Control and Prevention
Given the evolving nature of the pandemic, Organic Pantry LC is taking measures for protecting workers from exposure to and infection with SARS-CoV-2, the virus that causes Coronavirus Disease 2019 (COVID-19). That risk varies based on the type of work being performed, the potential for interaction (prolonged or otherwise) with people, and contamination of the work environment. We have adopted infection prevention and control strategies based on a thorough workplace hazard assessment, using appropriate combinations of engineering and administrative controls, safe work practices, and personal protective equipment (PPE) to prevent worker exposures.
Interim General Guidance for All Workers: For all workers, regardless of specific exposure risks, it is always a good practice to:
- Wear cloth face coverings, at a minimum, at all times when around coworkers or the general public. If a respirator, such as an N95 respirator or better, is needed for conducting work activities, then that respirator should be used, and the worker should use their cloth face covering when they are not using the respirator (such as during breaks or while commuting).
- Frequently wash your hands with soap and water for at least 20 seconds. When soap and running water are not immediately available, use an alcohol-based hand sanitizer with at least 60% ethanol or 70% isopropanol as active ingredients and rub hands together until they are dry. Always wash hands that are visibly soiled.
- Avoid touching your eyes, nose, or mouth with unwashed hands.
- Practice good respiratory etiquette, including covering coughs and sneezes or coughing/sneezing into your elbow/upper sleeve.
- Avoid close contact (within 6 feet for a total of 15 minutes or more over a 24-hour period) with people who are visibly sick and practice physical distancing with coworkers and the public.
- Stay home if sick.
- Recognize personal risk factors. According to the U.S. Centers for Disease Control and Prevention (CDC), certain people, including older adults and those with underlying conditionssuch as heart or lung disease, chronic kidney disease requiring dialysis, liver disease, diabetes, immune deficiencies, or obesity, are at higher risk for developing more serious complications from COVID-19.
The CDC has also developed interim COVID-19 guidance for businesses and employers. The interim guidance is intended to help prevent workplace exposure to acute respiratory illnesses, including COVID-19. The guidance also addresses considerations that may help employers as community transmission of SARS-CoV-2 evolves. The guidance is intended for non-healthcare settings. Healthcare workers and employers should consult guidance specific to them, including the information below and on the CDC coronavirus webpage. Additional guidance from the Equal Employment Opportunity Commission (EEOC) and other federal agencies may be relevant to both workers and employers.
Interim Guidance for Job Tasks Associated with Lower Exposure Risk
Workers whose jobs do not require contact with people known to have or suspected of having COVID-19, nor frequent close contact with (within 6 feet for a total of 15 minutes or more over a 24-hour period) the general public or other workers, are at lower risk of occupational exposure.
As the Hazard Recognition page explains, workers' job duties affect their level of occupational risk and such risk may change as workers conduct different tasks or circumstances change.
Employers and workers in operations associated with a lower risk of exposure should remain aware of evolving trends in community transmission. Changes in community transmission, or work activities that move employees into higher risk categories, may warrant additional precautions in some workplaces or for some workers.
Protect Workers Performing Screening Duties
As part of screening programs, ensure that personnel performing screening activities, including temperature checks, are appropriately protected from exposure to potentially infectious workers entering the workplace:
- Implement engineering controls, such as physical barriers or dividers or rope and stanchion systems, to maintain at least 6 feet of distance between screeners and workers being screened.
- Ensure that screening is conducted in a safe area by, for example, directing parking lot or delivery traffic elsewhere.
- If screeners need to be within 6 feet of workers, provide them with appropriate PPE based on the repeated close contact the screeners have with other workers.
- Such PPE may include gloves, a gown, a face shield, and, at a minimum, a medical-grade face mask.
- Train employees on how to properly put on, take off, and dispose of all PPE.
- Filtering facepiece respirators, such as N95s, may be appropriate for workers performing screening duties. If respirators are needed, they must be used in the context of a comprehensive respiratory protection program that includes medical evaluation, fit testing, and training in accordance with OSHA's Respiratory Protection standard (29 CFR 1910.134).
- OSHA video: Putting on and Taking off a Mask (Spanish)
- OSHA poster: Seven Steps to Correctly Wear a Respirator at Work (available in 16 languages)
Screening workers for COVID-19 signs and/or symptoms (such as through temperature checks) is a strategy that employers may choose to implement as part of their efforts to maintain or resume operations and reopen physical work sites. Employers may consider developing and implementing a screening and monitoring strategy aimed at preventing the introduction of SARS-CoV-2 into the work site.* Those who may be infected with SARS-CoV-2 may not show any signs or symptoms, thus screening and monitoring may have limitations. The complexity of screening will depend on the type of work site and the risk of a COVID-19 outbreak among staff, but, if implemented, should include:
- Protocols for screening workers before entry into the workplace (which may entail asking workers to take their own temperatures or otherwise perform self-screening measures before reporting to work).
