Is Your Company COVID Safe?

Given the recent spike in COVID-19 infections across the country, we decided to re-post this vital infographic we created to illustrate the key aspects of an Infections Disease Response Plan.

The plan contains combined guidance from both OSHA and CDC and is designed to help employers control workplace COVID-19 infections.

You can find more related information and guidance below the infographic.

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Please include attribution to Berg Compliance Solutions with this graphic.

Are You Doing Everything Possible to Make Your Company Safe From COVID-19 Infections & Risks?
- Most employers don’t realize that in order to make their company safe from COVID, they must develop & manage a comprehensive Infectious Disease Response Plan.
- Most companies are implementing “bits and pieces” of the plan, like using social distancing and face masks, but there’s much more to be done.
- This Infographic will explain the basic plan requirements & how it can help protect your business, employees & customers from COVID-19 related harm.
Here’s What We’ll Cover:
- What is an Infectious Disease Response Plan? A Preview
- Risks & Liabilities Associated With Failing To Develop A Plan
- Critical OSHA Laws & Standards You Need to Know About
- How To Build An Infectious Disease Response Plan
What is An Infectious Disease Response Plan?
- It’s primarily made up of OSHA and CDC guidance, recommendations and laws.
- The plan requires an overall risk assessment of the business
- Implementation of a long list of engineering, administrative and PPE measures & controls to address workplace infection risks
- Bonus: the plan can address any future pandemic, not just COVID
What Risks Do You Face for Not Developing & Managing A Plan?
- OSHA fines and penalties: OSHA is currently focusing their enforcement efforts towards COVID Employee Complaints.
- Company outbreaks which could shut down your business
- Bad Press & reputation damage
- Potential Civil Liability

Critical OSHA Laws & Requirements You Need To Know About:

OSHA’s “General Duty Clause” states that workplace COVID-19 infections are a “recognized hazard” which employers must assess and control.
Employers should focus on how their employees could be exposed to infected people or environments, materials, and surfaces contaminated with COVID.
Once exposures are known, employers should implement policies and procedures to eliminate or reduce risk of exposures. This often triggers other OSHA laws as described below.
- Personal Protective Equipment Standard (“PPE”) Includes:
  - Draft Written Program
  - Selection & provide appropriate PPE
  - Conduct Job Task Hazard Assessments
  - Develop and Deliver Customized Employee Training & Document
  - Illustration: Did You Know That Face Masks Aren’t Considered PPE?
- Respiratory Protection Standard Includes:
  - Draft Written Program
  - Select & provide appropriate respirators
  - Conduct medical evaluations & fit tests
  - Develop and Deliver Employee Training & Document
- OSHA 300 Logs:
  - Employers must track and report all work related COVID-19 infection on OSHA 300 logs
  - Post OSHA 300 Logs Annually
  - Certain Industries Must Electronically Submit OSHA 300 Logs
- Whisteblower Protection:
  - Employers cannot retaliate against employees to complain to OSHA about safety related work conditions, including COVID complaints.
- OSHA Enforcement:
  - Employers who fail to manage these laws face huge fines that can run into the $10s or $100s of thousands of dollars.
  - OSHA will evaluate if violating employers evaluated all compliance options, including virtual professional assistance and training.

How To Build An Infectious Disease Response Plan:

Step 1: Assess Your Company Risks
- Occupational Infection risks increases as follows: (MOVED From Above)
  - Gatherings of employees & customers in close proximity (< 6’), including work areas, for training & meetings.
  - Poor airflow/ventilation
  - Business travel:
    - Air travel
    - Travel to infection “hot spots”
    - Travel to customer and vendor locations
  - Exposure to contaminated materials
  - Exposure to customers and visitors\

Once company risks have been assessed, develop a customized Infectious Disease Response Plan to address them. (MOVED from Above)

- The Plan Should Focus On A Variety of Control and Prevention Measures
- Measures include a combination of engineering, administrative, safe work practices and PPE use.

Illustration: A person wondering about what all of this means.

Control Measure Option Examples:
- Engineering Controls:
  - Installing barriers, floor markings, increasing air ventilation, filters, signage
- Administrative Controls:
  - Training, staggering shifts, symptom reporting procedures
- Safe work practices:
  - Frequent hand washing, cover face when coughing or sneezing, social distancing (>6’)
- Personal Protective Equipment (PPE):
  - Respirators, face shields, gloves, goggles
  - **Cotton face masks AREN’t PPE!!**
- NEVER FORGET THAT PPE SHOULD BE THE LAST LINE OF PROTECTION!

