Earlier today, the Occupational Safety and Health Administration issued its Guidance on Mitigating and Preventing the Spread of COVID-19 in the Workplace. The Guidance is not legally binding but does detail recommended best practices around managing COVID-19 in the workplace.
OSHA has reiterated that workers should continue to maintain at least a six-foot distance from others when possible, wash hands, properly wear a face mask (covering nose and mouth), and take proper precautions when sneezing or coughing. OSHA specifically called for continued mask wearing even after receiving a vaccine, given the uncertainties with how transmission is or not affected by vaccination.
The bulk of the Guidance focuses on COVID-19 Prevention Programs, which OSHA maintains is the most effective way to mitigate against the spread of COVID-19 in the workplace. OSHA suggests that such prevention programs include (among other things):
- a workplace coordinator who is responsible for COVID-19 issues;
- conducting a hazard assessment to determine where and how workers may be exposed to COVID-19;
- identifying measures that can be taken to reduce the spread of COVID-19, with a priority focus on using the most effective controls first [the Guidance has a detailed section on this Hierarchy of Controls approach that includes engineering controls, administrative controls, safe work practices, and PPE];
- extra protections for workers, especially those who are higher risk for severe illness;
- establishing an effective communication system surrounding COVID issues;
- training employees on COVID-19 policies and practices;
- keeping those who are sick or likely sick with COVID out of the work place, with a non-punitive absence policy;
- encouraging telework or paid leave for employees in quarantine;
- properly cleaning and disinfecting the workplace upon confirming a COVID-19 case;
- conducting appropriate screening;
- providing information on testing;
- recording work-related illnesses and death to the extent they are known;
- ensuring employees are protected from retaliation if they should voice concerns related to COVID-19 in the workplace;
- making the vaccine available or subsidizing the cost is an option; and
- requiring all employees, whether vaccinated or not, to continue with other safe preventative practices.
OSHA also set out a very detailed suggestions for limited the spread at work, that includes separation, physical distancing, installing physical barriers, improved ventilation, hygiene supplies, regular cleaning and disinfecting, and other similarly common place COVID-related practices.