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OSHA's Guidance on Preparing Workplaces for COVID-19

The Occupational Safety and Health Administration (OSHA) has set forth the following guidelines for all employers in order to reduce the risk of exposure to the novel coronavirus, which is the virus that causes COVID-19, in workspaces across the country. The guidelines can be simplified into a four-step plan as follows:

Step One: Develop an Infectious Disease Preparedness and Response Plan. This plan should (1) identify the sources of exposure of COVID-19 to the general public, customers, and high-risk individuals; (2) consider the employees' individual risk factors; and (3) implement federal, state, and local recommendations as a contingency plan for outbreaks within your workplace location(s).

Step Two: Prepare to Implement Basic Infection Prevention Measures. These measures should include:

  • Frequent and thorough hand washing by employees, customers, and worksite visitors (if soap and running water are not available, provide hand wipes containing at least 60 percent alcohol)
  • Encouraging sick or symptomatic employees to stay home
  • Providing customers and the general public with tissues and no-touch trash receptacles
  • Establishing flexible worksites and/or flexible work hours (e.g., staggered shifts) to increase physical distance among employees and others
  • Discouraging employees from using others' phones, desks, offices, tools, and other equipment, and maintaining regular and routine cleaning and disinfecting with EPA-approved products

A list of EPA-approved products may be found here. Employers should implement these measures and communicate them to the employees frequently through a method and/or platform known to the employees.

Step Three: Implement Workplace Controls. Such controls may include installing high-efficiency air filters, physical barriers, such as clear plastic sneeze guards, and a drive-thru window for service to the general public; increasing the ventilation rates within the workplace environment; posting hand-washing signs in all restrooms; and providing employees with up-to-date education and training on COVID-19 risk factors and protective behaviors.

Step Four: Provide Personal Protective Equipment (PPE) to all Exposed Employees. Determine which PPE each employee needs based on the respective exposure risk of each job type within the workplace, and provide the applicable PPE. Employers are required to provide the necessary PPE to keep employees safe. All PPE must be selected based upon the hazard to the employees; properly fitted and periodically refitted; consistently and properly worn; regularly inspected, maintained, and replaced; and properly removed, cleaned, and stored or disposed. For additional guidance regarding OSHA's classification of employee exposure levels and corresponding protective measures needed, see the summary chart Baker Donelson has prepared here.

Baker Donelson is here to assist you in implementing OSHA's guidance to create a plan tailored to your business. Please reach out to Ashley Strittmatter for assistance. For more information and general guidance on how to address other legal issues related to COVID-19, please visit the Coronavirus (COVID-19): What You Need to Know information page on our website.

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