- Criteria for the exclusion of sick workers (including asymptomatic workers who have tested positive for SARS-CoV-2 and have not yet been cleared to discontinue isolation).
- Criteria for return to work of exposed and recovered employees (those who have had signs or symptoms of COVID-19 but have gotten better).
Because people infected with SARS-CoV-2 can spread the virus even if they do not have signs/symptoms of infection, screening may play a part in a comprehensive program to monitor worker health during the pandemic but may have limited utility on its own. In many workplaces, screening efforts are likely to be most beneficial when conducted at home by individual workers. Employers' temperature screening plans may rely on workers self-monitoring, rather than employers directly measuring, temperatures. Consider implementing such programs in conjunction with sick leave policies that encourage sick workers, including those whose self-monitoring efforts reveal a fever, to stay at home. The Families First Coronavirus Response Act requires certain employers to provide employees with paid sick leave or expanded family and medical leave for specified reasons related to COVID-19, eligible for 100% reimbursement through employer tax credits.
* Protocols for worker screening must be applied equally, without discrimination based on race, national origin, sex, age, disability, or other protected characteristics.
If employers choose to implement on-site screening or monitoring programs, they may need to be coordinated, as appropriate, with local public health authorities and occupational medicine and health and safety professionals.
Employers implementing on-site screening programs may need to plan for:
- Providing verbal screening in appropriate languages to determine whether workers have had new or unexpected symptoms of COVID-19 in the past 24 hours.
- Checking temperatures of workers at the start of each shift to identify anyone with a fever of 100.4°F or greater (or reported feelings of feverishness).1
- Measures for testing workers for SARS-CoV-2 and responding to positive test results.
- Prohibiting employees from remaining in the workplace if they have a fever of 100.4°F or greater (or report feelings of feverishness), or if screening or testing results indicate that the worker is suspected of having or known to have COVID-19. In such an event:
- Encourage workers to self-isolate and contact a healthcare provider;
- Provide information on the employer's return-to-work policies and procedures; and
- Inform human resources, employer health unit (if applicable), bargaining unit representation (if applicable), and supervisor (so the worker can be moved off schedule during illness and a replacement can be assigned, if needed).
- Conduct contact tracing to identify and inform coworkers or others that may have had exposure.
- Measures to ensure worker privacy and confidentiality during any screening.
- Regardless of how employers ultimately decide to implement temperature checks or other health screening measures, they should act cautiously on results. Employers should not presume that individuals who do not have a fever or other symptoms of COVID-19 do not have the virus.
- Similarly, because of the limitations of current testing capabilities, employers who implement workplace testing strategies should act cautiously on COVID-19 test results. Employers should not presume that individuals who test negative for SARS-CoV-2 infection (i.e., COVID-19) present no hazard to others in the workplace.
- Employers should ensure that screening protocols are consistent with other labor and disability laws, and with collective bargaining agreements where applicable.
Employers should continue to implement universal cloth face coverings, basic hygiene, physical distancing, workplace controls, flexibilities (e.g. sick leave, telework), and employee training described in this and other OSHA and CDC guidance in ways that reflect the risk of community spread of SARS-CoV-2 from the geographical area where the workplace is located.
Administrative controls and safe work practices change policies and procedures for how workers perform job duties to ensure work activities are conducted safely. Examples of administrative controls that employers may find useful for protecting workers from SARS-CoV-2 include:
- Limiting the number of workers assigned to a particular shift in a facility and ensuring workstations are spaced at least 6 feet apart.
- Posting signage, in languages the workers understand, to remind workers, customers, and visitors to maintain a distance of at least 6 feet between one another and to practice regular hand hygiene.
- Providing training and information in languages the workers understand.
- Increasing the frequency of cleaning and disinfection within the work site.
- Encouraging or permitting workers to wear cloth face coverings, if appropriate, to help contain potentially infectious respiratory droplets.
PPE protects workers from hazards when engineering and administrative controls are insufficient on their own. The types of PPE that workers may need for protection from exposures to SARS-CoV-2 in areas with community transmission will vary based on work activities, exposure risks, and the results of the employer's hazard assessment. The Additional Considerations for PPE section provides additional details about PPE selection and use for all employers whose workers have increased risk of exposure to SARS-CoV-2 during the pandemic. Because of PPE supply chain concerns during the COVID-19 pandemic, employers should consider whether operations that require PPE can be delayed either until PPE is not needed (e.g., because the COVID-19 hazard diminishes) or until PPE supply chains stabilize. Employers should consider accommodations for religious exercise for those employees who, for instance, have or cannot trim facial hair due to religious belief, or provide reasonable modifications for persons with disabilities.
