US | COVID-19 | CDC and OSHA Issue Interim Guidance for Manufacturing Workers and Employers

On May 12, 2020, the Centers for Disease Control and Prevention (CDC) and the Occupational Safety and Health Administration (OSHA) issued interim guidance on practices to reduce the risks and spread of COVID-19 in the manufacturing workplace.

The guidance advises manufacturing employers to create a COVID-19 assessment and control plan and appoint a qualified workplace coordinator to assume its related responsibilities. The coordinator must:

  • Be aware of all local, state, and federal COVID-19 regulations applicable to a manufacturing environment
  • Conduct periodic work site assessments to identify COVID-19 risks and prevention strategies

Within the plan, employers should establish controls using the following hierarchy and include practices in the categories described below.

  1. Eliminate a hazard or processes
  2. Install engineering control
  3. Implement appropriate cleaning, sanitation, and disinfection practices to reduce exposure or shield workers

Engineering

Employers should institute the following engineering controls:

  • Configure communal work environments so that workers are spaced at least six feet apart if possible.
  • Modify the alignment of workstations so that workers are at least six feet apart in all direction and do not face each other.
  • Use physical barriers to separate manufacturing workers from each other.
  • Consider consulting with an HVAC engineer to ensure adequate ventilation in work areas.
  • Take steps to minimize air from fans blowing from one worker directly at another worker. Personal cooling fans should be removed, but employers should also be aware of and take steps to prevent heat hazards.
  • Place hand washing stations or hand sanitizers with at least 60% alcohol in multiple locations.
  • Add additional clock in/out stations that are spaced apart to reduce crowding in these areas and consider alternatives such as touch-free methods.
  • Remove or rearrange chairs and tables or add partitions in break rooms.

Administrative

To promote social distancing, employers should employ as many of the following practices as possible:

  • Limit facility access only to essential workers.
  • If meetings must be held, break them into smaller groups instead of larger meetings. Eliminate non-essential meetings.
  • Encourage single-file movement with a 6-foot distance between each worker through the facility.
  • Designate workers to monitor and facilitate distancing on production or assembly line floors.
  • Stagger break times or provide temporary break areas and restrooms to avoid groups of workers during breaks. Workers should maintain at least six feet of distance from others at all times, including on breaks.
  • Stagger workers’ arrival and departure times to avoid congregations of workers in parking areas and locker rooms and near time clocks.
  • Provide visual cues such as floor markings and signs as reminders to maintain social distancing.
  • Encourage workers to avoid carpooling to and from work, if possible.
  • Besides providing workers with access to soap and sanitizers, consider other workplace programs to promote personal hygiene.
  • Workers should be educated to avoid touching their faces until after they have thoroughly washed their hands upon completing work and/or removing PPE.
  • Educate and train workers and supervisors about how they can reduce the spread of COVID-19.
  • Place simple posters in all of the languages that are common in the worker population that encourage staying home when sick, cough and sneeze etiquette, and proper hand hygiene practices. These should be placed in areas where they are likely to be seen.
  • Ensure that frequently touched areas are regularly cleaned and disinfected.
  • Consider developing and implementing a comprehensive screening and monitoring strategy aimed at preventing the introduction of COVID-19 into the worksite.
  • Ensure that personnel managing sick employees are appropriately protected from exposure.
  • If a worker is confirmed to have COVID-19, the employer should instruct fellow workers about how to proceed based on the CDC Public Health Recommendations for Community-Related Exposure guidance document.
  • Reintegrate exposed critical infrastructure asymptomatic workers to on-site operations following CDC Critical Infrastructure Guidance. This guidance advises that employers may permit workers who have been exposed to COVID-19 but remain without symptoms to continue to work provided they adhere to additional safety precautions.
  • Workers with COVID-19 who have symptoms and those that have tested positive should not return to work until they have met CDC’s criteria to discontinue home isolation and have consulted with healthcare providers and state and local health departments.

Personal Protective Equipment

In accordance with 29 CFR 1910 Subpart I, employers must perform a typical hazard assessment to determine whether COVID-19 hazards for which workers need PPE are present. Based on the results of this assessment, employers should require their employees to use the proper PPE and train them in proper use accordingly.

Cloth Face Coverings

CDC recommends that employees wear cloth face coverings as a protective measure in addition to social distancing. This is especially important when social distancing is not possible or feasible. CDC emphasizes that cloth face masks are not PPE.

Employers who determine that cloth face coverings should be worn in the workplace should ensure the cloth face coverings do the following:

  • Fit over the nose and mouth and fit snugly but comfortably against the side of the face
  • Are secured with ties or ear loops
  • Include multiple layers of fabric
  • Allow for breathing without restriction
  • Can be laundered using the warmest appropriate water setting and machine dried daily after the shift, without damage or change to shape (a clean cloth face covering should be used each day)
  • Are not used if they become wet or contaminated
  • Are replaced with clean replacements, provided by the employer, as needed
  • Are handled as little as possible to prevent transferring infectious materials to or from the cloth
  • Are not worn with or instead of respiratory protection when respirators are needed

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Sources:

Manufacturing Workers and Employers Interim Guidance from CDC and the Occupational Safety and Health Administration (OSHA), May 12, 2020.

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