Navigating workplace health and safety amid a pandemic adds increased challenges and additional concerns for employers to consider. OSHA recordkeeping requirements at 29 CFR Part 1904 mandate covered employers record certain work-related injuries and illnesses on their OSHA 300 log, including in some cases workplace exposures to COVID-19.
COVID-19 can be a recordable illness if a worker is infected as a result of performing work-related duties. However, employers are only responsible for recording cases of COVID-19 if all of the following are met:
- The case is a confirmed case of COVID-19 (see CDC information on persons under investigation and presumptive positive and laboratory-confirmed cases of COVID-19).
- The case is work-related, as defined by 29 CFR 1904.5.
- The case involves one or more of the general recording criteria set forth in 29 CFR 1904.7 (e.g., medical treatment beyond first aid, days away from work).
In assessing potential hazards, employers should consider whether or not their workers may encounter someone infected with COVID-19 in the course of their duties. Employers should also determine if workers could be exposed to environments (e.g., worksites) or materials (e.g., laboratory samples, waste) contaminated with the virus. Employers need to inform employees to alert their supervisor if they think they have been exposed to or become infected with COVID-19 on the job.
Control and Prevention
Measures for protecting workers from exposure to, and infection with, COVID-19 depend on the work type being performed and subsequent exposure risk, including potential interaction with infectious people and work environment contamination. Employers should adapt infection control strategies based on a thorough hazard assessment, using appropriate combinations of engineering and administrative controls, safe work practices, and personal protective equipment (PPE) to prevent worker exposures.
Some OSHA standards that apply to preventing occupational exposure to COVID-19 also require employers to train workers on elements of infection prevention, cleaning chemical safety, bloodborne pathogens, and PPE.
Employers should train all workers with reasonably anticipated occupational exposure to COVID-19 on the virus’ exposure sources and the hazards associated with exposure, and have appropriate workplace protocols in place to prevent or reduce exposure risk. Workers who are required to use PPE must be trained on when to use PPE; which PPE is necessary; how to properly put on, use, and take off PPE; how to properly dispose of or disinfect, inspect for damage, and maintain PPE; and PPE limitations.
RETTEW’s Safety Consulting professionals can assist you with assessing your potential hazards, developing infection control strategies, and training your employees. Contact Kelly Kramer, CECD, HEM, at 800.738.8395 to schedule a consultation. If your organization is a non profit or public entity, you may be eligible to receive training through a FEMA grant, click here for additional information.
Safety training and consulting are only some of RETTEW’s 600+ services. Our safety team works hand in hand with engineers, scientists, project managers, and other technical experts at places such as manufacturing facilities, drill pads, and commercial construction sites. We are well respected in many industries and known for ensuring workers and equipment remain safe, which keeps your projects on track and your bottom line growing.