On June 10, 2021, OSHA updated its general COVID-19 guidance, Guidance on Mitigating and Preventing the Spread of COVID-19 in the Workplace. It is in response to the reality of workplaces with vaccinated and unvaccinated workers and is tailored to “protecting unvaccinated or otherwise at-risk workers in their workplaces”.

The Guidance has lots of information but the key takeaways are OSHA’s eleven recommendations:

1. Grant paid time off for employees to get vaccinated.
    
2. Instruct any workers who are infected, unvaccinated workers who have had close contact with someone who tested positive for SARS-CoV-2, and all workers with COVID-19 symptoms to stay home from work.
    
3. Implement physical distancing for unvaccinated and otherwise at-risk workers in all communal work areas.
    
4. Provide unvaccinated and otherwise at-risk workers with face coverings or surgical masks, unless their work task requires a respirator or other PPE.
    
5. Educate and train workers on your COVID-19 policies and procedures using accessible formats and in language they understand.
    
6. Suggest that unvaccinated customers, visitors, or guests wear face coverings.
    
7. Maintain Ventilation Systems.
    
8. Perform routine cleaning and disinfection.
    
9. Record and report COVID-19 infections and deaths.
    
10. Implement protections from retaliation and set up an anonymous process for workers to voice concerns about COVID-19-related hazards.
     
11. Follow other applicable mandatory OSHA standards.

Throughout, OSHA makes reference, where applicable, to its mandatory provisions. But its goal appears to be to provide guidance to workplaces so as to protect the health of the workers, especially in workplaces where there are unvaccinated employees and vaccinated but at-risk employees.

Note: Be mindful that OSHA rules were just announced for healthcare workers.

By Kristen L. Brightmire, kbrightmire@dsda.com