Additional Considerations for PPE
Interim guidance for specific types of workers and employers includes recommended PPE ensembles for various types of activities that workers may perform. In general:
- PPE may be needed when engineering and administrative controls are insufficient to protect workers from exposure to SARS-CoV-2 or other workplace hazards and essential work operations must continue.
- PPE should be selected based on the results of an employer's hazard assessment and workers' specific job duties.
- PPE ensembles should reflect the types of exposures identified in an employer's hazard assessment. Most workers' exposure to SARS-CoV-2 is likely to be through the contact or droplet routes, although some workers, including those in healthcare, postmortem care, and laboratories, may have exposure to aerosols for which higher level PPE (including N95 respirator with an assigned protection factor of 10 or better) is needed.
- When disposable gloves are used, workers should typically use a single pair of nitrile exam gloves (unless other gloving protocols are necessary for the work setting or task). Change gloves if they become torn or visibly contaminated with blood or body fluids.
- When both face and eye protection are needed, use surgical masks and either goggles or face shields.
- Personal eyeglasses are not considered adequate eye protection.
- Cloth face coverings are not acceptable substitutes for PPE intended to prevent worker exposure to droplets or other splashes or sprays of liquids.
- If workers need respirators, they must be used in the context of a comprehensive respiratory protection program that meets the requirements of OSHA's Respiratory Protection standard (29 CFR 1910.134) and includes medical exams, fit testing, and training.
- Surgical masks are not respirators and do not provide the same level of protection to workers as properly-fitted respirators. Cloth face coverings are also not acceptable substitutes for respirators.
- An OSHA poster (available in 16 languages) and video (Spanish) provide information about how to properly wear and dispose of filtering facepiece respirators.
- If there are shortages of PPE items, such as respirators or gowns, they should be prioritized for high-hazard activities.
- Workers need respiratory protection when performing or while present for aerosol-generating procedures, including cardiopulmonary resuscitation (CPR) and intubation.
- Workers must be protected against exposure to human blood, body fluids, other potentially infectious materials as well as hazardous chemicals and contaminated environmental surfaces.
- CDC provides strategies for optimizing the supply of PPE, including guidance on extended use and limited reuse of N95 filtering facepiece respirators (FFRs) and methods for decontaminating and reusing disposable filtering facepiece respirators during crises.
- These guidelines are intended for use in healthcare but may help employers in other sectors optimize their PPE supplies as well.
- After removing PPE, always wash hands with soap and water, if available, for at least 20 seconds. Ensure that hand hygiene facilities (e.g., sink or alcohol-based hand sanitizer) are readily available at the point of use (e.g., at or adjacent to the PPE removal area).
- Employers should establish, and ensure workers follow, standard operating procedures for cleaning (including laundering) PPE and items such as uniforms or laboratory coats, as well as for maintaining, storing, and disposing of PPE. When PPE is contaminated with human blood, body fluids, or other potentially infectious materials, employers must follow applicable requirements of the Bloodborne Pathogens standard (29 CFR 1910.1030) with respect to laundering. OSHA's Enforcement Procedures for the Occupational Exposure to Bloodborne Pathogens (CPL 02-02-069) provide additional information.
Employers in all sectors may experience shortages of PPE, including gowns, face shields, face masks, and respirators, as a result of the COVID-19 pandemic. Although employers are always responsible for complying with OSHA's PPE standards (in general industry, 29 CFR 1910 Subpart I, and, in construction, 29 CFR 1926 Subpart E), including the Respiratory Protection standard (29 CFR 1910.134), whenever they apply, OSHA is providing temporary enforcement flexibility for certain requirements under these and other health standards.
Additional Considerations for Environmental Cleaning and Disinfection
When people touch a surface or object contaminated with SARS-CoV-2, the virus that causes COVID-19, and then touch their own eyes, noses, or mouths, they may expose themselves to the virus.
Early information from the CDC, the National Institutes of Health, and other study partners suggests that SARS-CoV-2 can survive on certain types of surfaces, such as plastic and stainless steel, for 2-3 days. However, because the transmissibility of SARS-CoV-2 from contaminated environmental surfaces and objects is still not fully understood, employers should carefully evaluate whether or not work areas occupied by people suspected to have the virus may have been contaminated and whether or not they need to be disinfected in response.
The CDC provides instructions for environmental cleaning and disinfection for various types of workplaces, including:
- Healthcare facilities, as part of CDC healthcare infection control recommendations
- Postmortem care facilities, such as autopsy suites
- Other, non-healthcare facilities
Employers operating workplaces during the COVID-19 pandemic should continue routine cleaning and other housekeeping practices in any facilities that remain open to workers or others. Employers who need to clean and disinfect environments potentially contaminated with SARS-CoV-2 should use EPA-registered disinfectants with label claims to be effective against SARS-CoV-2. Routine cleaning and disinfection procedures (e.g., using cleaners and water to pre-clean surfaces before applying an EPA-registered disinfectant to frequently touched surfaces or objects for appropriate contact times as indicated on the product's label) are appropriate for SARS-CoV-2, including in patient care areas in healthcare settings in which aerosol-generating procedures are performed.
