OSHA has launched a National Emphasis Program (NEP) to inspect high-hazard workplaces for COVID-19 hazards. This emphasis program does the following:

• Sets a COVID-19 inspection goal for each OSHA office that would result in about 1,600 expected inspections.
• Places a renewed emphasis on in-person inspections. Many inspections in 2020 were phoned in or carried out by contacting the company through fax.
• Puts inspection priority on workplaces with deaths from COVID-19, workplaces in communities with high rates of infection and workplaces where workers must work in close proximity to coworkers or the public. The secondary priority will be inspections based on worker complaints regarding insufficient COVID-19 control measures, workplaces where cases have occurred or workplaces with symptomatic workers.
• Uses the 5(A)(1) section of the OSH Act, which requires employers to provide a safe workplace “free of recognized hazards” based on the latest CDC guidance.
• Increases emphasis on protecting whistleblowers from discrimination for complaining about hazardous conditions.
• Outlines how OSHA inspectors should protect themselves from COVID-19 risks during inspections.

The primary targets for these inspections will be in industries with a high risk of infection among workers, such as: healthcare (including nursing facilities, residential facilities for the disabled and retirement communities); meat, animal and poultry processing; grocery stores, department stores and warehouses; restaurants and correctional institutions. The construction industry is listed as a secondary inspection target along with industries such as agriculture, manufacturing, transportation, the postal service and garden centers.

Although cases and deaths of COVID-19 are dropping and millions of Americans are getting vaccinated each day, workers are still at risk. OSHA’s NEP is an essential piece of the puzzle to fight the virus and protect essential workers, who continue to be at increased risk due to their job duties and work environment.

Following protective measures to reduce or stop the spread of COVID-19 is particularly important in an essential industry like construction, where work has never stopped. Since the start of the pandemic, many different organizations have produced both general and industry-specific guidance to help employers protect their workforce from COVID-19. As researchers have learned more about the virus and how it is transmitted, this guidance has been adapted and added to over time. Recently, the Construction Committee of the American Industrial Hygiene Association (AIHA) published a  construction-specific guidance document called Focus on Construction Health: COVID-19 (also available in Spanish).

The approach outlined in the AIHA guidance will be familiar to many occupational safety and health professionals for its risk-based approach, similar to how other construction hazards are handled. This guidance lays out six steps to creating a safer workplace:

1. Identify a COVID-19 site safety officer/competent person
2. Develop a COVID-19 control plan for the site
3. Create a site map detailing where control measures (e.g., hygiene stations) are in place
4. Identify and implement program elements to reduce risk
5. Develop Job Safety Analyses (JSAs) for each task to identify risk level. Risk level is based on factors such as the length of the task, if it’s performed indoors or outdoors, if the work is noisy or heavy (which might require shouting or heavier breathing) and if work must be done with others close by.
6. Create a COVID-19 case response plan in the event a case does occur.

This AIHA guidance is also similar to how many construction contractors already handle other jobsite hazards because it follows the hierarchy of controls:

• Start with eliminating the hazard through source reduction (i.e., ensuring that workers sick with COVID-19 don’t come to work and infect others).
• Use engineering controls such as increased ventilation and surface decontamination.
• Implement administrative controls to achieve social distancing. This can be accomplished by scheduling work to minimize workers overlapping with one another, managing deliveries, staggering arrivals and breaks and minimizing large gatherings (meetings, trainings) to limit situations where workers can’t be six feet apart.
• Ensure wash stations and hand sanitizer are readily accessible.
• Provide personal protective equipment (PPE) based on the risk levels identified in the JSAs.

For more information about how to control COVID-19 on your jobsite, visit the Fund’s COVID-19 Resources page.

[Scott Schneider]