Do workplaces need an exposure control plan specific to COVID-19?

As the country begins to reopen after a long hiatus of stay at home orders due to the Coronavirus pandemic, employers of companies that are allowing employees and customers back to brick and mortar businesses must be ready with infection prevention measures. On top of OSHA and the CDC’s recommendation in adopting an Exposure Control and Response Plan that is site-specific for Covid-19, some states are requiring a written document prior to reopening the facility. This plan should cover subjects such as:

  • Newly implemented administrative and engineering controls that will enable employees to work 6 feet apart. This can be anything ranging from staggered work shifts, the option to work from home, rearranging desks at the appropriate distance, etc.
  • Actions taken to encourage employees to practice proper hygiene as well as new protocols for the sanitization of frequently used objects and surfaces.
  • Social distancing measures and how your workplace will be able to successfully implement them.
  • The types of protective equipment, such as masks and gloves, that will be used for certain tasks.
  • Actions that will be taken in preventing sick employees or customers from entering the workplace.
  • How the company will train employees and respond to cases appearing in the workplace as well as mitigation in the event that infection occurs.

An Exposure Control and Response Plan can be compared to something like a fire prevention plan in that both are used to protect people’s lives in the event of dangerous working conditions. For that reason, the lack of having an appropriate plan for infectious diseases comes with serious consequences. These can be anywhere from OSHA citing the business for not complying with the general duty clause, the business being shut down by state or local health authorities, and the company could even be blamed for wrongful death by the deceased employee’s close relations.


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