Four members of AEU's loss control team – John Bloess, Jimmy Burgin, Terry Guidry, and Christian Murillo – recently recorded a webcast discussing their insights and observations around coronavirus-related safety issues. This article is a summary of their conversation, which addresses questions that they have received from ALMA members about continuing operations safety during the COVID-19 pandemic.
Personal Protective Equipment
Can employees use a homemade mask in their work facility?
Employees can't use a homemade face mask in the workplace because they are not NIOSH-approved. Companies must continue to comply with their written respiratory program which identifies the approved NIOSH respirators to protect employees. Also, employers are also still responsible for training employees on the limitations of all respirators.
Can employees reuse or extend the use of N95 respirators?
Yes. Employers must provide employees guidance in reusing or extending the use of N95 respirators based on the manufacturer's recommendation of the respirator. At a minimum, the employer should train employees on how to inspect the respirator to make sure the structural and functional integrity of the respirator has not been compromised. Employers should not allow respirators to be used by multiple employees. OSHA has a video and a poster showing the seven steps for correctly wearing an N95 mask.
What should a company do if they cannot buy N95 respirators?
Companies should revisit and assess their current engineering controls, their workplace practices, and any administrative controls they have in place to ensure employees are protected from workplace hazards. An example of engineering controls is to use a different approved NIOSH respirator that provides a greater level of protection until it can be replaced with an N95 respirator.
What's the difference between cleaning and disinfecting?
Cleaning is basically removing dirt and particles using soap and water or another type of solution. Disinfecting is killing bacteria and viruses using an EPA-approved disinfectant.
What steps are recommended for cleaning and disinfecting your work areas?
- Develop a plan. Determine if you're going to clean the facility yourself or use an outside contractor. If you don’t outsource, then you need to develop a COVID-19 safety steering committee that can help develop this plan. Who is going to be responsible for cleaning and disinfecting? What types of surfaces are you going to clean? When will the cleaning take place? What resources are available for cleaning products, disinfectants, and PPE?
- Implement the plan. This will require cleaning as well as disinfecting the equipment. You want to disinfect and clean surfaces that are touched frequently. It’s important to follow the manufacturer’s label of the disinfectant which has safety information including the PPE needed, ventilation required, and other guidelines.
- Maintain and revise your plan as needed. If one of your designated cleaners is unable to do the job, who will take their place? If you can’t find PPE or a disinfectant, what product will be used to replace it? Your COVID-19 safety steering committee should meet at least weekly to discuss how the plan is going, and what changes have developed, and what you can do to address those changes.
What common surfaces and equipment should be cleaned and disinfected?
- Hard non-porous surfaces include doorknobs, belt buckles, door latches, radio controls, glass, etc. These are generally things that people touch a lot and should be cleaned and disinfected often.
- For electronics, follow the manufacturer’s guidelines and instructions on how to clean and disinfect that specific type of equipment. If you cannot find that, use a sanitizing wipe that contains at least 60% alcohol. Make sure the equipment is thoroughly dry, and don't leave any areas pooling that could damage it.
- Soft porous surfaces include carpet, seats, seat belts, etc. Clean and disinfect these based on the manufacturer's instructions.
What are some best practices for disinfecting industrial vehicles or equipment to prevent exposure to COVID-19?
Companies should have a plan that includes cleaning and disinfecting industrial vehicles before each shift that involves the changing of operators. Pay special attention to those surfaces and objects that are frequently touched by operators and passengers, such as door handles, windows, buttons, armrests, buckles, etc.
How can workers protect their hands while cleaning or disinfecting surfaces that might have the novel coronavirus on it?
Wearing disposable gloves (either Nitrile or latex) is the best form of protection when cleaning and disinfecting surfaces. Gloves should be discarded after each cleaning. If reusable gloves are used, then those should be dedicated for cleaning and disinfection of surfaces for COVID-19 purposes only. Consult with the manufacturer concerning the cleaning instructions of those reusable gloves.
Workers should clean their hands often and immediately after removing gloves. Workers should also wash their hands with soap and water for a minimum of 20 seconds. If soap and water are not available and the hands are not visibly dirty, then they should use an alcohol-based hand sanitizer that contains at least 60% alcohol. However, if hands are visibly dirty, soap and water should be used. Otherwise, always follow hand hygiene. This includes not touching your face and washing your hands on a regular basis, especially if you sneeze or cough in your hand, after using the restroom, before preparing food, before eating, and if you're touching pets.
