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Jon Anderson

For the past several months, managers and safety professionals have been tested as never before. Workplace challenges come at us fast and furious. We have had to adjust, modify, create, and constantly adapt to frequently changing guidance and instructions regarding the SARS Coronavirus 2.

It is becoming commonplace to focus entirely on the COVID-19 threat with social distancing, testing, and workplace modifications necessary to keep our employees safe and mitigate exposure to this potentially deadly disease. While this is critical, it is also important to keep our eyes on the bigger picture. There are many safety-related obligations we must maintain for the sake of our workforce. Managers cannot afford to lose sight of the overall goal to maintain a safe work environment and keep associates safe.

OSHA announced they would use discretion for employers on April 16, 2020 through an enforcement memo entitled, Discretion in Enforcement when Considering an Employer’s Good Faith Efforts During the Coronavirus Disease 2019 (COVID-19) Pandemic. An excerpt from the memo indicated that, “OSHA understands that some employers may face difficulties complying with OSHA standards due to the ongoing health emergency. Widespread business closures, restrictions on travel, limitations on group sizes, facility visitor prohibitions, and stay-at-home or shelter-in-place requirements may limit the availability of consultants, or contractors who normally provide training, auditing, equipment inspections, and other essential safety services.”

This announcement should not be construed as a forbearance on inspections and citations. OSHA compliance officers are still active. A search of inspection activity on OSHA’s website shows citations are being handed out for a variety of workplace violations, program-related shortcomings, serious injuries, and fatalities. The memo instructs Compliance Safety and Health Officers (CSHOs) to “evaluate whether the employer made good faith efforts to comply with applicable standards and to ensure employees are not exposed to hazards for which they are not prepared or trained.”

The enforcement memo directs CSHOs to, “evaluate whether the employer thoroughly explored all options to comply with the applicable standard(s) (e.g., the use of virtual training or remote communication strategies). CSHOs should also consider any interim alternative protections implemented or provided to protect employees, such as engineering or administrative controls, and whether the employer took steps to reschedule the required annual activity as soon as possible.”

The #1 priority must always be the safety and health of employees. The potential for OSHA inspections and citations are real. They should not drive the safety program. During this time of the COVID-19 threat, management must maintain focus on the most significant hazards and risks. This includes best practice, a safe workplace and affective training and education for the workers.

Maintaining a safe workplace includes attention to common regulatory issues such as annual audiograms, process hazard analysis, respirator fit testing, medical evaluations, hazard communication training and hazardous chemical identification, control of hazardous energy (lockout/tagout), forklift operator training, personal protective equipment, machine guarding, emergency response, and others. As companies address these regulatory issues, documentation is required to verify good faith efforts.

Many times, the most at-risk worker will be the new employee. Safety orientation and understanding the job responsibilities must be addressed before beginning work. Management has an ethical and legal obligation to ensure employees are aware of risks and hazards as they perform their tasks and navigate the facility. Employees must be equipped with knowledge and training to perform their responsibilities safely.

Because the COVID-19 business interruptions may prohibit us from scheduling a mobile test van for the required annual audiometric testing. Management may need to consider options such as smartphone apps for audiometric testing and noise level surveys. Implement interim protective measures such as engineering controls where possible. If engineering controls are not feasible solutions, document your attempts. If rescheduling the audiometric testing is the only option, reschedule as soon as possible when restrictions begin to lift. The correct and consistent use of hearing protection in high noise areas must be maintained.

When your company uses a consultant for respirator training and refresher training and the consultant is unable to be on-site at your location, you might consider a web-based meeting or webinar for training. Fit testing procedures may be learned through webinars and web-based meetings and in-house personnel can become proficient in some fit testing methods.

Hazard communication training will play an important role in making sure employees are informed of the new types of cleaning chemicals used to sanitize common touch surfaces due to potential exposure to the coronavirus. Safety management will need to make sure all chemical hazard information is obtained and the appropriate training is provided to those who handle the chemicals and for those who will be exposed. Along with chemical hazard training, include an updated hazard analysis for personal protective equipment (PPE) when using the newly introduced cleaning chemicals. The updated PPE hazard analysis will likely require additional hazard recognition training and education regarding appropriate PPE.

Many workplaces are facing scheduling challenges and a shortage of employees, some of whom may have specialized instruction such as authorized employee training for lockout/tagout. If employees with specialized training and knowledge are no longer available, management cannot afford to take short cuts and ask associates to perform tasks they are not equipped to perform. It may be tempted to have a few authorized persons perform lockout for others who are untrained because of time limitations. This practice may lead to serious consequences when miscommunication occurs or people with a lack of training and low skill levels overestimate their ability to perform work on machinery.

Another consequence of staffing and scheduling issues may result in untrained employees being asked to operate equipment such as forklifts. Operator training must be provided before an individual may operate the equipment, not only for their own safety but for the safety of everyone in the work area.

This article outlines just a few of the safety concerns management must stay on top of during the workday. Your company may have additional safety concerns, policies, safe operating procedures, and best practices during ongoing operations. Our challenge before the pandemic was to build a safety culture that promoted safe behaviors and processes. Our challenge now, during this pandemic, will be to maintain these safety functions and processes to solidify our safety culture and dedication to the hard-working and essential employees that management has the responsibility to protect.

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