The U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) has issued guidance and a “lessons learned” sheet to help employers understand which standards are most frequently cited during Coronavirus-related inspections. These documents are based on data from issued citations resulting from complaints, referrals, and fatalities in industries such as hospitals, nursing homes, long-term care facilities, and other sources.
The guidance document may be reviewed at: https://www.osha.gov/SLTC/covid-19/covid-citations-guidance.pdf. The “lessons learned” publication provides examples of requirements employers must follow, such as these:
- Provide a medical evaluation before a worker is fit-tested or uses a respirator.
- Perform an appropriate fit test for workers using tight fitting respirators.
- Assess the workplace to determine if COVID-19 hazards are present, or likely to be present, which will require the use of a respirator and/or other personal protective equipment (PPE).
- Establish, implement, and update a written respiratory protection program with required worksite-specific procedures.
- Provide an appropriate respirator and/or other PPE to each employee when necessary to protect the health of the employees (ensuring the respirator and/or PPE used is the correct type and size).
- Train workers to safely use respirators and/or other PPE in the workplace and retrain workers about changes in the workplace that might make previous training obsolete.
- Store respirators and other PPE properly in a way to protect them from damage, contamination, and, where applicable, deformation of the facepiece and exhalation valve.
- For any fatality that occurs within 30 days of a work-related incident, report the fatality to OSHA within eight hours of finding out about it.
- Keep required records of work-related fatalities, injuries, and illness.
Employers are also encouraged to learn more about OSHA’s On-Site Consultation Program, which offers no-cost and confidential occupational safety and health services to small- and medium-sized businesses – see https://www.osha.gov/consultation
Compliance Perspective
OSHA requires employers to provide safe and healthful workplaces for their employees. During the COVID-19 pandemic, failure by facilities to prevent and control the spread of the virus through provision of the necessary personal protective equipment (PPE); properly fitting respirators; and keeping necessary records of work-related fatalities, injuries, and illness may result in citations and fines.
Discussion Points:
- Review policies and procedures to ensure that OSHA guidelines for protecting employees are current and implemented.
- Train staff members on the correct methods for wearing and disposal of PPE and the proper fitting of respirators.
- Periodically audit to ensure there is an adequate supply of PPE and respirators, and that they are being worn and disposed of properly.
