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OSHA Interim Enforcement Response Plan for COVID-19 Pandemic

Apr 14, 2020

As COVID-19 continues to impact employers and workers across the country,Man standing in a hallway writing on a clipboard OSHA has released an interim enforcement response plan that offers area offices and compliance safety and health officers (CSHOs) guidance and instructions on handling COVID-19-related complaints, referrals and severe illness reports. This guidance covers all inspections and investigations specifically related to the workplace hazard of SARS-CoV-2, the virus that causes COVID-19.

The plan notes that prior to any workplace inspection related to COVID-19, area directors should evaluate the risk level of exposure to SARS-CoV-2 at the workplace and prioritize resources in coordination with their regional offices to determine whether an on-site inspection is necessary. If so, CSHOs must evaluate potential hazards and limit any possible exposures.

Furthermore, area directors must maximize the use of electronic means of communication for inspections and consult with their regional solicitors when appropriate. When engaging with facilities treating a significant number of COVID-19 patients, CSHOs should take steps to not interfere with the provision of ongoing medical services.

If a CSHO identifies a workplace with a high-risk exposure potential and determines that an inspection is necessary under the terms of this guidance, they should immediately coordinate with their supervisors and regional office, and, if necessary, contact the Office of Occupational Medicine and Nursing, which can serve as a liaison with public health authorities and facilitate medical access orders to obtain worker medical records from employers and health care providers.

The guidance also notes that all COVID-19 inspections will be treated as novel cases and that CSHOs who believe they may have been exposed to SARS-CoV-2 during an inspection must report the potential exposure to their supervisor and/or area director. In addition, the Directorate of Enforcement Programs must be notified of all proposed citations and federal agency notices that relate to a COVID-19 exposure. State plan designees should report any COVID-19 inspections to their regional office.

Find more information and the latest updates on OSHA’s COVID-19 webpage.

Related Links
OSHA Temporarily Suspends Some Recordkeeping Requirements on Work-Relatedness of COVID-19
10 Ways to Reduce Worker Exposure to COVID-19
OSHA Guidance on N95 Shortage
COVID-19: CDC Guidance on Returning to Work
How to Apply the Hierarchy of Controls in a Pandemic

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