Issue link: http://palletcentral.uberflip.com/i/1243182
PalletCentral • March-April 2020 25 packages, pallets, and other products), those working in or providing services to the health care sector (hospitals, nursing homes, rehabilitation facilities) or related entities (such as laboratories, laundries, mortuaries). Individuals working at airports, ports, terminals, or security may also face exposures as they are the first line of defense in some operations. OSHA has issued some basic guidance on best practices for those who must continue working during the pandemic. There are guidelines, posters, and information compiled at OSHA (osha.gov) or via the National Wooden Pallet & Container Association (palletcentral.com/covid19). The CDC added guidance for safety practices impacting "critical infrastructure workers who may have had exposure to a person with suspected or confirmed COVID-19." The CDC defines such exposure as a household contact or being within 6 feet of an individual with a confirmed or suspected case, including the 48 hours before the individual became symptomatic. For critical workers who have had such exposure but themselves remain asymptomatic, the CDC says they can continue working but should have their temperature checked by the employer before entering the facility. They should also self-monitor under the employer's occupational health program, wear a face mask at all times while in the workplace for 14 days after the last exposure, maintain "social distancing" by staying 6 feet from other workers, and clean and disinfect all shared areas and equipment. On April 10, 2020, OSHA issued revised guidance on recording and reporting illnesses arising in the workplace to OSHA. At this point, OSHA requires employers to record cases on their OSHA Forms 300/301 and to include them on the annual summary form (300A) that gets electronically submitted. For most pallet industry employers, those forms are due March 2nd of each year. OSHA will expect employers to record a COVID-19 case if the matter is confirmed as a COVID-19 illness or is work-related as defined by 29 CFR 1904.5, and if it involves one or more of the general recording criteria in 1904.7 (medical treatment beyond first aid, restricted duty, days away from work, or death). However, this latest guidance acknowledges that where there is ongoing community transmission, employers outside of the health care, correctional institutions, law enforcement, and emergency response sectors "may have difficulty making determinations" whether workers contracted the disease at work. Therefore, OSHA now says that it will not enforce recordkeeping requirements relative to COVID-19 except where: (1) There is objective evidence that a COVID-19 case may be work- related, and (2) the evidence was reasonably available to the employer. Be advised. If a worker collapses on the job and the cause is unknown, and the worker is hospitalized or dies, you must notify OSHA within 8 hours of a fatality or 24 hours of hospitalization so that the agency can make a work-relatedness determination. The same is true for heart attacks, strokes, drug O.D.s and even suicide attempts that occur at the workplace. The penalty for failing to notify OSHA timely begins at $5000, so it is best to notify them and let them determine not to pursue it, as is the likely outcome! OSHA also revised its views on respirator use, testing and maintenance in the wake of COVID-19 and the worldwide shortage of N95 respirators in the healthcare community. Many pallet companies either mandate or make available for use these N95 "dust masks" to prevent exposure to wood dust, silica, and other air contaminants that may arise in the course of work. OSHA now says that as long as employers make "good faith effort" to comply with 1910.134 and adhere to agency guidance, it will not issue citations for violations of the annual fit testing mandate. Still, an initial fit test is required. The exception applies across all industries but will expire once the public health crisis ends. The agency relaxed its ban of expired respirators, provided the workers are notified. Still, OSHA advised employers to reassess its engineering and administrative controls to eliminate the need for N95 masks where possible (e.g., by using barriers or improved ventilation). If extended or reuse of N95 masks is required, this is permissible as long as the respirator maintains its structure and functional integrity. If respirators are not available to prevent person-to-person spread, OSHA will consider Be advised. If a worker collapses on the job and the cause is unknown, and the worker is hospitalized or dies, you must notify OSHA within 8 hours of a fatality or 24 hours of hospitalization so that the agency can make a work-relatedness determination.