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Is Your Company COVID Safe?

  • Are You Doing Everything Possible to Make Your Company Safe From COVID-19 Infections & Risks?
    • Most employers don’t realize that in order to make their company safe from COVID, they must develop & manage a comprehensive Infectious Disease Response Plan.
    • Most companies are implementing “bits and pieces” of the plan, like using social distancing and face masks, but there’s much more to be done.
    • This Infographic will explain the basic plan requirements & how it can help protect your business, employees & customers from COVID-19 related harm.
  • Here’s What We’ll Cover:
    • What is an Infectious Disease Response Plan? A Preview
    • Risks & Liabilities Associated With Failing To Develop A Plan
    • Critical OSHA Laws & Standards You Need to Know About
    • How To Build An Infectious Disease Response Plan
  • What is An Infectious Disease Response Plan?
    • It’s primarily made up of OSHA and CDC guidance, recommendations and laws.
    • The plan requires an overall risk assessment of the business
    • Implementation of a long list of engineering, administrative and PPE measures & controls to address workplace infection risks
    • Bonus: the plan can address any future pandemic, not just COVID
  • What Risks Do You Face for Not Developing & Managing A Plan?
    • OSHA fines and penalties: OSHA is currently focusing their enforcement efforts towards COVID Employee Complaints.
    • Company outbreaks which could shut down your business
    • Bad Press & reputation damage
    • Potential Civil Liability

Critical OSHA Laws & Requirements You Need To Know About:

  • OSHA’s “General Duty Clause” states that workplace COVID-19 infections are a “recognized hazard” which employers must assess and control.
  • Employers should focus on how their employees could be exposed to infected people or environments, materials, and surfaces contaminated with COVID.
  • Once exposures are known, employers should implement policies and procedures to eliminate or reduce risk of exposures. This often triggers other OSHA laws as described below.
    • Personal Protective Equipment Standard (“PPE”) Includes:
      • Draft Written Program
      • Selection & provide appropriate PPE
      • Conduct Job Task Hazard Assessments
      • Develop and Deliver Customized Employee Training & Document
      • Illustration:  Did You Know That Face Masks Aren’t Considered PPE?
    • Respiratory Protection Standard Includes:
      • Draft Written Program
      • Select & provide appropriate respirators
      • Conduct medical evaluations & fit tests
      • Develop and Deliver Employee Training & Document
    • OSHA 300 Logs:
      • Employers must track and report all work related COVID-19 infection on OSHA 300 logs
      • Post OSHA 300 Logs Annually
      • Certain Industries Must Electronically Submit OSHA 300 Logs
    • Whisteblower Protection:
      • Employers cannot retaliate against employees to complain to OSHA about safety related work conditions, including COVID complaints.
    • OSHA Enforcement:
      • Employers who fail to manage these laws face huge fines that can run into the $10s or $100s of thousands of dollars.
      • OSHA will evaluate if violating employers evaluated all compliance options, including virtual professional assistance and training.

How To Build An Infectious Disease Response Plan:

  • Step 1:  Assess Your Company Risks
    • Occupational Infection risks increases as follows: (MOVED From Above)
      • Gatherings of employees & customers in close proximity (< 6’), including work areas, for training & meetings.
      • Poor airflow/ventilation
      • Business travel:
        • Air travel
        • Travel to infection “hot spots”
        • Travel to customer and vendor locations
      • Exposure to contaminated materials
      • Exposure to customers and visitors\
  • Once company risks have been assessed, develop a customized Infectious Disease Response Plan to address them. (MOVED from Above)
    • The Plan Should Focus On A Variety of Control and Prevention Measures
    • Measures include a combination of engineering, administrative, safe work practices and PPE use.
  • Illustration: A person wondering about what all of this means.
  • Control Measure Option Examples:
    • Engineering Controls:
      • Installing barriers, floor markings, increasing air ventilation, filters, signage
    • Administrative Controls:
      • Training, staggering shifts, symptom reporting procedures
    • Safe work practices:
      • Frequent hand washing, cover face when coughing or sneezing, social distancing (>6’)
    • Personal Protective Equipment (PPE):
      • Respirators, face shields, gloves, goggles
      • **Cotton face masks AREN’t PPE!!**
    • NEVER FORGET THAT PPE SHOULD BE THE LAST LINE OF PROTECTION!
  • OSHA strongly recommends that employers assign 4 categories of risk level and then take action to control each:
    • Review all company job tasks and assign each to one of the 4 risk categories
    • Implement specific control measures for each risk category, including engineering, administrative, safe practices and PPE

Other Key CDC & OSHA Guidance & Recommendations:

    • Include State & Local Requirements:
      • Many local governments are issuing their own laws & requirements
      • Mandatory face mask use for employees & customers
      • Mandatory infection reporting
      • Criminal enforcement authority
      • Illustration: Business owner scanning computer screen.
    • Disinfecting & Sanitization Procedures:
      • Develop plan for routinely cleaning common surfaces including desktops, guardrails, keyboards, door handles, etc.
      • Train assigned employees & provide PPE
      • Only use EPA approved disinfectants
      • Enhanced decontamination if employee tests positive at work.
    • Employee Training:
      • Train staff on potential exposures and risks
      • Include relevant company policies and procedures
      • PPE use
      • Infection Reporting & Management:
        • Develop policies and procedures to quickly identify and isolate sick employees
        • Screen employees for symptoms.
        • Symptomatic staff should stay home and not return to work until all symptoms have ceased for at least 24 hours.
        • Maintain flexible and compliant policies to deal with sick leave, care for family members, etc.
  • Plan for potential widespread Covid-19 outbreak:
    • Companies should begin planning for varying levels of outbreak severity.
    • CDC offers detailed planning guidance which we will not attempt to summarize here. We encourage employers to review and act on this guidance in the event that the coronavirus reaches severe levels resulting in long term, major business and economic disruption.
  • Increase Building Air Exchange & Ventilation:
    • Several agencies are now recommending increased air exchanges to dilute potential infected microdroplet exposures.
    • Modify HVAC systems to increase outdoor air exchanges
    • Install HEPA filters
    • Open windows
    • Small Businesses Face Major Challenges managing COVID-19 requirements & risks
      • Key challenges include lack of:
        • Expertise
        • Time
        • Resources

We’ve responded to these challenged by offering a new set of Workplace COVID-19 Safety Services to help companies manage these risks and requirements.  Checkout the services or give us a call for a free consultation at 512-457-0374