SC&RA COMMENT: Protecting workers

Joel Dandrea discusses new Covid-19-related guidance from OSHA.

OSHA recently issued guidance and an accompanying document to help employers understand which standards are most frequently cited during coronavirus-related inspections. They based these findings on data from citations issued, many the result of complaints, referrals and fatalities in industries such as hospitals and healthcare, nursing homes and long-term care facilities and meat-processing plants.

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“Common Covid-19 Citations: Helping Employers Better Protect Workers and Comply with OSHA Regulations” was published to help employers better protect their workers. By understanding which workplace hazards have most often resulted in OSHA citations, employers can better ensure that they are adequately protecting workers.

Relatedly, they also issued guidance that will assist contractors and other businesses in passing jobsite inspections.

The most frequently cited violations are those related to respiratory protection (1910.134), and specifically, the lack of medical evaluations and fit tests. The next-most violated standards are respiratory protection programs: not implementing a written program with worksite-specific safety procedures; not providing employees with information about using respirators when their use is not mandatory; and not designating a qualified administrator to ensure the program’s effectiveness.

OSHA is using existing standards when inspecting jobsites for violations because it chose not to develop Covid-19-specific emergency standards due to evolving guidance from public health officials.

Respiratory protection citations aside, OSHA also cited employers with such violations as Recording and Reporting Occupational Injuries and Illnesses (Subpart 1904); Personal Protective Equipment (1910.132); and General Duty Clause (OSH Act 5(a)(1)).

To come into compliance in advance of an inspection, employers should consider: providing a medical evaluation before a worker is fit-tested or uses a respirator; using a tight-fitting respirator to perform the fit test; assessing the workplace to determine if Covid-19 hazards are or are likely to be present and if they will require the use of a respirator and/or other PPE; establishing, implementing and updating a written worksite-specific respiratory protection program with required worksite-specific procedures; providing an appropriate respirator and/or other PPE to each employee when necessary; providing up-to-date training to workers on the safe use of respirators and/or other PPE; properly storing respirators and other PPE to protect them from damage; timely reporting of work-related fatalities; and keeping required records of work-related fatalities, injuries and illness.

Lessons learned

Overall, OSHA has emphasized that employers are required to make sure employees wear respirators when jobsite conditions call for their use – elaborating that respirators, some of which capture fumes, and others dust – shouldn’t be confused with face coverings like masks and shields, which often don’t achieve as tight a fit. As for construction workers in particular, OSHA has issued guidance that indicates workers should wear face coverings while on the job and practice social distancing when possible.

OSHA also introduced a rule that makes it mandatory to report workplace-related Covid fatalities within eight hours. The reporting is only required if the case was connected to workplace exposure.

The one-page “Lessons Learned: Frequently Cited Standards Related to Covid-19 Inspections” addresses frequently cited standards and examples of other requirements such as retraining workers about changes in the workplace that might make previous training obsolete, and storing respirators and other PPE to protect them from damage, contamination and deformation.

OSHA provides a free on-site consultation program that offers confidential services to small- and medium-sized businesses to identify workplace hazards, provides advice for compliance with OSHA standards and assists in establishing and improving safety and health programs. This service does not result in penalties or citations.


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