Patterns Emerge in OSHA COVID-19 Enforcement Data
COVID Citations By-the-Numbers
|Citations issued||Establishments cited||Avg. citation amount||Most common citation amount||Largest citation issued by OSHA|
Average citation amount for COVID-related violations
Most common fine amount for COVID-related violations
The largest citation OSHA has issued for COVID-related violations as of October 15, 2020.
In addition to applicable Federal OSHA Standards, many states have created their own COVID-19 requirements for employers.
In California, for example, Cal/OSHA recently issued another round of COVID-19 related citations. The list includes a $222,000 citation to a frozen food manufacturer following twenty or more employee COVID-19 infections and one employee death.
What Regulations Are Inspectors Citing?
Across these enforcement cases, OSHA cites four key 29 CFR Standards again and again. These are the existing OSHA programs in place to protect workers from respirable and infectious hazards like SARS-CoV-2:
General PPE requirements (29 CFR
injury/illness reporting and recordkeeping. (29 CFR 1904)
29 CFR 1910.134 – Respiratory Protection.
Paragraph (c)(1) Written respirator protection program
Requires employers to create, implement, and administer a written respiratory protection program if employees in any workplace where respirators are required by the employer or necessary to protect employee health.
Paragraph (e) Medical Evaluations
Lays out the medical evaluation criteria, including having a physician of licenses health care professional to perform the medical evaluations (e)(2)(i).
Paragraphs (f)(1) and (f)(2) Respiratory Fit Tests
Employers must ensure that employees using a tight-fitting facepiece respiratory pass an appropriate fit test before the employee may be required to it. The fit test must also be done if the respirator facepiece size, model, or make changes.
Fit testing must be repeated annually.
Paragraph (k) Employee Training and Information
Employers must provide “effective training” to employees who are required to wear respirators. The Standard details specific knowledge that employees must hold after the training is complete.
Training must be provided in a manner that is understandable to the employee 1910.134(k)(2).
Annual re-training is required 1910.134(k)(5)
29 CFR 1904 Injury and Illness Reporting and Recordkeeping
OSHA requires employer to record work-related injuries and illnesses (including COVID-19) that meet certain criteria.
For work-related incidents that result in death, employer must report to OSHA within 8 hours. Work-related incidents that result in hospitalization, amputation, or eye loss must be reported within 24 hours.
OSHA recently clarified its injury and illness recordkeeping and reporting requirements.
Are All Chemical Exposure Recordable? https://www.lion.com/Lion-News/November-2017/Are-All-Chemical-Exposures-Recordable-Injuries
Fainting at the Sign of Blood—Is it Recordable?
1910.1030(c)--(g) Bloodborne pathogens
Inspectors cited employers for violations related to workplace exposure controls, employee training, and general requirements of the bloodborne pathogens standards at 29 CFR 1910.1030.
Training and annual re-training requirements in paragraph (g).
1910.132(d)(1) PPE General requirements
Employers must assess the workplace for hazards, select and provide adequate PPE as needed to protect employee safety, make sure the PPE fits the employee, and communicate to the employee why certain PPE was selected.
1910.132(d)(2) requires a written “certification of hazard assessment” to verify that the employer performed the workplace hazard assessment as required.
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