OSHA’s General Duty Clause requires that employers provide employees with a workplace free from recognized hazards likely to cause death or serious physical harm. To that end, OSHA’s guidance suggests employers should consider the following levels of risk associated with various worksites and job tasks:
- Where, how, and to what sources of COVID-19 might workers be exposed: general public, customers, or coworkers
- Non-occupational risk factors at home and in the community
- Workers’ individual risk factors (e.g., older age, presence of chronic medical conditions, immunocompromising conditions, pregnancy)
In addition, OSHA further recommends that employers plan and prepare for the following in the event they result in the necessity of certain contingencies:
- Increased rate of worker absenteeism
- The need for social distancing, staggered work shifts, downsizing operations, delivering services remotely, and other exposure-reducing measures
- Options for conducting essential operations with a reduced workforce
- Interrupted supply chains or delayed deliveries
OSHA recommends using a framework called the “hierarchy of controls” to select ways of controlling workplace hazards, which suggests the best way to control a hazard is to systematically remove it from the workplace, rather than rely on workers to reduce their exposure. Where impossible or impractical to remove the hazard, employers should utilize the following protective measures (listed from most effective to least effective):
- Engineering controls, which involve isolating employees from work-related hazards to reduce exposure without relying on worker behavior, and could include installing high-efficiency air filters, increasing ventilation rates in the office, installing physical barriers, etc.
- Administrative controls, which require action by the worker or employer, often representing a change in work policy or procedures to reduce or minimize exposure, and could include encouraging sick workers to stay home, minimizing contact among workers, replacing face-to-face meetings with virtual communications, establishing alternating days of work to reduce the total number of employees in the office at a given time, discontinuing nonessential travel, providing workers with up-to-date education and training on COVID-19 risk factors and protective behavior, etc.
- Safe work practices, which are types of administrative controls that include procedures for safe and proper work used to reduce the duration, frequency or intensity of exposure to a hazard, and could include providing resources and a work environment that promotes personal hygiene by providing tissues, no-touch trash cans, hand soap and sanitizer, and posting handwashing signs in restrooms and other high-touch areas throughout the office.
- PPE, meaning “personal protective equipment”, may be advisable for certain high-touch or higher-risk work environments or tasks, and could include providing gloves, face shields or face masks, and other PPE, when appropriate.
The IMT Loss Control Department has resources available to help our agents and policyholders in their efforts to reduce exposures and injuries while promoting safety at the workplace and in the home. We have a host of online, streaming and on-demand tools at our disposal to consult and work with you. Please contact your local IMT Agent if you think could benefit from additional information or education and training materials.
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