The Occupational Safety and Health Administration (OSHA) issued a COVID-19 emergency temporary standard (ETS) with which healthcare employers will be required to comply. This ETS includes an outline and description for an effective COVID-19 plan designed to reduce injuries and illnesses in healthcare workplaces. A COVID-19 plan is essential to responding to COVID-19 hazards in an effective manner. These safety and health programs must proactively and constantly identify and mitigate hazards before employees develop illness or injury in order to be truly effective. In the case of COVID-19 hazards in healthcare settings, this includes identifying employees at risk of exposure to the virus and developing ways to protect them. This type of approach helps employers meet their obligation to provide a safe workplace under the OSH Act. The ETS requires a COVID-19 plan that contains the main components of this kind of safety and health program. According to the ETS OSHA released, there are studies showing that these programs are positively impacting the safety, health, and performance of healthcare workers.
OSHA has identified seven core elements of a successful safety and health program. These are:
- Management Leadership – establish a safety plan, communicate it to all employees and assign a coordinator to track the progress.
- Worker Participation – train employees to recognize hazards and develop open communication to use their expertise and insight to identify and address hazards. This is the most important.
- Hazard Identification & Assessment – use a team approach to identify hazards. Observe work habits and evaluate employee input from surveys or meetings to determine if, where, and how workers could be exposed and if there are safeguards in place to reduce those risks.
- Hazard Prevention & Controls – assess if hazards can be eliminated (e.g. work from home) and when they cannot be, consider how the risks may be reduced (e.g. disinfecting, social distancing, physical barriers, ventilation).
- Evaluation and Improvement – evaluate regularly to make sure the plan is implemented as intended, continue to identify new hazards, and make improvements where necessary.
- Coordination & Communication at Multi-Employer Sites – in some settings, employees may travel from one site to another, possibly exposing employees of a different location. Communicate with all affiliated employers to review your plans and to share information on reported hazards and illness.
- Education & Training – ensure that all employees are able to recognize hazards and know the procedures for addressing them. Establish ways for employees to contribute to the safety and health plan.
In addition to the COVID-19 plan, the ETS also requires that covered employees:
- Clean and disinfect the workplace.
- Screen employees for symptoms of COVID-19 and follow requirements for removing potential infected employees from the workplace.
- Ensure social distancing.
- Screen patients upon arrival.
- Report COVID-19 hospitalizations and fatalities.
- Provide reasonable time off and paid leave for COVID-19 vaccinations.
Occupational Exposure to COVID-19; Emergency Temporary Standard, 29 C.F.R. §1910.502. (June 21, 2021).