OSHA Legal Guidance for COVID-19 Return to the Workplace
APRIL 10, 2020 — Occupational Safety and Health Administration (OSHA) has issued guidance on preparing workplaces for COVID-19. It focuses on the need for employers to implement engineering, administrative, and work practice controls and personal protective equipment (PPE), as well as considerations for doing so.[1]
To reduce the impact of COVID-19 outbreak conditions on businesses, workers, customers, and the public, it is important for all employers to plan now for COVID-19.
Development of an Infectious Disease Preparedness and Response Plan
Develop an infectious disease preparedness and response plan that can help guide protective actions against COVID-19.
Stay abreast of guidance from federal, state, local, tribal, and/or territorial health agencies and consider how to incorporate those recommendations and resources into workplace-specific plans.
Plans should consider and address the level(s) of risk associated with various worksites and job tasks workers perform at those sites.
Such considerations may include the following:
Where, how, and to what sources of SARS-CoV-2 workers may be exposed
Nonoccupational risk factors at home and in community settings
Controls necessary to address those risks
Follow federal and state, local, tribal, and/or territorial (SLTT) recommendations regarding development of contingency plans for situations that may arise because of outbreaks.
Preparation to Implement Basic Infection Prevention Measures
For most employers, protecting workers depends on emphasizing basic infection prevention measures. As appropriate, all employers should implement good hygiene and infection control practices, including the following:
Development of Policies and Procedures for Prompt Identification and Isolation of Sick People, if Appropriate
Prompt identification and isolation of potentially infected individuals is a critical step in protecting workers, customers, visitors, and others at a worksite.
Employers should inform and encourage employees to self-monitor for signs and symptoms of COVID-19 if they suspect possible exposure.
Employers should develop policies and procedures for employees to report when they are sick or experiencing symptoms of COVID-19.
When appropriate, employers should develop policies and procedures for immediately isolating people who have signs and/or symptoms of COVID-19 and train workers to implement them. Move potentially infected people to a location away from workers, customers, and other visitors.
Take steps to limit spread of the respiratory secretions from a person who may have COVID-19.
If possible, isolate people suspected of having COVID-19 from those with confirmed infection to prevent further transmission.
Restrict the number of personnel entering isolation areas.
Protect workers in close contact with (ie, within 6 feet) a sick person or who have prolonged/repeated contact with such persons by using additional engineering and administrative controls, safe work practices, and PPE.
Development, Implementation, and Communication of Workplace Flexibilities and Protections
Actively encourage sick employees to stay home.
Ensure that sick leave policies are flexible and consistent with public health guidance and that employees are aware of these policies.
Talk with companies that provide your business with contract or temporary employees about the importance of sick employees staying home and encourage them to develop nonpunitive leave policies.
Do not require a healthcare provider’s note for employees who are sick with acute respiratory illness to validate their illness or to return to work, as healthcare provider offices and medical facilities may be extremely busy and not able to provide such documentation in a timely manner.
Maintain flexible policies that permit employees to stay home to care for a sick family member. Employers should be aware that more employees may need to stay at home to care for sick children or other sick family members than is usual.
Recognize that workers with ill family members may need to stay home to care for them. Be aware of workers’ concerns about pay, leave, safety, health, and other issues that may arise during infectious disease outbreaks. Provide adequate, usable, and appropriate training, education, and informational material about business-essential job functions and worker health and safety, including proper hygiene practices and the use of any workplace controls (including PPE).
Work with insurance companies (eg, those providing employee health benefits) and state and local health agencies to provide information to workers and customers about medical care in the event of a COVID-19 outbreak.
Implementation of Workplace Controls
During a COVID-19 outbreak, when it may not be possible to eliminate the hazard, the most effective protection measures are (listed from most effective to least effective) engineering controls, administrative controls, safe work practices (a type of administrative control), and PPE.
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Engineering controls
Engineering controls involve isolating employees from work-related hazards. In workplaces where they are appropriate, these types of controls reduce exposure to hazards without relying on worker behavior and can be the most cost-effective solution to implement. Engineering controls for SARS-CoV-2 include the following:
Administrative controls
Administrative controls require action by the worker or employer. Typically, administrative controls are changes in work policy or procedures to reduce or minimize exposure to a hazard.
