On January 29, 2021, OSHA published guidance to help organizations establish COVID-19 prevention programs, mitigate the spread of the virus, and protect employees and business operations. This 16-point guidance is an important reference point for companies seeking to reopen their workplaces and avoid infractions. For more information, watch the webcast of Vector's recent webinar, 16 Steps to a COVID-19 Prevention Plan at Work.
Here, we provide an overview of the topics covered in the OSHA guidance, discuss systems and technology solutions that can help organizations with their prevention strategies, and offer a downloadable COVID Return-to-Work Checklist to help you prepare for a safe and healthy return to work.
The workplace coordinator should administer the COVID-19 prevention program on the employer’s behalf and serve as the main point of contact for any questions or concerns that workers may have. It’s important that all employees can easily access the coordinator’s contact information.
Once you choose a COVID-19 workplace coordinator, you'll want to communicate this to your workforce. Many two-way safety and security risk communication platforms, like Vector LiveSafe, feature broadcast message functionality that can be used to inform all employees of the coordinator's role description and contact information. This information can also be posted to Vector LiveSafe's configurable Resources section within the mobile app for employees to easily access, with or without an internet connection.
OSHA recommends that employers conduct a thorough hazard assessment to identify how and where employees might be exposed to COVID-19 on the job. This assessment will be most effective if workers are able to provide report concerns, as they are often most familiar with the conditions and potential hazards they face in the workplace.
With the Vector LiveSafe Mobile App, employees can submit tips about COVID-related hazards in the workplace, such as coworkers congregating without masks. This helps organizational leadership identify how the workforce may be exposed and develop appropriate prevention and response strategies.
When assessing workplace risk, it's important to consider risk exposure levels. OSHA classifies job tasks into four potential risk exposure levels: very high, high, medium, and lower, depending in part on the following factors:
If you aren’t familiar with the process of assessing workplace hazards, one of the best ways to do so is through conducting a job safety analysis (JSA), also commonly known as a job hazard analysis (JHA). According to OSHA, a JSA is “a technique that focuses on job tasks as a way to identify hazards before they occur.” This enables you to break a job down into the tasks it involves and then to identify hazards associated with each task.
If you need help getting started, consider this article about how to conduct a JSA and use a risk matrix to evaluate COVID-19 occupational exposure risks. Whether this is your first introduction to JSAs, or they’re already an important component of your safety program, there are tools that can help you to streamline your COVID-19 job hazard evaluations.
In addition, Vector EHS Management software allows organizations to easily create JSA checklists to assess employees’ exposure risks to COVID-19, identify controls, and share JHAs with key team members for review and approval in order to establish and improve best practices. Vector EHS Management’s robust reporting tools allow EHS managers to dig deeper into JHA analytics to view close-out rates and track COVID-19 hazards by source, department, area, and more.
Once you have identified a hazard (or hazards) at work, usually through a job hazard analysis, you then use the hierarchy of controls as a framework when considering how to implement controls that mitigate the risk of the identified hazards.
The hazard controls are listed in order of their effectiveness. First, and most effective, is elimination. If this isn’t possible or feasible, then you continue down the list to substitution, then engineering controls, then administrative controls, and then finally personal protective equipment.
Once you have identified COVID-related risks and appropriate response policies using the hierarchy of controls, Vector LiveSafe's Broadcast and Resources offerings can be used to communicate them. Vector LMS and & Training Management can also be used to educate employees on COVID-related safety measures.
Older adults and people of any age who have serious underlying medical conditions are at higher risk for severe illness from COVID-19. Workers with disabilities may be legally entitled to "reasonable accommodations" that protect them from the risk of contracting COVID-19.
Where feasible, employers should consider reasonable modifications for workers identified as high-risk who can do some or all of their work at home (part or full-time), or in less densely occupied, better-ventilated alternate facilities or offices. Better workplace ventilation is one option that could be considered for employees who have heart or lung vulnerabilities.
When you are developing policies for high-risk workers it's important to get employee feedback. Communication solutions like LiveSafe's Tip Submit tool help employees share their policy recommendations. Once policies have been developed, you can upload information and guidance into the customizable LiveSafe Resources for easy access by employees.
