Many workplaces across the United States are currently being impacted by the effects of the coronavirus (COVID-19) pandemic and are ill-equipped to deal with the complexity of these type of events outside the healthcare setting. Considering this continually changing event, this article will filter through the massive amount of information and focus on answering three key questions employers and safety professionals may have concerning this outbreak. (To ensure common terminology in this article, COVID-19 is a respiratory disease caused by the SARS-CoV-2 virus and different sources and expert guidance compiled in this article may refer to each interchangeably).
- What is the employer’s responsibility during a pandemic?
- How do I keep my workers safe?
- Where can I find relevant COVID-19 information for the workplace?
What is the employer’s responsibility during a pandemic?
Just like previous epidemics and pandemics in years past, there are no specific OSHA standards covering COVID-19 or other airborne pathogens as there are for other potentially infectious material, such as blood and bodily fluids. However, some OSHA requirements pertaining to occupational exposure to COVID-19 may apply to workplace settings. All employers should be reminded that OSHA’s General Duty clause expects employers to ensure each worker has “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.”
The types of PPE required during a COVID-19 outbreak will be based on the risk of being infected with SARS-CoV-2 while working and job tasks that may lead to exposure. OSHA's Personal Protective Equipment (PPE) standards require using gloves, eye and face protection, and respiratory protection during the treatment of certain patients. Workers, including those who work within six feet of patients known to be, or suspected of being, infected with SARS-CoV-2 and those performing aerosol-generating procedures need to use respirators. When respirators are necessary to protect workers, employers must implement a comprehensive respiratory protection program in accordance with the Respiratory Protection standard (29 CFR 1910.134). This includes fit-testing, training, and medical exams.
OSHA recently issued temporary guidance related to enforcement of respirator annual fit-testing requirements for healthcare providers we will discuss later.
Recording workplace exposures to COVID-19
The Center of Disease Control (CDC) has significant guidance based on numerous variables that simply cannot be covered here with regards to recording workplace exposures to COVID-19 . A link to the CDC risk assessment of potential exposures is included below, with many additional available resources.
OSHA recordkeeping regulations mandate employers record certain work-related injuries and illnesses on their OSHA 300 log. COVID-19 isn’t automatically a recordable illness, but can be 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; and
- 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).
How do I keep my workers safe?
OSHA recently released a “Guidance on Preparing Workplaces for COVID-19” publication 3990-03 2020. This document serves as a best practices guide for nearly all workplace classifications concerning COVID-19. OSHA has classified job tasks of probable worker exposure to COVID-19 into four occupational risk exposure levels: Very high, high, medium, and lower risk. OSHA very clearly states most American workers will likely fall in the lower (caution) or medium exposure risk levels. Though each risk group has recommended guidance, all employer risk groups should at a minimum follow the guidance on page seven, “Steps All Employers Can Take to Reduce Workers’ Risk of Exposure to SARS-CoV-2,” which includes:
- Develop an Infectious Disease Preparedness and Response Plan
- Prepare to Implement Basic Infection Prevention Measures
- Develop Policies and Procedures for Prompt Identification and Isolation of Sick People
- Develop, Implement, and Communicate about Workplace Flexibilities and Protections
- Implement Workplace Controls
If your facility has trained medical responders, EMTs, occupational health professionals, or a combination of such, there are essential protective measures to consider to ensure the safety of these personnel, as well as all other persons at your workplace. The CDC refers to Healthcare professionals (HCP) as all paid and unpaid persons serving in healthcare settings who have the potential for direct or indirect exposure to patients or infectious materials, including:
- Body substances
- Contaminated medical supplies, devices, and equipment
- Contaminated environmental surfaces
- Contaminated air
Where can I find relevant COVID-19 information for the workplace?
Training is the essential foundation for educating the workplace population on how to identify and prevent workplace hazards, including reducing exposure risk to the SARS-CoV-2 virus. Several national training institutions offer training courses that meet OSHA’s 1910.1030 bloodborne pathogens standard training requirement, which may apply to your workplace in some circumstances. Even though these courses may be primarily for infection control of blood and/or other potentially infectious material, some training providers, such as the National Safety Council, also include a lesson specifically on airborne pathogens. If you are like most facilities where there are visitor restrictions in place indefinitely, online courses are available and only take about an hour to complete. Just make sure it includes a specific airborne pathogen training module to fully educate your workers on the hazards we all are currently facing.
Here is a list of resources to better assist those of you still in the workplace setting.
- OSHA-approved State Plans may have standards, regulations, and enforcement policies that are different from, but at least as effective as, OSHA’s. Check with your individual state plan, as applicable, for more information.
- OSHA Publication “Guidance on Preparing Workplaces for COVID-19”: https://www.osha.gov/Publications/OSHA3990.pdf
- OSHA COVID-19 Website: https://www.osha.gov/SLTC/covid-19/standards.html
- OSHA’s Temporary Guidance on Respiratory Protection: https://www.osha.gov/memos/2020-03-14/temporary-enforcement-guidance-healthcare-respiratory-protection-annual-fit
- CDC/ NIOSH guidance for optimizing respirator supplies: www.cdc.gov/coronavirus/2019-ncov/hcp/respirators-strategy
- OSHA’s Respiratory Protection standard, 29 CFR 1910.134: https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=12716&p_table=STANDARDS
- Interim US Guidance for Risk Assessment and Public Health Management of Persons with Potential Coronavirus Disease 2019 (COVID-19) Exposures: https://www.cdc.gov/coronavirus/2019-ncov/php/risk-assessment.html
J. TRAVIS CARRICATO retired from Columbia (S.C.) Fire Department as an operations division chief after 25 years of service. An accomplished speaker and instructor, he has provided various emergency response training programs domestically and internationally, including Saudi Arabia, China, Kuwait, and the Russian Federation. Carricato now operates this training mission full-time as principal owner of E-Med Training Services, LLC and BrigadeIQ.com, specializing in emergency response program training and compliance solutions for the industrial sector.