Examples of administrative controls for SARS-CoV-2 include the following:
Safe work practices
Safe work practices are types of administrative controls that include procedures for safe and proper work used to reduce the duration, frequency, or intensity of exposure to a hazard. Examples of safe work practices for SARS-CoV-2 include the following:
Personal protective equipment (PPE)
While engineering and administrative controls are considered more effective in minimizing exposure to SARS-CoV-2, PPE may also be needed to prevent certain exposures. While correctly using PPE can help prevent some exposures, it should not take the place of other prevention strategies.
All types of PPE must meet the following requirements:
Employers are obligated to provide their workers with PPE needed to keep them safe while performing their jobs. The types of PPE required during a COVID-19 outbreak is based on the risk of being infected with SARS-CoV-2 while working and job tasks that may lead to exposure.
Workers, including those who work within 6 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. Considerations are as follows:
Promote frequent and thorough handwashing, including by providing workers, customers, and worksite visitors with a place to wash their hands. If soap and running water are not immediately available, provide alcohol-based hand rubs that contain at least 60% alcohol.
Encourage sick workers to stay home.
Encourage respiratory etiquette, including covering coughs and sneezes. Provide customers and the public with tissues and trash receptacles.
Employers should explore whether they can establish new policies and practices, such as flexible worksites (eg, telecommuting) and flexible work hours (eg, staggered shifts), to increase the physical distance among employees and between employees and others if local and state health authorities recommend the use of social-distancing strategies.
Discourage workers from sharing phones, desks, offices, or other work tools and equipment, when possible.
Maintain regular housekeeping practices, including routine cleaning and disinfecting of surfaces, equipment, and other elements of the work environment.
Installing high-efficiency air filters
Increasing ventilation rates in the work environment
Installing physical barriers, such as clear plastic sneeze guards
Installing a drive-through window for customer service
Specialized negative-pressure ventilation in some settings, such as for aerosol-generating procedures (eg, airborne infection isolation rooms in healthcare settings and specialized autopsy suites in mortuary settings)
Encouraging sick workers to stay at home
Minimizing contact among workers, clients, and customers by replacing face-to-face meetings with virtual communications and implementing telework, if feasible
Establishing alternating days or extra shifts that reduce the total number of employees in a facility at a given time, allowing them to maintain distance from one another while maintaining a full onsite work week
Discontinuing nonessential travel to locations with ongoing COVID-19 outbreaks
Developing emergency communications plans, including a forum for answering workers’ concerns and internet-based communications, if feasible
Providing workers with up-to-date education and training on COVID-19 risk factors and protective behaviors (eg, cough etiquette and care of PPE)
Training workers who need to use protecting clothing and equipment how to put it on, how to use/wear it, and how take it off correctly
Providing resources and a work environment that promotes personal hygiene
Requiring regular handwashing or using of alcohol-based hand rubs
Posting of handwashing signs in restrooms
Selected based on the hazard to the worker
Properly fitted and periodically refitted, as applicable (eg, respirators)
Consistently and properly worn, when required
Regularly inspected, maintained, and replaced, as necessary
Properly removed, cleaned, and stored or disposed of, as applicable, to avoid contamination of self, others, or the environment
National Institute for Occupational Safety and Health (NIOSH)-approved, N95 filtering facepiece respirators or better must be used in the context of a comprehensive, written respiratory protection program that includes fit-testing, training, and medical examinations.
When disposable N95 filtering facepiece respirators are unavailable, consider using other respirators that provide greater protection and improve worker comfort. Other types of acceptable respirators include a R/P95, N/R/P99, or N/R/P100 filtering facepiece respirator; an air-purifying elastomeric (eg, half-face or full-face) respirator with appropriate filters or cartridges; powered air purifying respirator (PAPR) with high-efficiency particulate arrestance (HEPA) filter; or supplied air respirator (SAR).
Consider using PAPRs or SARs, which are more protective than filtering facepiece respirators, for any work operations or procedures likely to generate aerosols (eg, cough-induction procedures, some dental procedures, invasive specimen collection, blowing out pipettes, shaking or vortexing tubes, filling a syringe, centrifugation).
Use a surgical N95 respirator when both respiratory protection and resistance to blood and body fluids is needed.
Face shields may also be worn on top of a respirator to prevent bulk contamination of the respirator. Certain respirator designs with forward protrusions (duckbill style) may be difficult to properly wear under a face shield. Ensure that the face shield does not prevent airflow through the respirator.
Consider factors such as function, fit, ability to decontaminate, disposal, and cost.
Respirator training should address selection, use (including donning and doffing), proper disposal or disinfection, inspection for damage, maintenance, and the limitations of respiratory protection equipment.
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