OSHA’s 11-Point Return-to-Work Guidance

OSHA’s 11-Point Return-to-Work Guidance

The Occupational Safety and Health Administration (OSHA) recently revised its guidance for protecting workers during COVID-19 to reflect current health considerations, vaccine availability, and CDC recommendations. The updated guidance includes 11 points of advice to help employers stay OSHA compliant and protect their workforce and business operations.

Here, we discuss OSHA’s new guidance and offer a downloadable COVID Return-to-Work Checklist that includes the 11 points of advice and additional resources, including key points from previous OSHA COVID-19 recommendations.

The 11-Point Guidance

OSHA’s new COVID-19 guidance for employers can be found on the OSHA page, “Protecting Workers: Guidance on Mitigating and Preventing the Spread of COVID-19 in the Workplace.” This page was first published in January 2021 and offered 16 points of guidance to help employers develop workplace prevention programs. In June 2021, it was significantly updated and the 16-point guidance was replaced with new 11-point guidance.

The 11 points focus on how to comply with the General Duty Clause while resuming in-person operations. They emphasize on protecting unvaccinated and otherwise at-risk workers. This guidance is relevant and recommended for employers in all industries that aren’t covered by mandatory OSHA COVID-19 Emergency Temporary Standard.

The 11 points of OSHA’s guidance are as follows:

  1. Facilitate employees getting vaccinated.
  2. Instruct any workers who are infected, unvaccinated workers who have had close contact with someone who tested positive for SARS-CoV-2, and all workers with COVID-19 symptoms to stay home from work.
  3. Implement physical distancing in all communal work areas for unvaccinated and otherwise at-risk workers.
  4. Provide workers with face coverings or surgical masks, as appropriate, unless their work task requires a respirator or other PPE.
  5. Educate and train workers on your COVID-19 policies and procedures using accessible formats and in languages they understand. 
  6. Suggest or require that unvaccinated customers, visitors, or guests wear face coverings in public-facing workplaces such as retail establishments, and that all customers, visitors, or guests wear face coverings in public, indoor settings in areas of substantial or high transmission. 
  7. Maintain Ventilation Systems.
  8. Perform routine cleaning and disinfection.
  9. Record and report COVID-19 infections and deaths.
  10. Implement protections from retaliation and set up an anonymous process for workers to voice concerns about COVID-19-related hazards.
  11. Follow other mandatory OSHA standards.

To remain OSHA compliant and to facilitate workforce safety, consider those 11 elements and ensure that you regularly communicate updates, policies, and recommendations with your workers. Earlier OSHA guidance also recommends that you conduct COVID hazard assessments, identify limits to spread COVID at work, consider protections for high-risk workers, provide guidance on COVID screening and testing, and minimize the negative impacts of isolation and quarantine on workers.

Implementing OSHA Guidance

In order to implement this 11-point guidance, it’s important to first assess your workplace’s current policies. Once you identify any gaps or outdated information, you should then develop and disseminate any new guidance or requirements. This will likely include assessing COVID-related workplace hazards, researching local health and safety guidance (ex: capacity limits or mask-wearing requirements), soliciting employee feedback, and sharing comprehensive reopening guidance with all employees.

As you reopen, it may be useful to regularly review this 11-point guidance to ensure that you are remaining in compliance. For example, you should regularly confirm that there is an adequate supply of PPE, that ventilation systems are operating properly, and that physical distancing measures are in place. If you experience infections or illness in the workplace, it may be worth revisiting your cleaning procedures or reiterating your policies to your workforce. 

Here are some helpful additional resources:

Further COVID-19 Return-to-Work Resources

In addition to OSHA’s newest COVID-19 guidance, always consider OSHA standards and recommendations as well as information from the CDC and similar federal/state/local authorities, keep up to date with the current science on this evolving situation, and apply current best practices.

You may also want to consider how a mobile risk management platform can help you abide by OSHA guidelines and keep your workforce safe. Platforms like Vector LiveSafe offer features including a reliable Broadcast notification system, daily health surveys that employees can complete prior to work each day, a customizable resources section for relevant PDFs or URLs, and instant two-way communication functionality between employees and security team members.

To integrate OSHA’s 11-point guidance into your workplace COVID-19 prevention strategy, you may also be interested in our free COVID Return-to-Work Checklist. This checklist covers all 11 points of guidance and offers additional resources and guidance, including key points from OSHA’s earlier recommendations.

ALEXANDRA BRUNJES

Alexandra Brunjes has a B.S. in Neurobiology from Georgetown University in Washington, D.C. with minors in Creative Writing and French. She is a published journalist and experienced health and science writer. Her expertise includes risk intelligence, healthcare and neuroscience, and technology.

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