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US | COVID-19 | OSHA Issues Interim Enforcement Response Plan
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- #Occupational Safety and Health Administration (OSHA)
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On April 13, 2020, the Occupational Health and Safety Administration (OSHA) issued an interim enforcement response plan for COVID-19. This…
On April 13, 2020, the Occupational Health and Safety Administration (OSHA) issued an interim enforcement response plan for COVID-19. This plan clarifies how OSHA is prioritizing workplaces with high and very high exposure to suspected sources of SARS-CoV-2 for inspection.
Directed to OSHA’s Area Offices and compliance safety and health officers (CSHOs), the plan provides instructions and guidance for handling COVID-19 related complaints, referrals, and severe illness reports. It also gives employers additional guidance on what to expect from OSHA in the face of this pandemic.
When processing COVID-19-related complaints and conduct investigations, CSHOs and Area Offices are directed to focus on jobs with high and very high exposure to suspected sources of SARS-CoV-2. The workplaces identified are generally in the health care industry. Area Offices are instructed to process complaints from non-healthcare and non-emergency response establishments as “non-formal phone/fax.” Performing in-person inspections on these types of facilities should be avoided as much as possible. The memo also indicates that OSHA will be tracking all COVID-19 activity in the OSHA Information System with the specific code of N-16-COVID-19.Requirements for High and Very High Exposure Workplaces
OSHA inspectors will review the following documents and processes during inspections of high and very high exposure workplaces:- Pandemic plans recommended by CDC
- Hazard assessment protocols for PPE use with suspected or confirmed COVID-19 patients
- Medical records related to employee exposure incidents
- Whether the facility has handled contaminated specimens of COVID-19
- The facility’s respiratory protection program
- Employee training records
- Whether the employer has implemented a hierarchy of controls for worker protection
- 29 CFR § 1904 | Recording and Reporting Occupational Injuries and Illness
- 29 CFR § 1910.132 | General Requirements – Personal Protective Equipment
- 29 CFR § 1910.133 | Eye and Face Protection
- 29 CFR § 1910.134 | Respiratory Protection
- 29 CFR § 1910.141 | Sanitation
- 29 CFR § 1910.145 | Specification for Accident Prevention Signs and Tags
- 29 CFR § 1910.1020 | Access to Employee Exposure and Medical Records
- Section 5(a)(1) | General Duty Clause of the OSH Act
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