COVID-19 infections in workplaces are continuing and as a result OSHA inspections have become a matter of ‘when’ not ‘if’ they happen.
OSHA requires businesses to provide a workplace free of hazards that are likely to cause death or serious harm. COVID-19 falls under this. If OSHA comes to inspect because you have experienced an outbreak, a hospitalization, or any media attention, they will want you to be able to explain your plans, policies, and procedures detailing what you are doing to protect the employees. To respond effectively, an employer needs to be able to tell OSHA a story on all that they are doing to keep the employees safe. One of the most effective methods of doing this is through an Exposure/Infection Control plan. These are written company procedures of what is being done to prevent infection and the response to infection. Not having a plan in place will open the business to liabilities, as OSHA will come down in full force and review everything the business is doing per OSHA standards.
A recommended starting point for developing an exposure/infection control plan is to assess the level of risk for your business. Here is OSHA’s general current exposure risk guide: https://www.osha.gov/Publications/OSHA3993.pdf. The next step would be to determine if there are cases previously or currently in the workplace (regardless of origin), as well as checking with Local County, City and/or State Health Department to review number of cases and deaths in the community surrounding the workplace. Johns Hopkins University & Medicine outlines current COVID-19 cases and statistics in the U.S. The map tool can be found here: https://coronavirus.jhu.edu/us-map. One can specify State and County on the top right of the map, just under the “Critical Trends” tab. Click on the map to bring up details for that county.
The exposure/infection control plan can vary significantly due to the level of risk analyzed above; however, they generally cover 4 areas:
- Infection prevention including building and workforce preparation, which PPE to provide, and access controls;
- Ensuring compliance by maintaining social distancing and cleaning, reducing touch points, and screening the workforce;
- Response to suspected and confirmed cases, reporting rules; and
- Communication for transparency, so everyone is on the same page while limiting confusion on what the business is doing to help protect its workforce.
The final steps are to implement mitigating measures for risks, as well as fail safes for those measures. A general review of the CDC’s guidance for small business’ to ready themselves for COVID-19 can be found here: https://www.cdc.gov/coronavirus/2019-ncov/downloads/guidance-small-business.pdf.
The CDC released an in-depth toolkit for workplace readiness that covers all variables to consider when opening and/or maintaining a safe workplace. This toolkit takes the form of an easy to follow checklist, and can be found here: https://www.cdc.gov/coronavirus/2019-ncov/downloads/community/Resuming-Business-Toolkit.pdf
Simply having a plan is not enough. Business must be implementing and living the plan. Doing this will demonstrate in the occurrence of an OSHA inspection that the business is handling and responding to COVID-19 in an effective and compliant manner. Unfortunately, StaffScapes cannot create this plan for you; however, we have gathered these resources and information together to assist in drafting an effective and compliant exposure control plan.