Complying with OSHA’s 16-Point COVID-19 Guidance

Complying with OSHA’s 16-Point COVID-19 Guidance

On January 29, 2021, OSHA published guidance to help organizations establish COVID-19 prevention programs, mitigate the spread of the virus, and protect employees and business operations. This 16-point guidance is an important reference point for companies seeking to reopen their workplaces and avoid infractions. For more information, watch the webcast of Vector's recent webinar, 16 Steps to a COVID-19 Prevention Plan at Work.

Here, we provide an overview of the topics covered in the OSHA guidance, discuss systems and technology solutions that can help organizations with their prevention strategies, and offer a downloadable COVID Return-to-Work Checklist to help you prepare for a safe and healthy return to work.

1. Assign a workplace coordinator for COVID issues

The workplace coordinator should administer the COVID-19 prevention program on the employer’s behalf and serve as the main point of contact for any questions or concerns that workers may have. It’s important that all employees can easily access the coordinator’s contact information.

Once you choose a COVID-19 workplace coordinator, you'll want to communicate this to your workforce. Many two-way safety and security risk communication platforms, like Vector LiveSafe, feature broadcast message functionality that can be used to inform all employees of the coordinator's role description and contact information. This information can also be posted to Vector LiveSafe's configurable Resources section within the mobile app for employees to easily access, with or without an internet connection.

2. Identify where and how workers might get exposed to COVID at work

OSHA recommends that employers conduct a thorough hazard assessment to identify how and where employees might be exposed to COVID-19 on the job. This assessment will be most effective if workers are able to provide report concerns, as they are often most familiar with the conditions and potential hazards they face in the workplace.

With the Vector LiveSafe Mobile App, employees can submit tips about COVID-related hazards in the workplace, such as coworkers congregating without masks. This helps organizational leadership identify how the workforce may be exposed and develop appropriate prevention and response strategies.

When assessing workplace risk, it's important to consider risk exposure levels. OSHA classifies job tasks into four potential risk exposure levels: very high, high, medium, and lower, depending in part on the following factors:

  • the physical environment of the workplace;
  • the type of work activity;
  • the health status of the worker;
  • the ability of workers to wear face coverings and abide by CDC guidelines;
  • and the need for the worker to come into close contact with other people, including those known to have or suspected of having COVID-19, and those who may be infected with—and able to spread—COVID-19 without knowing it.

If you aren’t familiar with the process of assessing workplace hazards, one of the best ways to do so is through conducting a job safety analysis (JSA), also commonly known as a job hazard analysis (JHA). According to OSHA, a JSA is “a technique that focuses on job tasks as a way to identify hazards before they occur.” This enables you to break a job down into the tasks it involves and then to identify hazards associated with each task.

If you need help getting started, consider this article about how to conduct a JSA and use a risk matrix to evaluate COVID-19 occupational exposure risksWhether this is your first introduction to JSAs, or they’re already an important component of your safety program, there are tools that can help you to streamline your COVID-19 job hazard evaluations.

In addition, Vector EHS Management software allows organizations to easily create JSA checklists to assess employees’ exposure risks to COVID-19, identify controls, and share JHAs with key team members for review and approval in order to establish and improve best practices. Vector EHS Management’s robust reporting tools allow EHS managers to dig deeper into JHA analytics to view close-out rates and track COVID-19 hazards by source, department, area, and more.

3. Identify a combination of measures to help control the spread of COVID using the hierarchy of controls

Once you have identified a hazard (or hazards) at work, usually through a job hazard analysis, you then use the hierarchy of controls as a framework when considering how to implement controls that mitigate the risk of the identified hazards.

The hazard controls are listed in order of their effectiveness. First, and most effective, is elimination. If this isn’t possible or feasible, then you continue down the list to substitution, then engineering controls, then administrative controls, and then finally personal protective equipment.

Once you have identified COVID-related risks and appropriate response policies using the hierarchy of controls, Vector LiveSafe's Broadcast and Resources offerings can be used to communicate them. Vector LMS and & Training Management can also be used to educate employees on COVID-related safety measures.

4. Consider adding protections for high-risk workers using supportive policies and practices

Older adults and people of any age who have serious underlying medical conditions are at higher risk for severe illness from COVID-19. Workers with disabilities may be legally entitled to "reasonable accommodations" that protect them from the risk of contracting COVID-19.

Where feasible, employers should consider reasonable modifications for workers identified as high-risk who can do some or all of their work at home (part or full-time), or in less densely occupied, better-ventilated alternate facilities or offices. Better workplace ventilation is one option that could be considered for employees who have heart or lung vulnerabilities.

When you are developing policies for high-risk workers it's important to get employee feedback. Communication solutions like LiveSafe's Tip Submit tool help employees share their policy recommendations. Once policies have been developed, you can upload information and guidance into the customizable LiveSafe Resources for easy access by employees.