To facilitate COVID-19 mitigation and control, employers should provide workers with:
It's most effective to inform your workforce using a variety of communication methods. This could include a combination of workplace posters and signage, emails, text messages, verbal communication, and more.
Organizations should also have a means of tracking which workers have been informed and when. For example, if you communicate your COVID-19 policies in your weekly safety meeting, you can have everyone sign a log to confirm they have heard and understand what they learned in the meeting.
If your organization utilizes online training courses and a learning management system (LMS), you can easily deliver and document your COVID-19 employee training. If you use the Vector LiveSafe platform, you can include workplace safety and quarantine policies in the configurable Resources section. Employees can also use LiveSafe Emergency Options to communicate with emergency services and find nearby health resources on the Resources section Safety Map.
Vector Solutions also offers comprehensive, complimentary online COVID-19 training and CDC-based resources for families, employers and employees, businesses, caregivers, first responders, and cleaning and disinfection crews.
When possible, allow employees to telework, or work in an area isolated from others. If those are not possible, allow workers to use paid sick leave, if available, or consider implementing paid leave policies to reduce risk for everyone at the workplace.
Employers can use LiveSafe to share mental health resources and organizational points of contact. The LiveSafe platform can also be used to engage in two-way conversations with employees who may be struggling.
Workers who appear to have symptoms upon arrival at work or who develop symptoms during their work shift should immediately be separated from other workers, customers, and visitors, sent home, and encouraged to seek medical attention.
Organizations can use LiveSafe to communicate policies for workplace isolation.
OSHA advises that employers follow the CDC’s Guidance for Cleaning and Disinfecting to develop, implement, and maintain a plan to perform regular cleanings to reduce the risk of exposure to COVID-19.
This guidance recommends that organizations:
There have been increases in poisonings and injuries from unsafe use of cleaners and disinfectants since the start of the COVID-19 pandemic. Under OSHA's HazCom Standard, employers are required to provide workers with access to Safety Data Sheets (SDSs), which contain safety and usage information for each chemical.
Providing easy access to SDSs can be a challenge under normal conditions, but may be even more difficult presently as social distancing measures and reduced in-house staff causes workers to be more geographically separated than usual. Employers should consider the benefits of an easily-accessible web-based and mobile chemical and SDS management system.
Assuming your organization is required to maintain work-related injury and illness records, if there has been a confirmed case of an employee contracting COVID-19, the case might be recordable if one of the following circumstances occur:
It can be difficult to definitively determine whether a case of COVID-19 originated from exposure in the workplace. As a result, OSHA has issued guidance on determining work-relatedness for COVID-19 illnesses. For more on that, we've written a helpful overview of OSHA's guidance on recording and reporting COVID-19 cases. Vector EHS Management also facilitates work-related COVID-19 reporting and record-keeping.
Section 11(c) of the OSH Act prohibits discharging or in any other way discriminating against an employee for engaging in protected occupational safety and health activities. These protected activities include raising reasonable concerns about COVID-19 infection control or voluntarily wearing or providing their own personal protective equipment.
In addition to notifying workers of their rights to a safe and healthy work environment, employers should ensure that workers know whom to contact with questions or concerns, and that there are prohibitions against retaliation for engaging in protected occupational safety and health activities.
Organizations should also consider deploying method for workers to voice concerns anonymously, such as a hotline or another reliable reporting process. LiveSafe was purpose-built for two-way risk management communications. Employees can submit reports, anonymously if desired, using LiveSafe Tip Submit and can communicate about them using two-way chat.
Once your organization has made vaccines available to employees, upload vaccination policies to LiveSafe Resources and add relevant locations to the Safety Map. Use LiveSafe Broadcast to communicate relevant updates to your workforce.
Even when employees are vaccinated, it's important that they continue following your workplace's health and safety policies. To remind your workforce of this expectation, use an emergency notification system (ENS), such as LiveSafe's Broadcast messaging feature, to remind employees that vaccination status does not alter workplace health and safety policies.
In addition to following this 16-point guidance, be sure to follow all other relevant OSHA standards. Examples include: