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Coming back to work after COVID19 – A Response Plan

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OSHA has indicated that employers must have some level of response plan when considering the continuation or opening of their business. The plan is in place to protect workers from COVID19 exposure in the workplace. Here are three (3) major items to include in your response plan.

  1. Job Site Analysis or Job Hazard Analysis (JHA)
    • Anyone who has ever participated or completed safety work knows about a JHA. This process is designed to develop a better understanding of how employees are exposed to work related safety risks and design controls to those protect workers. The same applies with COVID19 exposure. We must look at the hazard, which is a respiratory droplet and potentially airborne pathogen. In order to protect workers, what controls are necessary to prevent exposure to this hazard?
    • This is also very dependent on the level of risk as defined by OSHA and the level of risk will dictate the level of controls necessary to ensure protection
  2. Implementation of Controls
    • Once the JHA is complete, additional identified controls must be implemented to protect workers. This includes engineering and work practice controls. Engineering controls can include installing plastic barriers between work stations or otherwise isolating the workers from exposure. Administrative controls are more practical but require employees to follow a rule such as:
      • Maintaining 6 foot distance while in the workplace
      • Rotating clock in times to limit contact with coworkers
      • Cleaning and disinfecting of high touch surfaces on a regular frequency
    • Once all controls are exhausted, then Personal Protective Equipment can be considered.
      • If the hazards can’t be controlled and employees are required to wear N95 and other tight fitting respirators, the employer must develop and implement a Respiratory Protection Program. Wearing a respirator puts an undue physiological burden on the user so employees must be medically cleared to wear the respirator by completing a Medical Evaluation Questionnaire (MEQ). Once they are cleared, they must be fitted on the mask that they will wear to ensure it provides an adequate seal.
  3. COVID Exposure Control Plan
    • Now that you have established ways to protect your employees while at work. What do you do if one of your employees, their immediate family member, or a visitor tests positive for COVID19?
    • There must be a plan in place which, at a minimum, requires employees to self isolate at home for at least 14 days.
    • A major component of this plan is also the communication which you will have with the employee to determine when it is safe for them to return to work.

Need help with developing this plan or any other regulatory compliance plans? We can help! Contact Us to schedule time to review your company specific needs.

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