City of Los Angeles Building & Safety Threatens to Shut Down Worksites if New Covid-19 Guidelines are Not Followed


On March 31, 2020, the City of Los Angeles Department of Building and Safety (LADBS) issued “COVID-19 Safety Guidance for Construction Sites.”  The guidelines are based, in part, on the Center for Disease Control’s (“CDC”)’s Interim Guidance for Preparing Workplaces for COVID-19 and OSHA’s Guidance on Preparing Workplaces for COVID-19.

Construction industry employers must develop a comprehensive COVID-19 exposure control plan, which includes control measures such as social distancing, symptom checking, hygiene, decontamination procedures, and training.  The exposure control plan must be followed to prevent the spread of COVID-19 at the worksite because many people with COVID-19 are asymptomatic and can unknowingly spread the disease. Failure to comply with this guidance shall be deemed as creating unsafe conditions and may result in withheld inspections or shutting down the construction site until corrected.

Employers must immediately develop a “COVID-19 Exposure Control Plan” to be distributed and enforced at construction sites within the City of Los Angeles.  The Exposure Control Plan must, at a minimum, address the following:

  1. Practice social distancing by maintaining a minimum 6-foot distance from others.
  2. Preclude gatherings of any size, and at any time two or more people must meet, ensure minimum 6-foot separation.
  3. Provide personal protective equipment (PPE) such as gloves, goggles, face shields, and face masks as appropriate for the activity being performed.
  4. The owner/contractor shall designate a site specific COVID-19 Supervisor to enforce this guidance. A designated COVID-19 Supervisor shall be present on the construction site at all times during construction activities.  The COVID-19 Supervisor can be an on-site worker who is designated to carry out this role.
  5. Identify “choke points” and “high-risk areas” where workers are forced to stand together, such as hallways, hoists, elevators, break areas, and buses and control them so social distancing is maintained.
  6. Minimize interactions when picking up or delivering equipment or materials, ensure a minimum 6-foot separation.
  7. Stagger the trades as necessary to reduce density and maintain a minimum 6-foot separation social distancing.
  8. Discourage workers from using other workers’ phones, desks, offices, work tools, and equipment. PPE, including respirators, may not be shared. To the extent the specialized nature of a tool mandates sharing, the equipment must be cleaned and disinfected before and after use.
  9. Post, in areas visible to all workers, required hygiene practices, including not touching face with unwashed hands or with gloves; washing hands often with soap and water for at least 20 seconds; use a hand sanitizer with at least 60% alcohol; cleaning AND disinfecting frequently touched objects and surfaces such as workstations, keyboards, telephones, handrails, machines, shared tools, elevator control buttons, and doorknobs; covering the mouth and nose when coughing or sneezing as well as other hygienic recommendations by the CDC.
  10. Place wash stations or hand sanitizers in multiple locations to encourage hand hygiene.
  11. Require anyone on the project to stay home if they are sick, except to get medical care.
  12. Have employees inform their supervisor if they have a sick family member at home with COVID-19. Each employer shall take action through their individual human resource departments concerning application of CDC social distancing and quarantine procedures
  13. Maintain a daily attendance log of all workers and visitors.

LADBS staff will verify compliance with the guidelines during regular scheduled inspections for projects under construction as well as during investigations associated with complaints that may be submitted to LADBS.

A well-devised Injury & Illness Prevention Plan (IIPP) should address most of these items.  We issued an Alert entitled Cal/OSHA Issues Interim Guidelines for Protecting General Industry Workers from Exposure to Coronavirus which contains suggestions for your IIPP.  The LADBS Guidelines go further and require “symptom checking” at the worksite which could include the use of a basic health questionnaire and measuring temperatures.  Review our Alert entitled Taking an Employee’s Temperature and Cal/OSHA in the Construction Industry which addresses these issues.  Review your IIPP and update it as necessary to comply with the new LADBS guidelines.  Further, make sure the employees are being trained and the guidelines are being strictly enforced at the worksite for the safety of everyone.  For questions, please contact Jonathan S. Vick at (562) 653-3200.

This AALRR publication is intended for informational purposes only and should not be relied upon in reaching a conclusion in a particular area of law. Applicability of the legal principles discussed may differ substantially in individual situations. Receipt of this or any other AALRR publication does not create an attorney-client relationship. The Firm is not responsible for inadvertent errors that may occur in the publishing process. 

©2020 Atkinson, Andelson, Loya, Ruud & Romo



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