OSHA Adopts New Covid-19 National Emphasis Program

OSHA has released its adoption of a National Emphasis Program (NEP) on COVID-19 as of March 12, 2021.

The new program release is a result of President Joe Biden’s executive order on Protecting Worker Health and Safety that was signed on January 21, 2021. The executive order commits to ensuring the health and safety of essential workers as it related to protection from COVID-19. This includes healthcare workers.

The goal of the NEP is to reduce the risks of COVID-19 virus exposure to workers by focusing on current standard compliance through inspections. It is also to determine if current standard enforcement is sufficient or if new emergency COVID-19 prevention standards are needed.

OSHA has provided a list of primary inspection targets that can be found in Appendix A of the OSHA Direction issued on March 12. The list does include healthcare entities. However, the executive order requires a focus on large employers and those with whistleblower complaints.

It is important to have organizational plans in place that address the mitigation of risks to employees related to COVID-19 exposure. In the event of an inspection, you can expect:

  • An opening conference with the OSHA Compliance Safety and Health Officer (CSHO). The conference will include those individuals at the facility responsible for leading the COVID-19 emergency plan, those responsible for record-keeping and other organizational leaders. These conferences may be held in large conference rooms -even outdoors if necessary- and include any applicable PPE.
  • A review of documentation, policies, plans and procedures by the CHSO. Some examples of documents that might be requested for review include the emergency management plan, safety plan, hazard vulnerability assessment, any policies on PPE use, documentation of the purchase of PPE, social distancing protocols, respiratory protection program, employee exposure medical records and employee training records.
  • A walk-through inspection of the organization. Representatives from the organization are allowed to accompany the CSHO on the walk-through. Information gathered from the opening conference interviews and documentation review will help the CHSO determine what areas will be inspected for hazards.
  • An evaluation of applicable OSHA Standards. Many OSHA standards will be applicable during the Covid-19 inspection process. These standards include recordkeeping and reporting, PPE, respiratory protection, any specification for accident prevention signs and tags, access to employee exposure and medical records, the general duty clause, and protection from bloodborne pathogens.
  • A review of the organization’s injury and illness records. This review determines if there has been exposure or illness from Covid-19 and whether those cases were recorded properly.

Things you can do to be prepared to address an OSHA or any other survey/inspection include:

  • Ensuring your policies, procedures, and response to COVID-19 are in place and readily available.
  • Providing employees with training on COVID-19 policies and documenting that it was done. In addition, communicate to employees what measures are being taken by the organization to keep them safe and reduce their exposure to COVID-19.
  • Stepping up the cleaning and disinfection of your organization, including areas that are commonly touched by many people such as door knobs and computer keyboards. Make sure appropriate cleaning and disinfection chemicals that are approved to kill the COVID-19 virus are available and used.
  • Ensuring employees are practicing appropriate hand hygiene, wearing appropriate PPE, and are practicing social distancing regularly.

Have questions? Contact our OSHA-certified Senior Risk Consultants Glenn Eiserloh at glenneiserloh@lhatrustfunds.com or Steve Johnson at stevejohnson@lhatrustfunds.com.

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The OSHA Direction memo can be found here.

Read the executive order here.

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