-03) or CDC’s COVID-19 webpage for additional information and detailed guidance for developing your pandemic plan.

COVID-19 Specific OSHA Regulatory FAQ

Is there a federal OSHA standard that specifically addresses COVID-19?

There is no specific OSHA standard covering COVID-19. However, some other OSHA regulations may apply to help prevent occupational exposure to COVID-19. The three most relevant standards are the Personal Protective Equipment (PPE) standard (in general industry, 29 CFR 1910 Subpart I), the Respiratory Protection standard (29 CFR 1910.134) and the General Duty Clause, Section 5(a)(1) which requires employers to furnish to each worker “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.”

Is COVID-19 considered a bloodborne pathogen in accordance with OSHA’s BBP standard?

OSHA’s Bloodborne Pathogens standard (29 CFR 1910.1030) applies to occupational exposure to human blood and other potentially infectious materials. Although this standard does not include respiratory secretions that may transmit COVID-19 it can provide a framework that may help control some sources of the virus.

Can I use California OSHA’s Aerosol Transmissible Disease Standard if I am not in the state of California?

The California Division of Occupational Safety and Health (Cal/OSHA) has developed a standard that protects workers from illnesses from infectious diseases. The Aerosol Transmissible Diseases (ATD) standard is aimed at preventing worker illness from infectious diseases that can be transmitted by inhaling air that contains viruses (including COVID-19), bacteria or other disease-causing organisms. While the Cal/OSHA ATD standard is only mandatory for certain healthcare employers in California, it can be used in any state and may provide useful guidance for protecting other workers exposed to COVID-19.

Are COVID-19 cases considered recordable illnesses in accordance with OSHA’s Recordkeeping Standard?

OSHA has provided specific guidance regarding the recording of COVID-19 cases on OSHA 300 logs. COVID-19 can be a recordable illness if a worker is infected as a result of performing their work-related duties. However, employers are only responsible for recording cases of COVID-19 if all of the following are met:

  • The case is a confirmed case of COVID-19 (see CDC information on persons under investigation and presumptive positive and laboratory-confirmed cases of COVID-19).
  • The case is work-related, as defined by 29 CFR 1904.5.
  • The case involves one or more of the general recording criteria set forth in 29 CFR 1904.7 (e.g., medical treatment beyond first aid, days away from work).

Additional Links

As new information about the virus, its transmission, and impacts, becomes available additional guidance and risk management techniques may be needed. The CDC and OSHA COVID-19 webpages offer a wealth of valuable information and guidance to help employers mitigate the risk associated with the virus.

Should you have any questions or needs relative to planning for the potential impact of COVID-19, please contact us direct:

Adam Thomas
Senior Casualty Loss Control Consultant

Jim Hedrick
Director Risk Management & Client Experience


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