On Safety: A look at OSHA’s National Emphasis Program on COVID-19

As part of the risk assessment, facilities should:

• Determine whether there are or were infections in the facility (doesn’t matter where they originated). If there are infections, ascertain whether there are any clusters in the facility.
• Check with the city, county and/or state health departments to look at the number of cases as well as the number of deaths in your city or county. This will help in determining the general risk in the community. Finally, check with the city, county and state health departments to see what they are recommending for businesses in your area.

If you have contractors onsite, look at their plans and programs to ensure their program is compliant with your program and procedures.

Once the risk assessment has been completed and the level of risk determined, develop an ECP based on the risk level. For example, low-risk establishments may include physical distancing, medical questionnaire, employee training, setting up of barriers, personal protective equipment and so forth. Again, the scope of the ECP depends on the risk level. Look at OSHA’s tuberculosis directive for guidance. Although it focuses on five industries in which the risk of TB exposure is high based on CDC guidelines, it provides some solid guidance.

In developing an ECP, refer to a joint CDC and OSHA guidance document for manufacturing workers and employers that was issued in May. Regardless of the scope of the risk level, determine which of the following points should be included in the program:

1. Assessing the potential exposure and level of exposure risk to employees based on their work and occupation, as well as activities for communicable and infectious agents that are present or can reasonably be anticipated to be present
2. Assigning a coordinator for overseeing the ECP
3. Onsite screening (temperature checks and questionnaires)
4. Developing precautions based on the level of risk – use of the Hierarchy of Controls (engineering, work practice and PPE controls)
5. Identification and isolation of any infected individuals
6. Safe distancing
7. Housekeeping and sanitation
8. Address testing for COVID-19 and vaccinations
9. Management of health care workers’ risks of exposure to infected persons, including post-exposure prophylaxis
10. Work restrictions for exposed or infected health care personnel
11. Highlighting and referencing existing OSHA standards, including:
    1. Bloodborne Pathogens (1910.1030)
    2. Respiratory Protection (1910.134)
    3. PPE (1910.132)
    4. Housekeeping and Warning Signs (1910.141)
    5. Specification for Accident Prevention Signs and Tags (1910.145)
    6. The General Duty Clause
12. Procedures to provide information and training to managers and employees about potential or actual occupational exposure to communicable and infectious agents and the elements of the ECP
13. Procedures for reporting an incident
14. Medical surveillance procedures to identify suspected or confirmed cases of a communicable or infectious disease and a plan to isolate or transfer individuals
15. Recordkeeping and recording on illness

Depending on the level of risk at the worksite, some or all of these provisions will need to be in place to avoid a General Duty Clause citation from OSHA. You should also periodically review CDC and OSHA guidelines for any additional recommendations.