Manufacturers are familiar with OSHA guidelines. OSHA exists to keep shops and employees safe. Now that there’s a new problem, OSHA and the CDC have come out with guidelines for employers to follow. Not all of these guidelines apply to manufacturers and it can be hard to sift through all of the information to find what’s important for your shop. Below are the most relevant parts of the OSHA and CDC guidelines, current as of the time of writing, which apply to manufacturers.
As an employer, your shop has a responsibility to meet OSHA and CDC guidelines to the best of your ability. While it is best to meet all of these guidelines, sometimes it’s impossible. If your shop can’t meet OSHA guidelines, then it’s important that you make a good faith effort. Because of the upheaval from this pandemic, shops may need this now more than ever. Essentially, a good faith effort is when your shop has looked into all possible ways to meet guidelines, looked at all alternatives, and still can’t meet them. It’s also important that your shop has some sort of current plan and a plan to meet those guidelines.
As we learn more about this virus and as our world continues to change, it’s important to keep up-to-date with the guidelines your shop needs to meet. Both OSHA and the CDC have webpages dedicated to the coronavirus. Checking them periodically will help you keep your shop up-to-date. It’s also important to make sure your employees have access to any relevant information from these sites. You could share the websites with them via email, print out important infographics/pages, or use another method to make sure they’re kept in the loop.
Level of Exposure Risk
Different jobs have different levels of risk for COVID-19, as classified by the CDC. Depending on the job your employees do, they are most likely either in the Lower Exposure Risk category or Medium Exposure Risk. The other two categories, High Exposure Risk and Very High Exposure Risk, are mostly for those working in healthcare or mortuaries. Whether your employees are at low or medium risk, it’s important your shop has basic infection prevention measures. Promote handwashing, encourage employees to stay home if they are sick, and routinely clean the shop. It’s worth noting that the CDC also does not consider cloth face masks as personal protective equipment (PPE). They do encourage everyone to wear something over their nose and mouth though. Cloth face masks are adequate for people with lower exposure risk, while those with higher exposure risk need more protection.
Lower Exposure Risk
According to the CDC’s pamphlet “Guidance on Preparing Workplaces for COVID-19”, low exposure risk jobs are “jobs are those that do not require contact with people known to be, or suspected of being, infected with SARS-CoV-2 nor frequent close contact with (i.e., within 6 feet of) the general public. Workers in this category have minimal occupational contact with the public and other coworkers.” This level has less exposure risk, so it needs less protection than other levels. The CDC does not require any additional engineering controls or PPE for this level of exposure. Although they do recommend cloth face masks. However, there are a few administrative controls.
At this level, there are only a few administrative controls. The CDC recommends that employers frequently check the CDC website for updates on COVID-19. They also recommend that employers and employees work together to decide on the best way to share any updates. Then, as the CDC makes updates, employers can communicate these with their employees.
Medium Exposure Risk
For Medium Exposure Risk, the definition is a bit longer. According to the CDC’s pamphlet “Guidance on Preparing Workplaces for COVID-19”: “Medium exposure risk jobs include those that require frequent and/or close contact with (i.e., within 6 feet of) people who may be infected with SARS-CoV-2, but who are not known or suspected COVID-19 patients. In areas without ongoing community transmission, workers in this risk group may have frequent contact with travelers who may return from international locations with widespread COVID-19 transmission. In areas where there is ongoing community transmission, workers in this category may have contact with the general public (e.g., schools, high population-density work environments, some high-volume retail settings).”
Your shop might only fit this category if your employees have to work closely together and/or your employees interact with a lot of visitors. This level of exposure risk has more to account for, so it has more guidelines. These include engineering controls, administrative controls, and PPE.
For this level of exposure, the engineering controls are fairly straightforward. Your shop should have physical barriers where needed. For example, if your shop has a receptionist, you’ll need a barrier between that person and the public. Most places go with a clear, plastic barrier. If your employees work closely together, your shop should put barriers between them as well.
There are more administrative controls for this level of exposure. At this level, the CDC says businesses should:
- Offer facemasks to all customers and employees
- Educate customers about COVID-19 symptoms (through posters in the shop or on phone recording when they call-in). Ask customers to limit interaction with employees until customers are healthy again
- Limit access to the worksite by customers and the general public
- Consider strategies to minimize face-to-face contact with the public through the use of things like a drive-through and telework
- Tell employees about medical screening or other health resources they have
If your shop does not have customers come in, then some of the items on this list aren’t applicable.
Personal Protective Equipment
At this level of exposure risk, the CDC recommends some level of PPE. What workers need is determined by the type of task. For a job shop, it’s not likely they’ll need much. However, as the CDC’s pamphlet says, “Workers with medium exposure risk may need to wear some combination of gloves, a gown, a face mask, and/or a face shield or goggles. PPE ensembles for workers in the medium exposure risk category will vary by work task, the results of the employer’s hazard assessment, and the types of exposures workers have on the job.”
When you’re thinking about PPE, it’s important to think about the function. If it’s functional, how easy it is to decontaminate, how it would be disposed of, and the cost. Disposable PPE is cheaper than reusable PPE per piece. However, if your employees would need to wear it for long periods of time and would need multiple pieces of disposable PPE, then it might be worth it to get reusable PPE and clean it in between uses. The final thing to consider about PPE is taking it off and putting it on. When employees take off or put on PPE, they need to be sure it’s done correctly and that they don’t contaminate it or themselves. The CDC made a video so that everyone can see how to put on and remove PPE correctly. If your employees need PPE, it’s probably a good idea to share this video.
Depending on what level of exposure your employees have, there can be a lot to consider when following the CDC and OSHA guidelines. However, it all boils down to keeping your employees safe so they can do their jobs well. Also, making sure they stay home if they’re sick. These guidelines give your shop some concrete ways to do that in the face of the pandemic, and they’ll help keep your shop open and running.