5. Establish a system for communicating effectively with workers about COVID-19 issues in a language the workers can understand

Ask workers to report, without fear of reprisal, COVID-19 symptoms, possible COVID-19 exposures, and possible COVID-19 hazards at the workplace. Employers should communicate to workers, in clear and accessible language, all policies and procedures implemented for responding to sick and exposed workers in the workplace.

In addition, OSHA states that a best practice is to adopt and test two-way communication systems that workers can use to self-report illness and exposure, and that employers can use to notify workers of exposures and resulting operational changes.

There are many solutions that can help employers to effectively communicate with their workers. Vector Solutions’ industry-leading LiveSafe offering is one. With intuitive broadcast messaging, two-way chat, and anonymous tip reporting, LiveSafe makes it easy to identify and address health and safety threats before they escalate.

Additionally, the Vector Solutions Coronavirus Resource Center offers several complimentary COVID-19 courses and Convergence Training offers extensive online training for workers in a variety of industries.

6. Educate and train workers about COVID-19 and your workplaces procedures and policies related to COVID-19 mitigation and control

To facilitate COVID-19 mitigation and control, employers should provide workers with:

  • Basic facts about COVID-19, including how it is spread and the importance of physical distancing, use of face coverings, and hand hygiene;
  • Workplace policies and procedures that have been implemented to protect workers from COVID-19 hazards;
  • Reinforcement of employees’ rights to a safe and healthful work environment, whom to contact with questions or concerns about workplace safety and health, and their right to raise workplace safety and health concerns free of retaliation.

It's most effective to inform your workforce using a variety of communication methods. This could include a combination of workplace posters and signage, emails, text messages, verbal communication, and more.

Organizations should also have a means of tracking which workers have been informed and when. For example, if you communicate your COVID-19 policies in your weekly safety meeting, you can have everyone sign a log to confirm they have heard and understand what they learned in the meeting.

If your organization utilizes online training courses and a learning management system (LMS), you can easily deliver and document your COVID-19 employee training. If you use the Vector LiveSafe platform, you can include workplace safety and quarantine policies in the configurable Resources section. Employees can also use LiveSafe Emergency Options to communicate with emergency services and find nearby health resources on the Resources section Safety Map.

Vector Solutions also offers comprehensive, complimentary online COVID-19 training and CDC-based resources for families, employers and employees, businesses, caregivers, first responders, and cleaning and disinfection crews.

7. Instruct workers who are sick, potentially sick, exposed, or potentially exposed to isolate/quarantine

Ensure that your absence policies are non-punitive. Policies that encourage workers to come to work sick or when they have been exposed to COVID-19 are disfavored.

Isolation and quarantine policies can be included in LiveSafe Resources and frequently communicated using LiveSafe Broadcast functionality. Health and safety locations near your organization can also be added to the LiveSafe Safety Map for easy access.

8. Implement policies, procedures, and other actions to support workers who are isolating/quarantining

When possible, allow employees to telework, or work in an area isolated from others. If those are not possible, allow workers to use paid sick leave, if available, or consider implementing paid leave policies to reduce risk for everyone at the workplace.

Employers can use LiveSafe to share mental health resources and organizational points of contact. The LiveSafe platform can also be used to engage in two-way conversations with employees who may be struggling.

9. Isolate workers who show symptoms at work

Workers who appear to have symptoms upon arrival at work or who develop symptoms during their work shift should immediately be separated from other workers, customers, and visitors, sent home, and encouraged to seek medical attention.

Organizations can use LiveSafe to communicate policies for workplace isolation.

10. Implement enhanced cleaning and disinfecting procedures if people who are confirmed positive or suspected positive enter your facility

OSHA advises that employers follow the CDC’s Guidance for Cleaning and Disinfecting to develop, implement, and maintain a plan to perform regular cleanings to reduce the risk of exposure to COVID-19.

This guidance recommends that organizations:

  • Routinely clean all frequently touched surfaces in the workplace, such as workstations, keyboards, telephones, handrails, and doorknobs with products that are EPA-approved for use against the virus that causes COVID-19.
  • Do not share objects or tools between workers, but if shared tools are required, ensure appropriate cleaning and disinfection is performed between uses.
  • Provide disposable disinfecting wipes so that workers can wipe down commonly used surfaces (e.g., doorknobs, keyboards, remote controls, desks, electronic payment terminals, other work tools and equipment) before each use.
  • Store and use disinfectants in a responsible and appropriate manner according to the label.
  • Do not mix bleach or other cleaning and disinfection products together. This can create toxic vapors.
  • Advise workers always to wear gloves appropriate for the chemicals being used when they are cleaning and disinfecting and that they may need additional PPE based on the setting and product.

