Workplace safety is critical as businesses come back on-line following shutdowns due to the SARS-CoV-2 virus and resulting COVID-19 illness. It is imperative that businesses ramp back up in a safe and managed way to ensure that the facility does not become a new "hot spot" for the pandemic. Illnesses, including COVID-19, potentially spread by unsafe acts, behaviors or conditions and can drastically impact employees and their families. And, as witnessed by the recent economic shutdown due to the effects of COVID-19, illnesses can also significantly impact a company's bottom line. Another impact on business operations is that any deaths of workers due to COVID-19 may be considered as "reportable" according to OSHA. Under OSHA's recordkeeping requirements
COVID-19 is a recordable illness, and employers are responsible for recording cases of COVID-19, if: (1) the case is a confirmed case of COVID-19, (2) the case is work-related as defined by 29 CFR § 1904.5; and (3) the case involves one or more of the general recording criteria set forth in 29 CFR § 1904.7.
Although OSHA indicates it will not enforce the reporting requirements at the present time, as the shutdown period ends, it may be that such incidents could be seen as directly related to work practices. Such losses would weigh heavily on a company's ability to keep insurance costs down, to maintain health and safety metrics (e.g., DART cases), not to mention the significant toll on the company and its employees. To date, the Centers for Disease Control and Prevention (CDC) reports that tens of thousands of people have died in the U.S., and the projections are that many more people will succumb to the virus. According to the CDC, the number of new cases, while somewhat flattening out, has not noticeably declined and the numbers continue to be alarming:
To reduce the potential for illness flare-ups, it is essential that effective safety and health practices be integrated into the "after COVID-19" daily work routines. In addition to adoption of new company-wide strategies to minimize exposure risks, it is imperative that the company develop and habituate amongst employees new processes to evaluate the potential health (and safety) hazards associated with each employee's work activities and to identify controls to eliminate or minimize the hazards.
To do this effectively, a job hazards analysis or job safety analysis (JSA) should be conducted. A JSA is a recognized and OSHA-recommended practice, and one of the most efficient ways to implement this is to use job hazard analysis software such as JSABuilder.
What Does OSHA Say About Next Steps for Business Restart?
Businesses, especially those in retail, construction, manufacturing and package delivery should review recently issued industry-specific guidance from OSHA and the CDC as the State-mandated shelter-at-home orders expire and employees return to work. Both OSHA and the CDC have recently published new guidelines to address these issues. Following the guidelines from OSHA will help employers and employees to contain the SARS-CoV-2 virus while bringing their business operations back on-line.
Common guidance among these industries includes encouraging workers to stay home if they are sick, allowing (and/or requiring) the use of masks and other personal protective equipment (PPE), promoting safe respiratory hygiene practices such as covering sneezes and hand-washing or using alcohol-based hand rubs (>60% alcohol), and encouraging workers to report any safety and health concerns. OSHA also recommends frequent cleaning of commonly touched surfaces using chemicals approved for destroying the coronavirus. All employers should also monitor public health communications about COVID-19 recommendations for the workplace and ensure that workers have access to and understand that information.
As an example, for the Construction Industry , OSHA recently has discussed the following guidance:
- Advise workers to avoid physical contact with others as much as possible, and direct all people on the job site to increase average personal space to at least six feet, where possible. Where work trailers are used, all workers should maintain social distancing while inside the trailers.
- Continue to use other normal control measures, including PPE, to protect workers from other job hazards associated with construction activities.
- Train workers in how to properly put on, use and wear, and take off protective clothing and equipment.
- To the extent tools or equipment must be shared, provide and instruct workers to use alcohol-based wipes to clean tools before and after use. When cleaning tools and equipment, workers should consult manufacturer recommendations for proper cleaning techniques and restrictions.
- Keep in-person meetings (including safety meetings) as short as possible, limit the number of workers in attendance, and use social distancing practices.
- Clean and disinfect portable job site toilets regularly. Hand sanitizer dispensers should be filled regularly. Frequently touched items (i.e., door pulls and toilet seats) should be disinfected. The US EPA has published cleaning and disinfecting guidelines that should be followed.
Businesses and individual facilities are going to have different concerns about coming back on-line while simultaneously managing their workforces in a safe manner during and after the COVID-19 pandemic. JSABuilder provides Health & Safety professionals with an easy-to-use tool that can help any type of business define potential hazards, including controlling the spread of viruses, and help define the means by which the employer will ensure that those hazards are mitigated.