Preparing for OSHA Requirements for COVID-19 prevention

William A. Levinson

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Why should you attend?

The 2019-2021 Covid-19 epidemic has cost hundreds of thousands of lives and has also caused enormous disruption to businesses and supply chains. Many small businesses such as restaurants have closed for good, and larger businesses have suffered enormous losses. The good news is however that off-the-shelf Nonpharmaceutical interventions (NPIs) as recommended by OSHA, ASHRAE, and other authoritative sources can reduce the risks to workers and customers, and also to continuity of operations. Some of the adaptations to the epidemic, such as working from home along with distance education and distance conferencing have proved meanwhile to be very cost effective, and a strong argument can be made for continuing to use them even after the new vaccines eradicate this disease.

While the new vaccines do look very effective against Covid-19, we must also recognize that viruses mutate—hence the need for an annual flu vaccine—which means that a new variant of Covid-19 could make a comeback and it is therefore desirable to have in-place countermeasures with which to deal with it. In addition, there is no guarantee that an entirely different disease might not appear one day as shown by the CDC's "Past Pandemics" at Covid-19 is the newest, but it is unlikely to be the last.

Areas Covered in the Session :

1.       The HEROES Act (Health and Economic Recovery Omnibus Emergency Solutions Act) would have required OSHA to develop a standard for protection against occupational exposure to pathogens such as COVID-19.

·         Even though this was not enacted into law in 2020, there is a chance that subsequent legislation may require this.

·         Even if no law or regulation requires compliance to a standard of this nature, we have an ethical obligation to protect workers, customers, and other stakeholders from Covid-19 and anything like it. There is also an overwhelming business case for ensuring continuity of operations, noting that businesses have in fact been shut down due to outbreaks while supply chains also have been affected.

2.       OSHA’s "Guidance on Preparing Workplaces for COVID-19" gives us a good idea of what to expect in a standard and can be used immediately regardless of whether a standard is developed.

3.       Planning requires consideration of two principal contagion sources; coughs and contaminated surfaces.

·         A cough is the most dangerous source of airborne contagion, so any countermeasure that will stop cough-borne viruses will stop them from ordinary speech and respiration.

·         Evidence acquired as of 2021 shows that contaminated surfaces are a relatively minor issue.

·         The workforce can create a risk register of likely contagion sources.

4.       Hierarchy of risk reduction

·         Eliminate the risk

·         Reduce the risk

·         Engineering controls that do not require vigilance or compliance

·         Administrative controls that rely on vigilance and compliance

·         Personal protective equipment (PPE) such as face masks and respirators

5.       Eliminate the risk through telecommuting, distance conferencing, and distance education. This has proven very cost-effective and should, in most cases, be continued even after the disease is eradicated.

·         Covid-19 is one virus that can't travel over the Internet (or telephone lines) even though some people once refused to take telephone calls for fear of getting polio.

6.       Reduce the risk through, for example, curbside pickup and home delivery.

·         The new vaccines also reduce the risk, and it is to be noted that the anti-Covid-19 measures taken in 2020 had the side benefit of eliminating ordinary flu almost totally because there was a vaccine for the latter.

7.       Engineering controls such as ventilation, ultraviolet light, and partitions reduce contagion and do not rely on vigilance or compliance.

8.       Administrative controls such as social distancing, as well as encouraging people who might have the disease to stay home, rely on vigilance and compliance. Staggered work shifts reduce the number of people present at any given time, and also (as proven by Henry Ford roughly 100 years ago) mitigate against rush hour congestion as well.

9.       Personal protective equipment (PPE) is a last line of defence.

·         When a job requires respiratory protection against Covid-19, a face mask will not do. Not only must respirators (such as N95 and better) be available, a documented respiratory protection program must be in place and in use. The good news is that medium risk jobs, i.e. most jobs per "Guidance on Preparing Workplaces for COVID-19," are unlikely to fall into this category.

·         The face masks in use today are actually inferior, at least in terms of sealing around the user's mouth and nose, to those used against the 1918 Spanish Flu. Even surgical masks that stop 95% of challenge particles (i.e. comparable to N95) offer no protection against contagion in air that leaks around the sides. Their performance can be improved by mask braces and mask tighteners.

·         Face shields and goggles offer protection against entry of contagious aerosols into the eyes.

·         Beware of substandard or counterfeit PPE. NIOSH maintains a data base of qualified respirator suppliers and models.

Attendees will receive a handout of the slides and accompanying notes.

Who will benefit:

All people with responsibility for reopening businesses in the aftermath of the COVID-19 outbreak, as well as people with responsibility for occupational health and safety (OH&S) compliance along with building layouts and heating, ventilation, and air conditioning (HVAC).

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Speaker: William A. Levinson,

William A. Levinson, P.E., is the principal of Levinson Productivity Systems, P.C. He is an ASQ Fellow, Certified Quality Engineer, Quality Auditor, Quality Manager, Reliability Engineer, and Six Sigma Black Belt. He is also the author of numerous books on quality, productivity, and management.

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