Be prepared for an OSHA or NYSDOH inspection for COVID-19 Compliance
Friday, April 17, 2020 Tiffany Bartz
How to be prepared for an OSHA or NYSDOH inspection for COVID-19 compliance for an essential business with “low risk” jobs*.
Are the following Documentations / Procedures / Policies in place and readily available? |
Yes |
No |
Documentation showing that the business is lawfully operating as an essential business. (NYS Executive Order 202.6) |
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Proof that telecommuting (working from home) is being provided to the maximum extent possible. |
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Proof that precautions are being made to prioritize the health and safety of vulnerable employees. (i.e. those 70 years of age or older; those with underlying health conditions; those who live with underlying health conditions). |
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Documentation of a written pandemic prevention plan (this can be included with other plans such as an Emergency Action Plan etc.). |
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Documentation of employee training records related to COVID-19 exposure prevention. |
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Documentation proving that sick leave policies are flexible and consistent with public health guidance and that employees are aware of and understand these policies. |
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Assurance that cleaning and disinfecting procedures, as outlined by the CDC, are being followed. |
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Proof that social distancing guidelines are being followed in the workplace. Employee interactions and workspaces are maintained at 6-feet and masks are worn for interactions that must occur within the 6-foot boundary. *NYSDOH $10,000 fine per instance |
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Procedures in place for COVID-19 hazard assessment and PPE protocols. |
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Medical records available for positive cases and exposures. OSHA recordkeeping is up to date. |
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Respiratory Protection Plan review and any modified respiratory policies related to COVID-19. Assess compliance with 29 CFR § 1910.134 |
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Documentation of provisions made to obtain and provide an appropriate and adequate supply of PPE. |
*Low risk jobs as defined by OSHA, are those jobs that do not require contact with people known to be, or suspected of being, infected with SARS-CoV-2 (COVID-19), nor in frequent close contact with, i.e. within 6 feet of, the general public. Workers in this category have minimal contact with the public and other coworkers. https://www.osha.gov/memos/2020-04-13/interim-enforcement-response-plan-coronavirus-disease-2019-covid-19#attach1
**Individual OSHA or NYSDOH inspectors may ask for additional information based on individual business activities.
***Observations made during on-site inspections may lead to additional findings.