OSHA Guidance for Mitigating & Preventing the Spread of COVID-19 in the Workplace

1. Assign a workplace coordinator
2. Identify where and how workers may be exposed to COVID-19 at work through a thorough hazard assessment
3. Identify measures that will limit the spread of COVID-19 in the workplace
   • Separate and send home potentially infected workers
   • Implement physical distancing requirements, including telework and remote work
   • Install barriers where physical distancing cannot be maintained
   • Use of face coverings
   • Improve ventilation
   • Use applicable PPE
   • Provide supplies for good hygiene
   • Routine cleaning and disinfection
4. Consideration of protections for workers at a higher risk for severe illness
   • Older adults and workers with serious underlying medical conditions
   • Where possible, consider reasonable modifications for high-risk workers who can work from home (even part time) or in a less densely-occupied area
5. Establish a system for communicating effectively with workers
   • Ask workers to report, without fear of reprisal, any symptoms, possible exposures, or possible hazards in the workplace
6. Educate and train workers on COVID-19 policies and procedures
   • Emphasis on communicating clearly and in a language workers can understand
   • Communicate basic facts about COVID-19 (how it is spread, physical distancing, use of masks, hand hygiene)
   • Ensure that workers know who to communicate with and what their rights are
7. Instruct workers who are infected or potentially infected to stay home and isolate or quarantine
   • Make sure these policies do not punish such workers
8. Minimize negative impact of quarantine and isolation on workers
   • Allow telework or working in isolated areas where possible
   • Allow use of paid sick leave and consider implementation of paid leave policies
   • The Families First Coronavirus Response Act provides certain employers 100% reimbursement through tax credits to provide employees with paid sick leave or expanded family and medical leave for specified reasons related to COVID-19 through March 31, 2021
9. Isolate workers who show symptoms at work
10. Perform enhanced cleaning and disinfection after people with suspected or confirmed COVID-19 have been in the facility. OSHA provides the following steps for a cleaning:
    • Close areas used by the infected person
    • Open outside doors and windows to increase air circulation
    • Wait as long as practical before cleaning or disinfecting, ideally 24 hours
    • Clean and disinfect all work areas and equipment used by the infected person
    • Vacuum if needed using a vacuum with a HEPA filter
    • Provide cleaning workers with disposable gloves
    • After cleaning, disinfect with an appropriate EPA-registered disinfectant
11. Provide guidance on screening and testing
12. Recording and reporting COVID-19 infections and deaths
    • Employers are responsible for recording any work-related cases of COVID-19 on their Form 300 logs if: (1) the case is a confirmed case of COVID-19; (2) the case is work-related; and (3) the case involves one or more relevant recording criteria (e.g., medical treatment, days away from work)
13. Implement protections from retaliation and set up an anonymous process for workers to voice concerns about COVID-19 hazards
    • The OSH Act prohibits employers from discriminating against employees for raising a reasonable concern about infection control related to COVID-19 to the employer, the employer’s agent, other employees, a government agency, or to the public
14. Make a COVID-19 vaccine available at no cost to employees
15. Do not distinguish between workers who are vaccinated and those who are not
    • Vaccinated employees must continue to follow protective measures such as physical distancing and face covering, as there is no evidence that COVID-19 vaccines prevent transmission of the virus at this time
16. All other applicable OSHA standards
    • These include: requirements for PPE (29 CFR 1910, Subpart I (e.g., 1910.132 and 133), respiratory protection (29 CFR 1910.134), sanitation (29 CFR 1910.141), protection from bloodborne pathogens: (29 CFR 1910.1030), and OSHA’s requirements for employee access to medical and exposure records (29 CFR 1910.1020).

Isolating workers who have or likely have COVID-19

• If workers have symptoms, they can return after:
  • 10 days since symptoms first appeared; and
  • At least 24 hours with no fever without fever-reducing medicine; and
  • Other symptoms of COVID-19 are improving
• Some workers may need to stay home for longer than 10 days, if advised by a medical provider
• The ADA permits employers to require a doctor’s note from workers to verify that they are healthy and able to return to work
• The CDC does not recommend use of antibody tests to determine which workers can work, as they are not very reliable

Quarantine workers who have been exposed to COVID-19

• An exposure to COVID-19 includes:
  • They were within 6 feet of someone with COVID-19 for 15 minutes or more
  • They had direct physical contact with someone who has COVID-19
  • They shared eating or drinking utensils with someone who has COVID-19
  • Someone with COVID-19 sneezed or coughed on them
• Quarantine for 14 days after the last contact with someone who has COVID-19
  • Watch for COVID-19 symptoms
  • Stay away from people who are at high risk for getting very sick from COVID-19

Limit the number of people in one place through:

• Telework or remote work
• Flexible hours

Increase physical space between workers and customers, and consider using physical distancing signs, tape marks, decals, or other visual cues to encourage individuals staying 6 feet apart.

Shift primary stocking activities to off-peak or after hours to reduce contact with customers.

OSHA recommends that employers provide all workers with face coverings, at no cost, unless a respirator is required. Employers must discuss the possibility of reasonable accommodation for workers who are unable or have difficulty wearing certain types of face coverings due to a disability.

Require any other individuals at the workplace, such as visitors and customers, to wear a face covering unless they are under the age of 2 or are actively consuming food or beverages.

The CDC has provided guidance on how to improve ventilation and prevent the spread of COVID-19, which can be found by clicking here: https://www.cdc.gov/coronavirus/2019-ncov/community/ventilation.html

Some of these guidelines are:

• Increase ventilation rates if possible
• Increase fresh outdoor airflow by opening windows and doors as weather allows
• Consider using a fan to exhaust air out an open window
• Disable demand-controlled ventilation
• Reduce or eliminate recirculation
• Improve central air filtration to the MERV-13 or highest compatible filter
• If ventilation cannot be increased, consider reducing occupancy of the building

When the above measures cannot be implemented to protect workers fully, OSHA requires employers to provide PPE to supplement other controls. This includes:

• Determining what PPE is necessary
• Providing PPE, including respirators, face shields, gloves, and protective gowns at no cost
• Where PPE is not required under OSHA, some workers may have a right to PPE as a reasonable accommodation under the ADA

Ensure that workers, customers, and visitors have supplies to clean their hands frequently and cover their coughs and sneezes. This includes:

• Tissues and no-touch trash cans
• Soap and water or alcohol-based hand sanitizer that is at least 60% ethanol or 70% isopropanol
• Provide workers time to wash hands or use hand sanitizer and inform workers that soap and water is preferable to hand sanitizer if hands are visibly dirty. Important times for cleaning hands are:
  • Before and after shifts
  • Before and after breaks
  • After blowing their nose, coughing, or sneezing
  • After using the restroom
  • Before and after preparing food
  • After putting on, removing, or touching PPE and face coverings
  • After coming into contact with surfaces touched by other people