OSHA strongly recommends that employers assign 4 categories of risk level and then take action to control each:
- Review all company job tasks and assign each to one of the 4 risk categories
- Implement specific control measures for each risk category, including engineering, administrative, safe practices and PPE

Other Key CDC & OSHA Guidance & Recommendations:

- Include State & Local Requirements:
  - Many local governments are issuing their own laws & requirements
  - Mandatory face mask use for employees & customers
  - Mandatory infection reporting
  - Criminal enforcement authority
  - Illustration: Business owner scanning computer screen.
- Disinfecting & Sanitization Procedures:
  - Develop plan for routinely cleaning common surfaces including desktops, guardrails, keyboards, door handles, etc.
  - Train assigned employees & provide PPE
  - Only use EPA approved disinfectants
  - Enhanced decontamination if employee tests positive at work.
- Employee Training:
  - Train staff on potential exposures and risks
  - Include relevant company policies and procedures
  - PPE use
  - Infection Reporting & Management:
    - Develop policies and procedures to quickly identify and isolate sick employees
    - Screen employees for symptoms.
    - Symptomatic staff should stay home and not return to work until all symptoms have ceased for at least 24 hours.
    - Maintain flexible and compliant policies to deal with sick leave, care for family members, etc.

Plan for potential widespread Covid-19 outbreak:
- Companies should begin planning for varying levels of outbreak severity.
- CDC offers detailed planning guidance which we will not attempt to summarize here. We encourage employers to review and act on this guidance in the event that the coronavirus reaches severe levels resulting in long term, major business and economic disruption.
Increase Building Air Exchange & Ventilation:
- Several agencies are now recommending increased air exchanges to dilute potential infected microdroplet exposures.
- Modify HVAC systems to increase outdoor air exchanges
- Install HEPA filters
- Open windows
- Small Businesses Face Major Challenges managing COVID-19 requirements & risks
  - Key challenges include lack of:
    - Expertise
    - Time
    - Resources

We’ve responded to these challenged by offering a new set of Workplace COVID-19 Safety Services to help companies manage these risks and requirements. Checkout the services or give us a call for a free consultation at 512-457-0374

By Russell Carr|2020-11-10T16:33:55-05:00July 1st, 2020|Good To Know|Comments Off

About the Author: Russell Carr

How A Sales Guy Transformed Into An Environmental, Health & Safety Expert & Advocate For Small Businesses I've spent my entire 30+ year career working within the manufacturing and “industrial services” sectors. The first 15 years of my career focused on sales of hazardous materials related products and services to the manufacturing sector, then for the last 16+ years transitioned into entrepreneurship, founding 3 small industrial services related contracting businesses. As you’ll see below, running these companies eventually lead me to found yet a 4th business, but more on that in a minute…. Here’s a brief description of the first 3 companies: Berg Environmental Services, Inc.: hazardous waste disposal & transportation services, founded in August of 2003 3rd party wind energy operations & maintenance services provider to utility scale wind farms throughout the US, founded in September 2007 3rd party oil & gas exploration & production services provider, founded in August of 2011 Each of these companies operated in extremely dangerous working conditions and exposed my employees to a wide range of serious health & safety hazards on a daily basis. To complicate matters, 2 of the companies also exposed the environment to significant potential harm. In other words, I learned very early the critical importance of managing environmental, health and safety issues so as to ensure the safety of our employees and the environment, as well as minimizing related risks. But I also learned how incredibly difficult and challenging this endeavor can be due to the wide range of complicated and continually changing environmental, health and safety rules and regulations that impacted the companies. To summarize the challenges: First I had to determine which regulations applied to each company, then I had to build compliance programs to meet those regulations, and finally I had to ensure that the programs were being managed and followed by our staff on a daily basis. All while trying to run and grow 3 profitable businesses…. It was overwhelming and I always struggled to keep up. To make matters worse, throughout this time I also witnessed the devastating price that companies, management and ownership can pay for failing to manage EHS compliance. This included seeing one of my hazardous waste management clients get sent to jail over environmental issues, another client’s management team threatened with jail time, a direct competitor get fined $378,000 by OSHA fine after an employee was nearly killed, and many others face major fines and penalties. Full disclosure, one of my companies got fined by OSHA at one point, & another was cited by TCEQ, so I know how it feels. In summary, I learned first hand how incredibly difficult it is for small companies to manage EHS compliance due to a common lack of the critical expertise, time and resources that are needed to keep up, and how this situation then ends up exposing them to these potentially catastrophic risks that can literally destroy lives and businesses. This later inspired me to found my 4th company, Berg Compliance Solutions in 2012, which is dedicated to helping other small businesses, and business owners, to manage EHS compliance and risk. Education BA, Philosophy, University of Colorado, Boulder, December, 1990. Summary of Professional Experience & Qualifications: 30+ years serving the manufacturing & industrial services sectors 30+ years of sales and marketing experience 16+ years as small business owner & entrepreneur: Founded and operated 4 small businesses since 2003. Environmental, Health & Safety Compliance & Program Related: 19 plus years of hazardous waste management including EPA, TCEQ & RCRA regulations 8 years of DOT/FMCSA compliance experience, including hazardous materials transportation 8 years of combined experience implementing and managing OSHA health and safety compliance programs for 2 high risk energy services businesses Successfully implemented and gained ISO 9001 Quality Management Certification and OHSAS 18001 (Occupational Health & Safety Advisory Service) Certification for wind energy maintenance business. Regulatory Enforcement Related Experience: Served as expert witness in criminal environmental compliance enforcement cases Superfund-CERCLA OSHA enforcement inspections, investigations and resolution in following industries: industrial services, manufacturing & construction. TCEQ enforcement inspections, investigations and resolution in manufacturing.

Is Your Company COVID Safe?