As with any workplace hazard, employers should assess overall risk level based upon anticipated exposure range and the degree of injury or illness severity. In the case of the COVID-19 pandemic, we are forced to navigate unfamiliar territory complicated by the absence of formal safety standards, such as OSHA or ANSI, to specifically direct employer compliance actions.
The WHO, CDC, OSHA and NECA all provide excellent Coronavirus specific resources to educate employers and our workforce on what this new virus is, how it can affect our health, and most importantly, precautions we can take to reduce potential exposures in all settings of life.
While under specific State mandated orders, certain business types have been forced to close to limit spread of the virus, it appears that many of our construction projects will continue to remain open, at least for now. Whether we have multiple crews working on a large-scale project, or just a few workers on a small service job, the strategies to protect our workforce, and prevent the spread of the virus, are fairly universal.
- Infectious disease policy development – contractors should establish and document the specific actions each business unit – office, pre-fab, service, construction site etc. – will follow moving forward. Key elements the policy should contain are employee illness response protocol, suspected exposure reporting, means to limit group activities, sanitation procedures and PPE use. OSHA has just released an employer guide #3990 which can help in this process.
- Employee training and education – Effective employee training on policy requirements and employer / client expectations is crucial for work practice uniformity. The training should be documented and repeated as necessary when noncompliant actions are observed in the workplace, or new procedures are introduced. NECA produced a good Coronavirus toolbox talk that can also be used in your overall training efforts.
- Hand washing and overall general hygiene – This cannot be overemphasized with your teams. Construction projects can be dirty and have historically struggled with providing employees suitable toilet and hand washing facilities. As such, frequent hand washing with preferably soap and water, or a sufficient supply of hand sanitizer when soap and water is not available, is critical. Toilets must be cleaned and sanitized more often, including all commonly touched surfaces such as toilet seats and door handles. Sharing of hand and power tools, including arc and shock rated PPE, should be eliminated and when necessary, thoroughly cleaned between uses. Employees should use tissues or their sleeved arm when sneezing and focus on not touching their face.
- Group meetings, crew size and social distancing – Work related activities such as stretch-and-flex, safety meetings, gathering for lunch and breaks are now considered high risk and must be managed accordingly. Current recommendations limit work groups to preferably 10 people or less AND only when the setting allows for social distancing from each other of at least 6 feet. This makes it nearly impossible for 2 workers to be in the same scissor lift, service truck, vault etc. Additionally, employers are directed to maximize work from home protocols for office workers and social distancing for those employees who must remain in the office. If the social distancing option is used, a designated persons(s) should be identified to audit group sizing and effectiveness of minimum spacing protocols.
- PPE use – If your company policy or site-specific requirements do not already mandate donning of safety gloves and glasses, you should implement those actions now. The CDC is currently NOT recommending that healthy people wear respiratory protection such as N95 or half face masks. If employees choose to voluntarily wear such PPE, keep in mind that OSHA requires that they be provided with Appendix D I would also recommend documenting such activity.
As we continue to respond to this rapidly changing event, you are likely to encounter additional site-specific protocols such as pre-screening workers before being allowed onto the job site. The EEOC has recently recognized this activity as acceptable in light of the virus reaching pandemic status.
If you need more information or I can provide assistance in any manner, please contact me.