OSHA announced the launch of a National Emphasis Program (NEP) to protect workers in high hazard industries from COVID-19. The NEP is effective immediately and will remain in effect through March 12, 2022. The NEP will augment OSHA’s efforts of conducting unprogrammed OSHA inspections of those targeted “high hazard” or “high-potential of exposure” industries. While the healthcare industry is the NEP’s primary target, OSHA includes construction as a secondary-targeted industry. Two important notes:
- The NEP does not establish a federal OSHA COVID-19 standard, which means OSHA will continue utilizing existing standards such as respiratory, PPE and sanitization standards and general-duty clause for COVID-19 related hazards.
- The NEP includes an added focus to ensure that workers who complain about unsafe or unhealthful conditions are protected from retaliation. These protections are covered under the Whistleblower Protection Program.
Potential Action Steps for Signatory Contractors
Construction employers can expect OSHA to ensure they are following CDC recommendations during these COVID-19 NEP inspections. The following are steps signatory contractors could take to help prevent potentially costly fines:
- Actively monitor OSHA, CDC and other public health agencies for updates to COVID-19 recommendations.
- Perform a hazard assessment for potential COVID-19 hazards.
- Sample COVID-19 Risk Assessment Form (direct download)
- (Note – Hazard Assessment and Hierarchy of Controls are part of the FCA International COVID-19 Exposure Control Plan)
- Use face coverings or masks throughout the workplace.
- Actively encourage sick employees to stay home.
- Accommodate employees through social distancing or telework (if possible).
- Emphasize proper respiratory etiquette and hand hygiene by al employees.
- Perform routine environmental cleaning.
- Conduct periodic inspections to ensure management and the workforce understand and are following the current COVID-19 control measures in place.
- Educate project or site-management on how to handle OSHA inspections, specifically using the conference as a way to confirm (or not) that the inspection falls within the COVID-19 NEP.
- Monitor incident/injury trends or issues to identify any indications of work-related COVID-19 issues at a particular facility or worksite.
- Check government websites (e.g., CDC, State Department, etc.) for any travel advisories (where applicable).
- Have a plan for potential infectious disease outbreaks in the workplace. (Note – Customizable Infectious Disease Programs are available to contributing FCA members)
Need a Plan? Request your FCA International COVID-19 Exposure Control Plan
The FCA International COVID-19 Exposure Control Plan is fully customizable and was developed specifically for signatory contractors. These plans are available to all contributing FCA members at no extra cost.
If your company has not yet requested your FCA International COVID-19 Exposure Control Plan, click here to request your copy today!