The following is an overview on 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.
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 means of controlling the virus to protect the employees, the business, and 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.
The following list provides some example control measures which may be applicable to your organization:
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.
Is there a federal OSHA standard which 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 which 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:
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.
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