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Cal/OSHA and COVID-19: Safety and Compliance Practices

UpKeep’s OSHA series is a collection of easy-to-digest resources and compliance checklists based on Federal and State OSHA Plans .
For those looking for general Cal/OSHA information and checklists, check out Cal/OSHA: An Overview here.

What’s Ahead?

Part I: Cal/OSHA Guidance for Employers Responding to COVID-19

We understand that for many in our industry, there is a new question at the top of every organization’s mind: “How can I continue my operations while following new (often confusing) guidelines and protecting the health and safety of my team during the COVID-19 pandemic?” UpKeep has spoken at length about the technological tools and processes you can put in place to operate remotely. (For a recent webinar on this topic, click here). The purpose of this resource is to provide information and guidance for organizations that must have teammates on-site and outline how they can do so while keeping their employees safe. 

To support our industry with this question, we reviewed existing literature on the subject, analyzed the advice, and compiled the below recommendations. We understand that information varies wildly based on location and industry. We also understand that this information is often dense and confusing.

Our goal in creating this resource is to create one central, accessible location for individuals in our industry to understand: 1. What are the current expectations and 2. How can I go above and beyond to ensure the safety of my employees.

This post is specifically geared towards businesses in California that are held to Cal/OSHA standards. If you’d like to review the experts’ regulations directly, you can find them at the CDC and Cal/OSHA sites. Please note, it’s important that you use this resource as a first step in your preparation and planning. Information and best practices are constantly evolving, and we are doing our best to stay on top of these changes as swiftly as possible. Before finalizing any plans, be sure to check the experts’ sites to confirm you are adhering to the most updated requirements. 

Here in Part I, we share what general guidelines Cal/OSHA has officially recommended for COVID-19 as of May 2020 formatted into an easy-to-use checklist to help ensure you are compliant. 

For an overview of Cal/OSHA and checklists to help you prepare for an audit, click here.

In Part II, we share information on the ATD Standard, a standard that is most likely not applicable to businesses who may be reading this blog, but we recommend be followed by any business looking to go above and beyond to ensure workplace safety. To make this easier, we’ve created an ATD Standard-Inspired checklist included in Part II.

General Cal/OSHA COVID-19 Checklist

These checklists provide general Cal/OSHA COVID-19 recommendations. For employers who want to go above and beyond, see the ATD Standard-Inspired Checklist below.

View Checklists

Part II: Going ‘Above and Beyond’ with ATD Standard-Inspired Practices

The COVID-19 pandemic highlights the need for additional proactive and preventative health and safety measures in all workplaces; especially as workplaces that were shut down, or operating at a lesser capacity, begin to reopen or move towards being fully operational. We understand that navigating this new environment is scary and presents a unique set of challenges!

With this future on the horizon, the ATD Standard discussed below can provide guidance for workplaces looking to go above and beyond in a post COVID-19 world. Understanding the context of the standard, what it is, and why it’s important, can provide useful insight for those looking to increase their own business’s safety measures.

While Cal/OSHA may not require your business comply with the ATD Standard, taking additional precautionary steps can help set you up for success in this new normal!

An Overview of the Aerosol Transmissible Disease (ATD) Standard

As we previously discussed in Cal/OSHA: An Overview, California is one of 22 states with an OSHA State Plan that covers the occupational safety and health of both private sector and state and local government workers. Because California operates under its own OSHA State Plan, it has many standards that don’t have a federal counterpart standard; one example of this is the Aerosol Transmissible Disease (ATD) Standard.

The purpose of the ATD Standard is to protect employees who are at a heightened risk of contracting certain airborne infections due to their work activities. The standard only applies to specific employers where there is occupational exposure to disease.

What is an Aerosol Transmissible Disease?

According to the Cal/OSHA ATD Standard outlined in title 8 of the California Code of Regulations, section 5199 Aerosol Transmissible Diseases are diseases, “transmitted by infectious particles or droplets through inhalation or direct contact with the mucous membranes of the eyes or respiratory tract.”

The ATD Standard identifies three categories of aerosol transmissible diseases/pathogens:

  • Airborne infectious diseases (AirID) – Transmitted through the air. Examples: tuberculosis, chicken pox, shingles
  • Aerosol transmissible diseases (ATD) – Transmitted by infectious droplets coming into contact with eyes, respiratory tract, or facial membranes. Ex: influenza, pneumonia, whooping cough
  • Aerosol transmissible pathogens – laboratory (ATP-L) – Any pathogen transmissible to lab employees

Understanding ATDs is important because the disease at the center of the current pandemic, COVID-19, falls into two categories – AirID and ATD, meaning it can be transmitted via air and droplet. For employer’s covered by the ATD Standard, both airborne and aerosol precautions must be utilized.

What is the ATD Standard?

The ATD Standard is a set of rigorous protocols and procedures to protect employees in workplaces where there is increased risk of occupational exposure to disease. Employers required to abide by this standard must have a written ATD Exposure Control Plan.

These plans are extensive and include everything from listing all high hazard procedures, listing tasks that require PPE, source control measures, processes for handling and evaluating exposure incidents, communicating with employees regarding exposure incidents, and ensuring adequate supply of PPE and other equipment.

For specific details on the ATD Standard, check out the California Workplace Guide to Aerosol Transmissible Diseases.

What workplaces are covered by the ATD Standard?

The ATD Standard is broken down into three classes and employers are classified based on their employees occupational exposure to disease.

  • Full Standard Employers – Direct exposure, must abide by full standard
  • Referring Employers – More limited exposure, follows specific portions of the standard
  • Laboratories – Deals with lab-generated aerosols or pathogens, requirements depend on level of exposure

Employers falling under the ATD Standard include:

  • Hospitals, nursing homes, clinics, medical offices, outpatient medical facilities, long-term health care facilities, home health care, medical transport, emergency medical services
  • Specific laboratories, public health services, and police services
  • Jails, homeless shelters, drug treatment facilities

ATD Standard-Inspired Checklist

Keep in mind, this checklist is for employers who are NOT required to abide by the ATD Standard, but are simply looking to go above and beyond more basic sanitation and cleanliness measures; so, if you’re looking for a program based off of the Cal/OSHA ATD Standard, this checklist is for you!

View Checklist

Attribution: The resources presented here were sourced from Cal/OSHA. For additional reading, tools and context please visit them here.

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