Inspectors are implementing unannounced spot inspections to ensure employers are managing the COVID-19 risks relevant to their facility.
We hope our information can help strengthen your current pandemic response plans as part of your larger Emergency Preparedness efforts. We have based this information from our discussions with OSHA, the May 2020 OSHA’s Interim Guidance document, conversations with our clients who have experienced a COVID-19 OSHA Inspection and our Governor’s Healthy at Work contact notification.
Top on the list of what should be part of your Emergency Preparedness – Pandemic plan would be the following:
Written program with designated “infectious control” person & internal enforcement
Face Mask usage
Social distance communications
Hands washing communication & routine disinfection
Let’s explore some of these items
Written Pandemic or Infection Control Program
An infection control program does not have to be complicated, but it does need to be written. The program needs to list the person at your company who has been designated as the Coordinator, and should explain the rules that your company has implemented to minimize the spread of COVID-19; these may include health screenings, handwashing/sanitizer use, mask use, social distancing, and other controls. Without a plan/policy/program it is difficult to consistently communicate requirements to employees.
Designated Pandemic – Emergency Preparedness Coordinator An infection control coordinator is the person at your company who is responsible for making sure that control strategies to minimize the spread of COVID-19 have been implemented and are being actively used. This coordinator would be part of the rapid response team to help isolate an employee, contact trace, and assist the Health Department in the event an employee develops symptoms while at work or tests positive, as well as work with employees to maintain the requirements of the plan. The designated person may be anyone at your company who has been given the authority by management to implement, monitor, and enforce the control strategies. This person might be your safety coordinator, security manager, Human Resources, the company owner, or receptionist.
Correct Use of Face Masks
When you wear protective masks they must be worn correctly and must cover both the mouth and nose. You may wish to reference guidelines for acceptable types of masks that have been established by the CDC or other public health agencies. You will find that you will need to establish rules for when masks must be worn, and when it is ok to work without wearing a mask. As stated by OSHA; social distancing outside and single “lone” workers do not need to wear masks. Inside an office as a sole worker, would not need to wear a mask. Inside well-ventilated areas with social distancing, it is acceptable to remove the mask while stationary in this area. However, once you are in the workspace of another, inside or outside, universal masks must be worn. Many employers have established rules requiring mask use at all times except when eating. Some employers allow masks to be removed when employees are in areas that are socially distanced from other employees.
Adequate Social Distancing Employees need to maintain adequate social distancing as recommended by the CDC of at least 6 feet. If it is difficult to maintain social distancing in the workplace, then engineering controls such as plexiglass shields or increased ventilation may need to be used. Administrative controls such as changing work hours or staggering break times may also help accommodate social distancing between employees. As always, if engineering and administrative controls cannot be adequately implemented, personal protection – in this case cloth masks –must be worn (depending on the work, other PPE may also be required). Health Screenings The current health status of each employee in the workplace should be screened on a daily basis. At a minimum, the screening should include the “Four Questions”
Have you experienced COVID-19 symptoms?
Does anyone in your household have COVID-19?
Have you been in contact with anyone showing COVID-19 symptoms?
Have you traveled out of the state?
Contactless temperature monitoring should be completed before the employee enters the workspace. It is best if you have a designated person in the workplace to take and document employee temperatures.
We know this is a tough and crazy time for all of our friends and clients. We hope that our “Planning for a New Tomorrow” informational series will help ease the daily ESH work everyone is doing. Let us know if we can help develop your pandemic plan or infectious control program, audit current control policies, or set-up a time to Partner in Safety!
Thanks for your time. Stay Safe! Stay the Distance! Stay Well! #MaskUp #TeamKY #StaySafe #PartnerInSafety My Best, Sara Fineman President, ESH Consultant 1205 Center Drive | PO Box 1402 Murray, KY 42071 P: 270-753-6529