The coronavirus pandemic has struck another aspect of the construction industry. California’s Occupational Safety and Health Agency (Cal/OSHA) issued a five-page “guidance “ document dated April 25 (but updated April 27).
The report is available online at
The agency says the document “does not impose any new legal obligations.” Then it explains that you have to make changes to your Illness and Injury Prevention Program (IIPP) and that it is MANDATORY. California employers are required to establish and implement an IIPP to protect employees from all worksite hazards, including infectious diseases.
To make it more interesting, the guidance document is the only resource available to you at right now, at least at press time. Cal/OSHA has canceled its Spring Training and Safety Awareness Events, generally held at their area Consultation Offices, to protect their employees.
What Must Go in IIPP
While Cal/OSHA wants an update to IIPPs, what they really want is for you to practice what you preach. This means that while the safety plan needs to outline the new requirements to meet the Covid-19 plague head-on, you are going to have to tailor your safety practices, from in-house training to tailgate talks to meet the standard you set in the IIPP
Since this new health threat is still a source of mystery and confusion, you and your safety team are probably going to have to be your own experts. As you comb through the five-page guidance plan, follow the links embedded there and download the content you will need to implement the program.
It All Starts With Training
The first rule is to provide training in a form that is readily understandable by all employees on the following topics:
- Information related to COVID-19 from the Centers for Disease Control and Prevention (CDC) – check for updates frequently – starting with:
- What COVID-19 is and how it is spread.
- Preventing the spread of COVID-19 if you are sick. o Symptoms of COVID-19 and when to seek medical attention.
- How an infected person can spread COVID-19 to others even when they don’t feel sick.
Beyond those introductory topics your IIPP and subsequent safety programs will concentrate on physical actions including frequent handwashing with soap and water (or using hand sanitizer as a last resort where employees cannot get to a sink or hand washing station), including:
- Following CDC guidelines to scrub for at least 20 seconds.
- When employees arrive at work and before they leave work.
- Before and after eating or using the toilet.
- After close interaction with other persons.
- After contacting shared surfaces, equipment or tools.
- Before and after wearing masks or gloves.
- After blowing nose or sneezing.
When you think that level of detail just covers hand washing, get ready for several hours/days of study on the rest of the requirements.
- Maintaining more than six feet of separation with others and eliminating close contact with others.
- Methods to avoid touching eyes, nose and mouth.
- The use of cloth face coverings, including cloth face coverings are not personal protective equipment (PPE) and do not protect the person wearing the face covering.
- Coughing and sneezing etiquette, including covering a cough or sneeze with a tissue or a sleeve instead of a hand.
- Safely using cleaners and disinfectants, which includes knowing the hazards of the cleaners and disinfectants used at the worksite.
- Wearing personal protective equipment (such as gloves).
- Ensuring cleaners and disinfectants are used in a manner that does not endanger employees.
- The importance of not coming to work if they have a frequent cough, fever, difficulty breathing, chills, muscle pain, headache, sore throat, or recent loss of taste of smell, or if they or someone they live with has been diagnosed with COVID-19.
- To seek medical attention if the symptoms become severe including persistent pain or pressure in the chest, confusion, or bluish lips or face.
While this is just skimming the surface, you can expect Cal/OSHA and other agencies, both state and local, to follow with more requirements. In some respects, the training that your employees get to meet this threat may be a significant benefit in unexpected ways, like a reduction of sick days for a host of other medical conditions, from the flu to bad colds. It may prove a silver-lining in a sky full of very dark clouds.
To dig into the details, download the document is available with active links at www.dir.ca.gov/COVID19CONST For assistance regarding this subject matter, employers may contact Cal/OSHA Consultation Services at 1-800-963-9424.