OSHA: Revised COVID-19 Guidance for Non-Healthcare Industries

COVID-19, Property & Casualty, Risk

On June 10, 2021, the Occupational Safety and Health Administration (OSHA) released new COVID-19 guidance for non-healthcare employers in tandem with their Emergency Temporary Standard (ETS) for COVID-19.

The revised guidance follows in the footsteps of the U.S. Centers for Disease Control and Prevention (CDC), saying that fully vaccinated employees “can resume activities without wearing masks or physically distancing” under most circumstances.

While non-healthcare employers can breathe a sigh of relief knowing that OSHA is no longer calling for them to “take steps to protect their workers from COVID-19 exposure in any workplace, or well-defined portions of a workplace, where all employees are fully vaccinated,” OSHA does state that employers should still consider their options to protect unvaccinated or at-risk workers in their workplaces.

Protecting unvaccinated or at-risk workers under OSHA’s new COVID-19 guidance

Non-healthcare employers can rely on some of OSHA’s guidance to effectively protect unvaccinated or at-risk workers.

Encouraging vaccination

OSHA first recommends that employers encourage employees to get vaccinated (with paid time off to do so), as “a growing body of evidence suggests that fully vaccinated people are less likely to have symptomatic infection or transmit the virus to others.” Once employees are fully vaccinated, employers no longer need to work to take steps featured in this latest COVID-19 guidance.

Maintaining some steps within your COVID-19 prevention program

The steps that were important for employers to implement in order to protect their employees from COVID-19 hold true for unvaccinated and at-risk workers. Review your COVID-19 prevention program and consider maintaining the following OSHA-recommended steps for these workers:

  • Instruct any workers who are infected, unvaccinated workers who have had close contact with someone who tested positive for SARS-CoV-2, and all workers with COVID-19 symptoms to stay home from work
  • Implement physical distancing for unvaccinated and otherwise at-risk workers in all communal work areas
  • Provide unvaccinated and otherwise at-risk workers with face coverings or surgical masks, unless their work task requires a respirator or other PPE
  • Educate and train workers on your COVID-19 policies and procedures using accessible formats and in language they understand
  • Suggest that unvaccinated customers, visitors, or guests wear face coverings
  • Maintain ventilation systems
  • Perform routine cleaning and disinfection
  • Record and report COVID-19 infections and deaths
  • Implement protections from retaliation and set up an anonymous process for workers to voice concerns about COVID-19-related hazards
  • Follow other applicable mandatory OSHA standards

Evaluate measures appropriate for higher-risk workplaces with mixed-vaccination status workers

If your organization is a member of an OSHA-deemed “higher-risk” industry (including manufacturing, meat and poultry processing, high-volume retail and grocery, and seafood processing), you should consider reviewing OSHA’s best practices to protect unvaccinated or other at-risk workers in your workplace, including:

  • Stagger break times in these generally high-population workplaces, or provide temporary break areas and restrooms
  • Stagger workers’ arrival and departure times
  • Provide visual cues as a reminder to maintain physical distancing
  • Implement strategies to improve ventilation

Key Takeaways:

Employers in non-healthcare industries can lighten their COVID-19 prevention plans in environments where all employees are fully vaccinated. However, employers should still consider steps to protect unvaccinated or at-risk employees in their workplace, especially if your organization is considered a “higher-risk” workplace. OSHA provides guidance and best practices for how employers can navigate their specific circumstances.

Please reach out to your M3 Risk Manager for additional information regarding OSHA’s revised guidance.

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