Cal/OSHA Issues Guidance for COVID-19 Infection Prevention in Construction

05.04.2020

On April 24, 2010, Cal/OSHA issued Safety and Health Guidance COVID-19 Infection Prevention in Construction to prevent the spread of COVID-19 for the construction industry.  The guidance does not impose any new legal obligations. It does, however, contain information on how employers can update their Injury and Illness Prevention Program (IIPP) to protect employees from infectious diseases in the worksite.  It contains information on employee training and preventing the spread of coronavirus (SARS-CoV-2), the virus that causes COVID-19, at the construction site. This is mandatory in most California workplaces since COVID-19 is widespread in the community.  The following is a summary of the recommendations.

Train Employees on COVID-19

Employers must provide training in a form that is readily understandable by all employees on the following topics:  Information from the Centers from Disease Control (CDC) about the virus and how it is spread, the importance of good hygiene, social distancing and the use of cloth face coverings. Cloth face coverings are not personal protective equipment (PPE) and do not protect a person wearing them, however they can protect those nearby.  Cal/OSHA does not require the use of cloth face coverings but states employers should provide these coverings for their own employees or at least encourage them to use their own.  Employers should designate a site-specific COVID-19 officer at every jobsite to observe and ensure site workers are implementing what they have been trained to do.

Increase Cleaning and Disinfection

Employers must establish and implement the following procedures to help prevent the spread of COVID-19: make hand-washing stations more readily available and encourage their use, allow employees time for hand-washing, clean and disinfect the jobsite and ensure adequate cleaning supplies are available.

Increase Physical Distancing

Physical distancing, also referred to as social distancing, is an infection control measure that can stop or slow down the spread of an infectious disease by limiting contact between people.  Employers should implement measures to create space between employees by staggering shifts, limiting the number of employees in elevators, holding meetings electronically, avoiding large meetings, and using engineering controls such as barriers between workers and face coverings.

Ensure Good Hygiene Practices

Employees should have access to hand-washing facilities and employers should provide time for employees to thoroughly and regularly wash their hands. Any PPE worn to protect employees from hazards must be washed and/or sanitized before use.  Cal/OSHA notes that health experts do not recommend the use of respirators by the general public for protection from COVID-19 but should be worn if necessary to protect against other respiratory hazards.

Implement Safe Work Practices

Employees should be encouraged to limit the sharing of tools.  If tools must be shared then try to group them to be used by people who reside together or travel to work together.  Workers should avoid carpooling unless they already live together. If carpooling cannot be avoided then workers should create as much space as possible and wear face coverings and wash hands after the trip.

What to do with Workers who might be sick with COVID-19

Cal/OSHA is recommending that employees who are sick stay home and employees who are well but who have a sick family member at home with COVID-19 should notify their supervisor and follow CDC-recommended precautions.  Employers can implement health screening which includes measuring temperatures and provides guidance for employee protection.  Cal/OSHA provides limited guidance on what employers should do if an employee tests positive.  The employer is directed to report this to local health officials and the local health officials will help the employer determine a course of action.. There is no recommendation to inform other employees or to take any steps to quarantine employees who worked in close proximity to an infected employee. 

If you have any questions or need assistance with health and safety issues please contact Jonathan S. Vick at jvick@aalrr.com

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. 

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