OSHA has recently released a set of guidelines for Covid-19 related violations including a listing of the most common citations that employers have faced during Covid-19 related inspections. In this post, we’re detailing everything you need to be aware of to avoid these citations and keep your employees safe during the Covid-19 pandemic.
Most Common Covid-19 Violations
The most common Covid-19 related violations revolve mostly around respiratory protection, personal protective equipment, and recordkeeping procedures. Follow these guidelines to avoid getting cited by OSHA.
- Medical Evaluation: Be sure to provide a medical evaluation before an employee is fit-tested or uses a respirator. Make sure the medical evaluation is complete and is not missing any of the required information. You’ll also want to create appropriate fit test records.
- Fit Testing: If a respirator has a tight fitting face piece, be sure to perform an appropriate fit test. This should be done before the respirator is used for the first time or even when a different face piece model, size, or style is used. After the first fit test, it should be completed annually.
- Respiratory Protection Program: Be sure to create, implement, and maintain a documented respiratory protection program that includes worksite specific procedures. This should also detail procedures for fit testing, medical evaluation, and regular evaluation of the program. Also be sure to assign a dedicated program administrator to implement and maintain the respiratory safety program.
- Training and Information: It’s very important to consistently train employees on the proper use of respirators, as well as continuously retrain as needed when changes occur. Each employee should be able to demonstrate basic understanding of how to use the respirator, its limitations and capabilities, and standard operating procedures. This training must be done before an employee uses a respirator. If you determine that respirators can be used voluntarily, be sure to provide employees with the mandatory information on the use of respirators when not required under standard.
- General Requirements: Always provide a NIOSH-certified respirator and ensure that it is the appropriate respirator for the hazard.
- Permissible Practice: When necessary, always provide an appropriate respirator to each employee to protect them from respiratory hazards.
- Maintenance and Care of Respirators: Always make sure respirators are stored safely and properly so as not to deform the face piece and avoid damage and contamination.
Personal Protective Equipment
- Hazard Assessment and Equipment Selection: You’ll want to assess the workplace to determine if there are any hazards present or have the potential to become present. Make sure this assessment is properly documented in writing. Then select the appropriate personal protective equipment (PPE) for each employee, and ensure that it fits each employee properly.
- Application: Always provide PPE that is in good sanitary condition.
- Training: Make sure to train each employee that is required to use PPE.
- Reporting: For any fatality that occurs within 30 days of a work-related incident, report the fatality to OSHA within 8 hours of finding out about it. OSHA should also be notified if an employee is admitted to the hospital for treatment.
- Recording Criteria: Keep required records of work-related fatalities, injuries, and illness. Under OSHA’s recordkeeping requirements, COVID-19 is a recordable illness, and thus employers are responsible for recording cases of COVID-19, if:
- The case is a confirmed case of COVID-19, as defined by the CDC
- The case is work-related
- The case involves one or more of the general recording criteria
General Duty Clause
It is the general responsibility of the employer to provide a workplace that is free from hazards for its employees. In order to meet this requirement, employers must establish procedures in the workplace to protect their employees from potential Covid-19 hazards by implementing standards such as social distancing or installing plastic barriers.
I hope this information was helpful to clarify the most common OSHA citations related to Covid-19. We are doing our best to stay up to date with Covid-19 regulations as they are being developed. If you have any questions or need assistance with your safety program or OSHA compliance, contact us today.