Your Top 9 COVID-19 Questions Answered

Posted on 5/4/2020 by Scott Dunsmore, CIT and Roger Marks

In this Q&A, Lion instructor Scott Dunsmore, CIT answers employer questions about workplace health and safety in the age of the novel coronavirus (COVID-19).

EHS professionals from a broad range of industries asked the nine questions below during our free Coronavirus and the Workplace webinars. Topics covered range from PPE to recordkeeping to sneezeguards to hazardous waste, and more. Read on to get answers you need to protect employees and comply with OSHA safety Standards that apply to your facility. 

Missed the webinars? Get a recording of our last session.

For more information, check out OSHA's Guidance on Returning to Work.

Q. Is COVID-19 a recordable illness for the purpose of OSHA compliance? 

A. It can be challenging to determine whether a reportable incident due to an infectious disease is work-related. In general, OSHA still requires that employers make this determination if an employee has a recordable incident as outlined in 29 CFR 1904.7.

In certain workplaces, it may be easier to presume an employee’s exposure was work related: Health care workers who have contact with COVID-19 patients, for example, or warehouse workers with exposure to other employees during an outbreak of COVID-19-related illnesses.

OSHA issued interim guidance on April 10, 2020 to address illness recordkeeping related to COVID-19 cases. OSHA recognizes the difficulty in determining work-relatedness. Therefore, OSHA will not expect employers to make a work-relatedness determination unless there is objective evidence or reasonably available evidence that the illness was work related.

This applies to all general industry employers except those in healthcare industry, correctional institutions, or emergency response organizations (i.e., police, fire, EMT).

5/26/20 UPDATE: OSHA updated enforcement guidance specific to recording workplace cases of COVID-19. OSHA makes it clear that they will enforce the recordkeeping requirements for workplace illnesses and injuries for all employers. The guidance includes a discussion of how employers can determine the “work-relatedness” of a novel coronavirus case. This rescinds OSHA's previous guidance related to recording cases of COVID-19.​

Q. Are cloth face coverings considered PPE that requires compliance with 29 CFR 1910.132?

A. OSHA has stated that face masks (e.g., examination masks) are not PPE because they will not protect employees from exposure to aerosols of the SARS-CoV-2 virus. Rather, cloth face coverings are typically intended to protect others (not the wearer) from exposure.

Many state and local governments currently require or recommend that individuals wear a face mask when in public, as a means of protecting others from potential exposure. These state or locNIOSH N95 mask in workplaceal requirements may extend to your workplace, and you should review these requirements.

If you have determined that your employees must be protected from respiratory exposure, then you are subject to any provisions at 29 CFR 1910, Subpart I, including: 
  • Documenting your PPE assessment and determination (1910.132); and 
  • Complying with applicable respiratory protection requirements (1910.134).
Supply of certain PPE may be limited. OSHA issued enforcement guidance on April 3, 2020 that addresses the prioritization of the employer’s efforts to locate PPE.

Q. Are N95 masks and KN95 masks the same thing?

A. Our research indicates that KN95 masks are filtering facepieces manufactured to specific Chinese standards. In general, OSHA standards specify that if an employer deems respirators necessary to protect employees from respiratory hazards, the respirators used must be NIOSH-approved.

OSHA published enforcement guidance on April 3, 2020. In the memo, OSHA permits the use of certain other countries’ facemasks in place of an N95 mask.
However, the memo specifically puts restrictions on use of facemasks from China. 

Q. Is a medical evaluation required for VOLUNTARY respirator use? What about a copy of the standard?

A. It depends. If the employee is voluntarily wearing a filtering facepiece respirator (e.g., an N95 facemask) then the employer does not need to conduct a medical evaluation or complete the medical questionnaire (29 CFR 1910.134(c)(2)(ii)).

For other types of respirators, such as full or half-face cartridge respirators, the employer must conduct the medical evaluations, including the medical questionnaire (29 CFR 1910.134(c)(2)(i)).

In both cases above, the employer must provide the employee with a copy of 29 CFR 1910.134 Appendix D, “Information for Employees Using Respirators When Not Required Under This Standard.”

Q. Are cartridge-based respirators more protective than N95s? Is it okay to use a cartridge-based mask when employees go out in the field in place of an N95?

A. Each respirator is designed to protect employees from different hazards and to different degrees. You will need to evaluate manufacturer specifications for prospective respirators to determine if they provide protection against your workplace hazards.

If you have determined that an N95 respirator is necessary, but supplies are limited, you may select a more protective device. It is important to note that if you have chosen to use a cartridge-style respirator, additional requirements may apply (see 29 CFR 1910.134).

Q. What are employer obligations when an employee brings in his or her own half-mask or elastomeric respirator to work?

A. If an employer allows an employee to bring his or her own elastomeric respirator (i.e., a half-face cartridge respirator), the employer is still obligated to comply with applicable OSHA requirements.

The employer must still conduct a medical evaluation of the employee and document the medical evaluation and maintenance program as required by 29 CFR 1910.134(c).  That said, because the employer has determined that this type of respirator is not required to protect the employee, fit testing is not required.

Q. What are potential hazards with respect to COVID-19 at facilities that generate, store, treat, or dispose of hazardous waste?

A. The risk at hazardous waste facilities is comparable to other industrial/manufacturing workplaces where employees may be in contact with potentially infected co-workers and contaminated surfaces.

Using the risk category definitions from OSHA’s Guidance on Preparing Workplaces for COVID-19, a facility that generates, stores, treats, or disposes of hazardous waste is likely to fall in either the “medium” or “low” risk category.

Q. In a university setting, would people who interact with the public need to have sneeze-guards installed?

A. OSHA does not have a specific COVID-19 or respiratory infectious disease standard and there is not a specific regulation that requires sneeze-guards. Any engineering controls must be selected based on the employer’s assessment of exposure risk to their employees.

Sneeze-guards have been common controls implemented by employers that have employees who work in close contact (i.e., less than 6 feet) with those who may be infected with COVID-19 but who are not known or suspected to be COVID-19 patients (i.e., medium exposure risk).

First, employers should determine their employees’ exposure risk category. Then, evaluate engineering and administrative controls that best fit the employee’s specific job function(s). 

Q. Is there any evidence that hotter temperatures or higher humidity affect the Coronavirus?

A. We are not aware of any evidence that indicates SAR-CoV-2 virus is affected by higher temperatures or higher humidity environments. With cases occurring in countries and states with warmer, more humid climates, it seems unlikely that temperature would have a significant impact.

If new evidence comes to light, we expect that the World Health Organization (WHO) and/or the US Centers for Disease Control (CDC) will report on it.

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