Covid Compliant Check List and List of Resources for Your Business
As business managers, we all want to be proactive and provide a safe workplace. As an employer, you also have clear and defined legal obligations to “provide a place of employment free from recognized hazards that are causing or are likely to cause death or serious physical harm to employees.” This broad-scope statement is from the OSHA General Duty Clause which is about as encompassing a legal requirement as can be levied against your company, and failing a full COVID policy and procedures, this will be where your citation will likely originate.
In today’s world, you must consider formal policies on concealed firearms, CBD use (which are now legally prescribed by physicians to your employees), and legalization of Marijuana and its use in the workplace. These are all new conditions we are struggling to understand and provide for. Add to this mix the threat of the Corona Virus and you have a concerning set of conditions threatening your organization’s profitability and perhaps its very existence.
Let’s focus on the most likely current threat - COVID-19. Here is a handy list of questions for you to review:
Do you know your legal responsibility to protect employees from workplace exposure to COVID-19 under OSHA regulations?
Have you conducted a hazard assessment of the workplace to identify the high-risk job functions?
What policy statements have you made (and published/posted) at your company to advise your employees on your plans and procedures to protect your workplace and employees? We are not talking about inter-office memos or postings. Full-on policy statements are needed.
What cleaning/sanitation protocols have you implemented to prevent the spread of COVID-19?
Do you know if you are obligated to report positive cases of COVID-19 on your OSHA 300 log? And, how do you legally determine the case IS work related?
If you have a positive COVID test in your workplace, what is your new policy regarding return-to-work authorization?
What Engineering, administrative and work practice controls should be introduced/required to prevent the spread of COVID-19? Example: are you cleaning the contact points on Material handling equipment (Power Industrial Trucks/pallet jacks, man-lifts, booms), any shared fall protection equipment or hand tools? How about telephones, water fountains, restroom facilities and all dispensing machines?
Are you being more aggressive with your HVAC filtration systems and changing filters?
Are you obligated to provide special PPE to your employees?
Have you issued requirements to your employees to self-quarantine if they or a family member is ill or showing COVID- like symptoms?
While this list is certainly not all-inclusive, we hope it contributes to your effort to be as pro-active as possible. When you start your research, know that OSHA, the CDC and World Health Organizations have volumes of information to assist you in your efforts.
The OSHA pdf on COVID: https://www.osha.gov/Publications/OSHA3990.pdf
The CDC site: https://health.mo.gov/living/healthcondiseases/communicable/novel-coronavirus/
World Health Organization’s Dashboard on COVID: