On January 29, 2021, the Occupational Safety and Health Administration (OSHA) issued updated guidance and recommendations on workplace safety and coronavirus protection programs, which require greater input from employees and enhanced mask protections:
COVID-19 Prevention Program
OSHA’s latest guidance indicates that implementing a COVID-19 prevention program is the most effective way to mitigate the spread of COVID-19 at work. This guidance follows states such as California and Virginia that have adopted standards requiring many employers to implement a COVID-19 prevention program. The fact that OSHA highlights the importance of implementing a COVID-19 prevention program suggests that, if an emergency temporary standard is issued, it will include a requirement that employers implement a prevention program.
According to this latest guidance, OSHA recommends that a COVID-19 prevention program engage workers in the development and implementation of the program, and include the following elements:
- Assignment of a workplace coordinator to address COVID-19 issues.
- Identification of where and how workers might be exposed to COVID-19 at work through a hazard assessment.
- Identification of measures that will limit the spread of COVID-19 in the workplace, including engineering hazards, administrative policies, and additional personal protective equipment.
- Consideration of protection for workers at higher risk for severe illness through supportive policies and practices.
- Establishment of a system for communicating effectively with workers in a language they understand, including a system for employees to self-report COVID-19 symptoms or exposure.
- Education and training for workers on COVID-19 policies and procedures.
- Instructing workers who are infected or potentially infected to stay home and isolate or quarantine.
- Minimizing the negative impact of quarantine and isolation on workers through telework and flexible paid leave policies.
- Isolating workers who show symptoms at work.
- Performing enhanced cleaning and disinfection after a suspected or confirmed case of COVID-19.
- Providing guidance on screening and testing.
- Recording and reporting COVID-19 infections and deaths.
- Implementing protection from retaliation and setting up an anonymous process for employees to voice concerns about COVID-19 hazards.
- Making a COVID-19 vaccine available at no cost to employees.
- Not relaxing preventative measures for employees who have been vaccinated.
Many employers have likely implemented many of these policies and procedures – but may not have adopted them in a comprehensive COVID-19 prevention program. You should use this guidance as an opportunity to review your current policies and procedures and begin the process of compiling them into a formal prevention program.
Please visit the Guardian HR Forms Library located in the Client Portal for templates, policies, and forms to assist you in creating a Covid Prevention Program. Access to our Client Portal is only available to active client users. In order to comply with these OSHA Guidelines, employers will need to undergo a detailed safety analysis to create a Covid Prevention Program. Please visit www.www.guardian-hr.com/safety-services/ for further information on how Guardian HR can help you with this safety analysis.
OSHA’s use of the language “for planning purposes” suggests that it is likely the first step towards OSHA implementing an Emergency Temporary Standard that will provide required steps that employers must take. Therefore, employers should begin to implement the guidance.
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