The ongoing COVID-19 pandemic has brought renewed attention to the hazard of infectious diseases in the workplace. Could you find yourself having to comply with a federal or state infectious disease standard? A EHS Daily Advisor article by Guy Burdick brings out some valuable insights.
Airborne transmissible disease (ATD) standard
California already has an airborne transmissible disease (ATD) standard that applies in correctional and healthcare facilities and to fire, police, and other public services.
Virginia has a permanent COVID-19 standard that remains in place until the state standards board rescinds it.
ORC HSE stated that the lack of an infectious disease standard left employers on their own to determine which hazard controls are effective in combating workplace infections.
ORC HSE said an ETS would both give employers clear guidance on their responsibilities and provide employees with needed protections.
Employers confronting the COVID-19 pandemic lack clear guidance and must sort out a variety of state requirements and guidelines, according to ORC HSE.
ORC HSE urged the agency to issue an ETS that would:
- Acknowledge a range of employees in public-facing occupations who are at an elevated risk of exposure to infectious diseases, including those who work in airline operations, border protection, health care, and retail, as well as workers in construction, laboratories, manufacturing, maritime, solid waste and wastewater management, and even administrative positions.
- Incorporate the industrial hygiene hierarchy of controls, utilizing engineering controls as the first line of defense, supplemented by work practice controls and personal protective equipment (PPE) where needed.
- Recommend N95 or better respirators certified by the National Institute for Occupational Safety and Health (NIOSH) and other PPE for healthcare and other workers at an elevated risk.
- Outline a risk-based model for workers who require different levels of protection depending on the tasks they perform and their potential exposures.
- Outline elements that employers should incorporate into their exposure or infectious disease control plan.
Screening of employees
ORC HSE also called on OSHA to establish requirements for employee screening and testing, training, and medical surveillance and work restrictions for exposed or infected employees.
Many of the recommended measures mirror requirements of the bloodborne pathogen (BBP) standard, which covers exposure to blood and other bodily fluids but not aerosol droplets or airborne pathogens.
OSHA General Duty Clause Enforcement
As with earlier outbreaks, OSHA’s COVID-19 enforcement relies upon the General Duty Clause of the Occupational Safety and Health Act of 1970.
Under the General Duty Clause, §5(a)(1), employers must provide a work environment “free from recognized hazards that are causing or are likely to cause death or serious physical harm.”
On March 12, OSHA launched a COVID-19 National Emphasis Program (NEP) for “high-hazard” industries and an updated Interim Enforcement Response Plan, prioritizing the use of on-site workplace inspections.
NIOSH Workplace Infectious Disease Review
Before the COVID-19 pandemic, NIOSH performed a review of the literature on workplace infectious disease outbreaks, identifying high-risk industries and occupations.
NIOSH’s report in Emerging Infectious Diseases looked at 66 investigations between 2006 and 2015.
The institute concluded that cases appear to be concentrated in specific industries and occupations like the healthcare industry, animal workers, laboratory workers, and public service workers.
NIOSH researchers found that bacteria were responsible for most reported cases, followed by viruses, fungi, and parasites or protozoa.
Respiratory viruses and zoonotic pathogens (zoonotic infections are diseases that have jumped from animals to humans) threaten workers’ health, especially among healthcare workers and animal-contact workers.
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Source: EHS Daily Advisor