To reduce the impact of COVID-19 or coronavirus outbreak conditions on business, workers, customers, and the public, it is important for employers to take steps now. Lack of planning can result in a cascade of failures as employers attempt to address challenges of COVID-19 with insufficient resources and workers who might not be adequately trained for jobs they may have to perform under pandemic conditions.

This guidance is intended for planning purposes. Employers and workers should use this planning guidance to help identify risk levels in workplace settings and to determine any appropriate control measures to implement. For the most up-to-date guidance as COVID-19 outbreak conditions change, refer to the Resources listed below.

How COVID-19 could affect workplaces

  • Occupational exposure. Historically, patients with infectious diseases are unlikely to seek routine and elective medical and dental care. However, if you’re a healthcare or dental professional, due to the nature of your work closely interacting with others, and of course if you are directly involved in treatment of COVID-19 patients, there is increased potential of occupational exposure. 
  • Absenteeism. Workers could be absent because they are sick; are caregivers for sick family members; are caregivers for children if schools or day care centers are closed; have at-risk people at home, such as immunocompromised family members; or are afraid to come to work because of fear of possible exposure. 
  • Change in patterns of commerce. Consumer demand for items relating to infection prevention (e.g. respirators) is likely to increase significantly. Consumers may also change shopping patterns such as shopping at off-peak hours, increase interest in home delivery, drive-through options, etc. to reduce person-to-person contact.
  • Interrupted supply/delivery. Shipment of items from geographic areas severely affected by COVID-19 may be delayed or cancelled with or without notification.
  • Business operations limitations or closure. Due to government directive or personal decision, you may decide to limit your business operations or close doors completely in favor of a work-from-home policy.

Steps all employers can take now

Develop an exposure control and response plan

If you don’t already, you should have an exposure control plan for your workplace. The ECP is your standard operating procedure for protecting against pathogens including COVID-19. In addition to OSHA mandated provisions for the ECP, stay abreast of guidance from federal, state, local and territorial health agencies, and consider how to incorporate those recommendations and resources into your workplace-specific plans. Your plans should consider:

  • Where, how, and to what sources of COVID-19 workers may be exposed, including:
    • The general public
    • Sick individuals
  • Workers’ individual risk factors
    • Older age
    • Chronic medical conditions
    • Pregnancy, etc.
  • Controls necessary to address those risks
    • Engineering controls 
    • Work practices
    • Personal protective equipment

Basic infection prevention measures

For most employers and especially for health, dental and veterinary care providers good hygiene and infection control practices should be implemented in the workplace. Many of these measures have been thoroughly covered in the media following the COVID-19 outbreak but they bear repeating here:

  • Frequent and correct handwashing. 
  • Encourage workers to stay home if they are sick.
  • Good cough etiquette and respiratory hygiene including covering coughs and sneezes.
  • Providing customers and patients tissues, no-touch trash cans, face masks, etc. as appropriate for your workplace setting.
  • Social distancing, flexible worksite / work hour policies.
  • Discourage sharing of work tools and equipment like phones, desks, etc. where possible.
  • Regular housekeeping including cleaning and disinfecting of the work environment.

Develop policies and procedures for the prompt identification and isolation of sick people

  • While patients with infectious diseases are not expected to seek routine medical or dental care, prompt identification and isolation of potentially infectious individuals is an important step in protecting all people at a worksite.
  • Encourage self-monitoring and a procedure for employees to report symptoms of COVID-19.
  • Isolate potentially infectious people. Although most worksites do not have specific isolation rooms, designated areas with closable doors may serve as isolation rooms until potentially sick people can be removed from the worksite. If possible, separate suspected and confirmed COVID-19 cases.
  • Provide a face mask, if feasible and available, to persons suspected of having COVID-19.
  • Restrict the number of personnel entering isolation areas.
  • OSHA has developed risk levels for workers depending on the nature of the job being performed. Based on risk classification, additional precautions may be required. See a future blog post for more information on this. 

Develop workplace controls

OSHA has a framework called “hierarchy of controls” to prioritize ways of controlling workplace hazards. The below graphic lists the different potential control mechanisms.


Source: https://www.cdc.gov/niosh/topics/hierarchy/default.html

Elimination

Physically removing the hazard is the most effective hazard control. For example, if employees must work high above the ground, the hazard can be eliminated by moving the piece they are working on to ground level to eliminate the need to work at heights.

Substitution

Substitution, the second most effective hazard control, involves replacing something that produces a hazard (similar to elimination) with something that does not produce a hazard—for example, replacing lead-based paint with titanium white. To be an effective control, the new product must not produce another hazard. 

With an outbreak, it isn’t always practical to eliminate or substitute a hazard. So the most effective protection measures (from most effective to least effective) are engineering controls, administrative controls and then personal protective equipment or PPE. 

Engineering Controls - reducing exposure to hazard without relying on worker behavior

  • High-efficiency air filters
  • Increasing ventilation rates in the work environment
  • Physical barriers such as clear plastic sneeze guards
  • Airborne infection isolation rooms (specialized negative pressure ventilation)

Administrative Controls - changes to work policy or procedures to reduce or minimize exposure to hazard

  • Encouraging sick workers to stay at home
  • Minimizing contact among workers and patients/customers
  • Reducing and alternating employee shifts
  • Providing resources and a work environment that promotes personal hygiene like providing tissues, no-touch trash cans, hand soap, alcohol-based handrub (at least 60% alcohol), etc. 
Personal Protective Equipment - last line of defense in protecting employee from hazard

While using PPE correctly can prevent some exposures, it should not be used without the other prevention strategies listed above. PPE is considered to be “performance-oriented” i.e. the equipment used must suit the job function being performed. While PPE determination is generally made by the employer, OSHA and the CDC have issued some guidance on recommended PPE for the COVID-19 outbreak. 

OSHA has developed risk levels for workers depending on the nature of the job being performed. Based on risk classification, specific personal protective equipment may be required. [See a future blog post for more information on this.] 

Who needs to use a respirator?

  • It’s important to note here that workers including those who work within 6 feet of patients known or suspected of having COVID-19 need to use respirators. 
  • Examples of such workers are healthcare and dental professionals, laboratory personnel, morgue and mortuary workers, healthcare delivery and support staff, and medical transport workers. 
  • There are several types of respirators but the minimum type that should be used is the n95 filtering facepiece respirator in the context of a comprehensive, written respiratory protection program.

For more information

With the situation evolving day-by-day, government directives and recommendations are also changing frequently. It can be overwhelming to keep up with all the information and difficult to know where to look for the right steps to take. We’ve designated this area of our blog to post important updates and share key resources and guidelines you need to best protect your employees and yourselves. 

In addition to checking this area of our blog, follow us on social media to receive notifications when we share important information. 

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Ultimately, federal, state, and local government agencies are the best source of information in the event of an infectious disease outbreak. Check out the resources below for the latest developments and guidance. Also be sure to check your state medical, dental or veterinary boards (as applicable) for guidance on things like seeing patients, practice closure directives, and more.

Resources

  • Centers for Disease Control and Prevention COVID-19 webpage: www. cdc.gov/coronavirus/2019-ncov 
  • OSHA COVID-19 webpage: www.osha.gov/covid-19 
  • OSHA Guidance on Preparing Workplaces for COVID-19: OSHA Publication OSHA 3990-03 2020 
  • National Institute for Occupational Safety and Health COVID-19 webpage: https://www.cdc.gov/niosh/emres/2019_ncov.html