On August 13, 2021, OSHA published Protecting Workers: Guidance on Mitigating and Preventing the Spread of COVID-19 in the Workplace. This guidance is intended to help employers and workers not covered by OSHA's COVID-19 Emergency Temporary Standard (ETS) for Healthcare. It's purpose is to help employers identify COVID-19 exposure risks to workers who are unvaccinated or otherwise at risk even if they are fully vaccinated. It contains recommendations that are advisory in nature and informational in content to assist employers in recognizing and abating hazards likely to cause death or serious physical harm as part of their obligation to provide a safe and healthful workplace.
OSHA states in the guidance "This guidance is also intended to help employers and workers who are located in areas of substantial or high community transmission, who should take appropriate steps to prevent exposure and infection regardless of vaccination status." The CDC’s latest report concludes that only a small proportion of persons fully vaccinated with an mRNA vaccine (Pfizer-BioNTech or Moderna) have become infected by the Delta Variant (Breakthrough Infections). Preliminary evidence from the CDC suggests that when these vaccinated persons become infected by the Delta Variant, they can still be infectious and spread the virus to others. Studies are currently ongoing to determine the effectiveness of the Johnson & Johnson/Janssen vaccine’s effectiveness against breakthrough infections and infectiousness of these persons. It is important for employers to consider this when completing a hazard assessment and determining proper exposure reporting procedures for your workplace. Given this new information, OSHA’s latest guidance suggests, fully vaccinated employees in areas with substantial or high community transmission wear masks to protect unvaccinated coworkers and patients/customers. Also, if a fully vaccinated worker has a close contact exposure with confirmed coronavirus, they must wear a mask for up to 14 days unless they present a negative coronavirus test at least 3-5 days after initial contact.
OSHA also clarifies that among promoting the vaccination of employees, key controls to help protect unvaccinated and other at-risk workers include removing from the workplace all infected people, all people experiencing COVID symptoms, and any people who are not fully vaccinated that have had close contact with someone with COVID-19 and have not tested negative for COVID-19 immediately if symptoms develop. If the unvaccinated person does not develop symptoms and again tests negative at least 3-5 days after the contact they may return to work 7 days after contact.
The preliminary evidence discussed above can be found at: Science Brief: COVID-19 Vaccines and Vaccination (cdc.gov)
OSHA continues to emphasize that vaccination is the optimal step to protect workers and encourages employers to engage with workers and their representatives to implement multi-layered approaches to protect unvaccinated or otherwise at-risk workers from the coronavirus.
Our goal at SafeLink Consulting is to help our clients meet the standards set out by OSHA and state OSHA plans, as well as the recommendations of the CDC. We are here to assist in the development of Infection Prevention and Job Hazard Analyses programs that are required for compliance and the safety of your employees, so don’t hesitate to contact SafeLink Consulting for help.
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