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April 09, 2020
Cal/OSHA issues expanded COVID-19 guidance

The California Division of Occupational Safety and Health (Cal/OSHA) has issued additional employer guidance related to the COVID-19 pandemic. Cal/OSHA released interim guidelines for long-term care and skilled nursing facilities and agricultural employers.

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A total of 15,865 positive cases of COVID-19 and 374 deaths were reported in California as of April 6, according to the California Department of Public Health. COVID-19 is a respiratory disease caused by the SARS-CoV-2 virus, first identified in Wuhan City, China, in December 2019.

Cal/OSHA’s recommendations for long-term care and skilled nursing facilities incorporated findings from COVID-19 outbreaks at 30 long-term skilled nursing and assisted living facilities in King County, Washington.

The Centers for Disease Control and Prevention (CDC) identified the following factors as likely contributing to the outbreaks:

  • Staff members worked while experiencing symptoms of the disease and worked in more than one facility;
  • Inadequate familiarity and adherence to standard, droplet, and contact precautions and eye protection recommendations at facilities; and
  • Delayed recognition of cases because of low index of suspicion, limited testing availability, and difficulty identifying persons with COVID-19 based on signs and symptoms alone.

Cal/OSHA’s Aerosol Transmissible Diseases (ATD) standard applies to skilled nursing and long-term healthcare facilities. Under the ATD standard, employers must provide employees with fit-tested respirators approved by the National Institute for Occupational Safety and Health (NIOSH) whenever an employee is in an area where COVID-19 patients are located. Employees also must be medically evaluated for respirator use, trained, and fit-tested.

Both Cal/OSHA and federal OSHA have issued interim guidelines temporarily allowing the use of surgical masks in certain circumstances in response to ongoing shortages of N95 respirators. Federal OSHA also has allowed the use of filtering facepiece respirators certified under other countries’ standards.

Long-term care and skilled nursing facilities typically refer or transfer patients with infectious diseases to other facilities under normal circumstances. However, surges in cases may preclude referral or transfer of patients with confirmed or suspected COVID-19 infections to other facilities.

Long-term care and skilled nursing facilities must take additional steps to protect employees and residents, including:

  • Implementing written infection control procedures such as restricting entry of visitors, volunteers, and nonessential personnel, as well as designating a person to administer the procedures;
  • Masking patients with confirmed or suspected COVID-19 infections when medically possible;
  • Providing and ensuring employees use appropriate personal protective equipment (PPE) and respiratory protection when entering an area or a room where a confirmed or suspected patient is located;
  • Investigating exposure incidents and providing medical services to exposed employees; and
  • Training employees in signs, symptoms, modes of transmission, and when a medical evaluation is needed for aerosol transmissible diseases, including COVID-19; the employer's source control measures and written ATD program; and proper use of PPE and respiratory protection.

Agricultural employment

While the ATD standard does not apply to farm work, agricultural employers must comply with Cal/OSHA’s Injury and Illness Prevention Program (IIPP) standard and protect workers from all worksite hazards, including infectious diseases such as COVID-19.

Agricultural employers should implement physical distancing measures—ensuring employees maintain a distance of 6 feet from others—to stop or slow down the spread of COVID-19, according to Cal/OSHA. Physical distancing measures apply outdoors, in vehicles, and inside structures.

Agricultural employers should adjust line speeds and other processes, limit crew sizes, and stagger break and lunch times to enable employees to maintain safe physical distancing while working.

They also should provide additional seating and shade structures to allow employees to take breaks while staying at least 6 feet apart. Agricultural employers are required to provide water, rest, and shade under Cal/OSHA’s Heat Illness Prevention standard.
Cal/OSHA also recommended that agricultural employers:

  • Train employees on signs and symptoms of COVD-19, cough and sneeze etiquette practices, and proper hand-washing procedures;
  • Immediately send employees with acute respiratory illness symptoms home or to a medical care facility, encourage sick workers to stay home by not punishing them for missing work, and consider offering sick leave benefits to help prevent the spread of COVID-19 among workers who might otherwise work out of economic necessity; and
  • Routinely clean and disinfect commonly touched surfaces and objects while ensuring cleaners and disinfectants are used in a manner that does not harm employees.
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