Workers who conduct cleaning tasks must be protected from exposure to hazardous chemicals used in these tasks. In these cases, the PPE (in general industry, 29 CFR 1910 Subpart I, and, in construction, 29 CFR 1926 Subpart E) and Hazard Communication (29 CFR 1910.1200) standards may apply, and workers may need appropriate PPE to prevent exposure to the chemicals. If workers need respirators, they must be used in the context of a comprehensive respiratory protection program that meets the requirements of OSHA's Respiratory Protection standard (29 CFR 1910.134) and includes medical exams, fit testing, and training.
Cleaning chemicals' Safety Data Sheets and other manufacturer instructions can provide additional guidance about whether workers need PPE to use the chemicals safely.
Do not use compressed air or water sprays to clean potentially contaminated surfaces, as these techniques may aerosolize infectious material. More information about protecting environmental services workers is included in the worker-specific section, below.
Additional Considerations for Worker Training
Train all workers with occupational exposure to SARS-CoV-2 (as described in this document) about the sources of exposure to the virus, the hazards associated with that exposure, and appropriate workplace protocols in place to prevent or reduce the likelihood of exposure. Training should include information about how to isolate individuals with suspected or confirmed COVID-19 or other infectious diseases, and how to report possible cases. Training must be offered during scheduled work times and at no cost to the employee.
Workers required to use PPE must be trained. This training includes when to use PPE; what PPE is necessary; how to properly don (put on), use, and doff (take off) PPE; how to properly dispose of or disinfect, inspect for damage, and maintain PPE; and the limitations of PPE. Applicable standards include the PPE (29 CFR 1910.132), Eye and Face Protection (29 CFR 1910.133), Hand Protection (29 CFR 1910.138), and Respiratory Protection (29 CFR 1910.134) standards. OSHA's website offers a variety of training videos about respiratory protection.
When the potential exists for exposure to human blood, certain body fluids, or other potentially infectious materials, workers must receive the training required by the Bloodborne Pathogens (BBP) standard (29 CFR 1910.1030), including information about how to recognize tasks that may involve exposure and the methods, such as engineering controls, work practices, and PPE, to reduce exposure. Further information on OSHA's BBP training regulations and policies is available for employers and workers on the OSHA Bloodborne Pathogens and Needlestick Prevention Safety and Health Topics page.
OSHA's Training and Reference Materials Library contains training and reference materials developed by the OSHA Directorate of Training and Education as well as links to other related sites. The materials listed for Bloodborne Pathogens, PPE, Respiratory Protection, and SARS may provide additional material for employers to use in preparing training for their workers.
OSHA's Personal Protective Equipment Safety and Health Topics page also provides information on training in the use of PPE.
Additional Considerations for Workers with Increased Susceptibility for SARS-CoV-2 Infection or Complications
Consider offering workers who may be at increased susceptibility for SARS-CoV-2 infection or complications from COVID-19 adjustments to their work responsibilities or locations to minimize exposure. Other flexibilities, if feasible, can help prevent potential exposures among workers who have heart or lung disease, chronic kidney disease requiring dialysis, liver disease, diabetes, severe obesity, or immunocompromising health conditions. Employers should be cognizant of the requirements of the Americans with Disabilities Act, the Rehabilitation Act, and the Age Discrimination in Employment Act. The EEOC has issued guidance about COVID-19 and equal employment opportunity laws.
Additional Considerations for Return-to-Work Planning
OSHA's guidance on returning to work assists employers in reopening non-essential businesses and their employees returning to work during the evolving coronavirus pandemic. The CDC has issued specific guidelines for returning to work, including after recovering from COVID-19 or having exposure to someone who has COVID-19, for certain sectors (e.g., healthcare and other critical infrastructure). Return to work guidance for non-healthcare workers may be based on criteria for ending home isolation. The American Industrial Hygiene Association (AIHA) and the National Safety Council (NSC) also provide recommendations to help employers and workers safely return to work.
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1 Note that 29 CFR 1910.1020 may apply to temperature records. Employers should evaluate the burdens and benefits of maintaining temperature records or asking workers to complete written questionnaires, as both will qualify as medical records if made or maintained by a physician, nurse, or other health care personnel, or technician. If employers do not record workers' temperatures, or if workers' temperatures are recorded but not made or maintained by a physician, nurse, or other health care personnel or technician, the mere taking of a temperature would not amount to a record that must be retained.