There have been increases in poisonings and injuries from unsafe use of cleaners and disinfectants since the start of the COVID-19 pandemic. Under OSHA's HazCom Standard, employers are required to provide workers with access to Safety Data Sheets (SDSs), which contain safety and usage information for each chemical.

Providing easy access to SDSs can be a challenge under normal conditions, but may be even more difficult presently as social distancing measures and reduced in-house staff causes workers to be more geographically separated than usual. Employers should consider the benefits of an easily-accessible web-based and mobile chemical and SDS management system.

11. Provide employees with guidance on screening and testing for COVID-19

Employers should follow state or local guidance and priorities for screening and viral testing in workplaces. Employers should inform workers of employer testing requirements, if any, and availability of testing options. Testing in the workplace may be arranged through a company's occupational health provider or in consultation with the local or state health department.

The CDC has published strategies for consideration of incorporating viral testing for SARS-CoV-2, the virus that causes COVID-19, into workplace COVID-19 preparedness, response, and control plans.

Organizations may consider implementing a system in which employees can report symptoms before entering the workplace. LiveSafe offers customizable surveys that employees can use to self-report COVID-19 symptoms, vaccination status, and potential exposures.

Employers can also upload testing and vaccination locations to the LiveSafe Safety Map for easy access and share relevant updates to employees through Broadcast messages. 

12. Record and report work-related COVID-19 infections and deaths

Assuming your organization is required to maintain work-related injury and illness records, if there has been a confirmed case of an employee contracting COVID-19, the case might be recordable if one of the following circumstances occur:

  • Medical treatment (beyond First Aid) is provided. It's likely that medical treatment or days away (lost time) will occur with COVID-19 cases; OR
  • Restricted work is imposed by the employee's treating physician or your employer; OR
  • Days away from work (lost time) are imposed by the treating physician. In other words, if the employee is kept from work and cannot work at home due to the virus; AND
  • The illness is a confirmed case of COVID-19. See the CDC’s information for clarification on persons under investigation and presumptive positive and laboratory-confirmed cases of COVID-19;
  • The case has been determined to be work-related.

It can be difficult to definitively determine whether a case of COVID-19 originated from exposure in the workplace. As a result, OSHA has issued guidance on determining work-relatedness for COVID-19 illnesses. For more on that, we've written a helpful overview of OSHA's guidance on recording and reporting COVID-19 cases. Vector EHS Management also facilitates work-related COVID-19 reporting and record-keeping.

13. Establish a system for employees to anonymously raise concerns about COVID-19 issues and implement protections from retaliation against any worker who does raise COVID concerns at work

Section 11(c) of the OSH Act prohibits discharging or in any other way discriminating against an employee for engaging in protected occupational safety and health activities. These protected activities include raising reasonable concerns about COVID-19 infection control or voluntarily wearing or providing their own personal protective equipment.

In addition to notifying workers of their rights to a safe and healthy work environment, employers should ensure that workers know whom to contact with questions or concerns, and that there are prohibitions against retaliation for engaging in protected occupational safety and health activities.

Organizations should also consider deploying method for workers to voice concerns anonymously, such as a hotline or another reliable reporting process. LiveSafe was purpose-built for two-way risk management communications. Employees can submit reports, anonymously if desired, using LiveSafe Tip Submit and can communicate about them using two-way chat.

14. Make COVID-19 vaccinations freely available to employees and provide training about the safety and value of the vaccine

Once your organization has made vaccines available to employees, upload vaccination policies to LiveSafe Resources and add relevant locations to the Safety Map. Use LiveSafe Broadcast to communicate relevant updates to your workforce.

15. Don’t distinguish between vaccinated and unvaccinated workers (i.e. maintain the same health and safety standards) 

Even when employees are vaccinated, it's important that they continue following your workplace's health and safety policies. To remind your workforce of this expectation, use an emergency notification system (ENS), such as LiveSafe's Broadcast messaging feature, to remind employees that vaccination status does not alter workplace health and safety policies.

16. Comply with other relevant OSHA standards

In addition to following this 16-point guidance, be sure to follow all other relevant OSHA standards. Examples include:

  • The OSHA General Duty Clause states that in addition to complying with all OSHA standards, employers must give all employees “employment and a place of employment which are free from recognized hazards,” including COVID-19. Following the safety protocols described in the section above can help maintain compliance.
  • OSHA Standard 1904.5 requires employers to record work-related COVID-19 illness on Form 300 logs and report it to health departments per local regulations.

OSHA-Compliant Return-to-Work Strategies

As your organization plans for a safe return to work amid COVID-19, OSHA’s 16-point guidance is a valuable reference point. Vector Solutions' offerings can help you comply with this guidance and keep your workforce safe and healthy.

In addition to deploying LiveSafe, continue using our free COVID Return-to-Work Checklist to help implement OSHA’s 16-point guidance into your workplace COVID-19 prevention strategy.

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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