OSEA Safety Blog

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)

Proof that telecommuting (working from home) is being provided to the maximum extent possible.

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).

Documentation of a written pandemic prevention plan (this can be included with other plans such as an Emergency Action Plan etc.).

Documentation of employee training records related to COVID-19 exposure prevention.

Documentation proving that sick leave policies are flexible and consistent with public health guidance and that employees are aware of and understand these policies.

Assurance that cleaning and disinfecting procedures, as outlined by the CDC, are being followed.

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

Procedures in place for COVID-19 hazard assessment and PPE protocols.

Medical records available for positive cases and exposures. OSHA recordkeeping is up to date.

Respiratory Protection Plan review and any modified respiratory policies related to COVID-19. Assess compliance with 29 CFR § 1910.134

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.

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