OSHA Guidance Related to COVID-19
OSHA has published a guidance document for preparing workplaces for COVID-19. What are the OSHA regulations related to this virus?
Although there is not a specific OSHA standard for the exposure to COVID-19, the prevention of the exposure and infection to the disease still applies. Some of the most relevant are OSHA's PPE standard for 1910 and 1915, Subpart I, 1917 Subpart E, and 1918 Subpart J, which require the use of gloves, eye, face protection and respiratory protection.
Another one is the general duty clause, which requires that employers furnish to each of its employees a workplace that is free from recognized hazards that are causing or are likely to cause death or serious physical harm.
The OSHA bloodborne pathogen standard also applies, which has some provisions that offer a framework that could help control some of the sources of the virus, including exposures to bodily fluids.
What are some resources that OSHA provides for COVID-19?
What additional engineering controls are suggested in the OSHA guidance document?
Some of the suggestions include installing high efficiency air filters, increasing or improving ventilation in the work environment, and installing physical barriers (such as clear plastic sneeze guards) in the work area.
What administrative controls are suggested in the OSHA guidance document?
- Encouraging workers to stay home if they're sick. If they're not feeling well, or if someone in their family is not feeling well, make sure that they understand that it's very important for them to remain home so they don't carry an illness back to the workplace.
- Minimizing contact between workers and customers by conducting virtual communications, eliminating face-to-face interaction as much as possible, and teleworking if feasible.
- Establishing extra shifts or staggering the employees in a facility or a job site to minimize the contact and maintain necessary social distancing.
- Discontinuing nonessential traveling to locations with ongoing COVID-19 outbreaks.
- Developing an emergency communication plan.
- Providing workers with up-to-date safety training, which includes COVID-19 risk factors and protective behaviors.
Safe work practices are also a part of administrative controls. What examples does OSHA provide?
Many of the examples that OSHA discusses in their guidance document revolve around providing an environment that promotes personal hygiene. For example, providing tissues, no touch-trash cans, hand soap, alcohol-based hand sanitizer with at least 60% alcohol, and disinfectants and disposable towels to clean the work surfaces. It also recommends that facilities require regular hand washing and post hand washing signs in or near the restroom area.
On April 10, OSHA published a memo* regarding compliance with OSHA 29 CFR 1904, the recordkeeping rule. Based on that memo, during this pandemic, has OSHA modified their requirements for recording coronavirus cases on the OSHA 300 log?
Yes. OSHA has relaxed their enforcement of the recordkeeping requirements as it pertains specifically to coronavirus cases and exposures. Companies must still record a confirmed case of the virus if there is objective evidence saying it is work-related. It's very important that companies conduct their due diligence on each case of the rule, on each case to rule out any objective evidence for a case not to be recordable.
If a company is unsure of the objective evidence to deny recordability of a case, they should document case and all the evidence that's available to them. Once they've done that, they can write the case on their OSHA 300 in red ink and revisit the case for any new evidence that would change the recordability of the case before completing the OSHA 300. Also, by documenting the evidence, a company will be in a better position to explain their decision should OSHA receive an employee complaint or conduct a site inspection.
*This guidance was revised on May 19, 2020.
Do employers have to record workers sent home for quarantine for coming in contact with another worker who tested positive for the virus?
No, a company does not have to record any employees who were sent home as a precautionary measure. It's also recommended by the Center for Disease Control that employees should be sent home if they've come in contact with the virus and quarantine themselves. However, should any quarantined worker subsequently test positive, then it would be objective evidence of workplace exposure and would need to be recorded on the OSHA 300.
Does an employer have to notify OSHA of a coronavirus hospitalization or fatality?
Yes. If the objective evidence found during the investigation confirms the employee contracted the virus in the workplace, then an employer must notify OSHA within 24 hours of hospitalization and eight hours of a fatality. That's why it's critical for a company to conduct a thorough investigation to confirm the virus was not contracted in the workplace.
What are employers doing to monitor employee temperature?
Many companies are conducting temperature checks on all individuals coming into the facility. Anyone having a low-grade fever is requested to see a doctor. Companies are also performing random temperature checks on employees throughout the day.