Manufacturing

Preparing for OSHA Requirement: Off the Shelf Solutions for Workplace COVID-19 Protection

Overview:

The recent resurgence in Covid-19 cases has resulted in calls for another nation-wide shutdown to prevent the disease from spreading and overwhelming hospitals. A wide array of countermeasures from OSHA, ASHRAE (American Society of Heating, Refrigerating and Air-Conditioning Engineers), and other authoritative sources is however readily available to workplaces to protect workers and other stakeholders (such as customers) to make a shutdown unnecessary. The effectiveness of ordinary face masks can meanwhile be increased enormously, and at little cost. This presentation will cover these non-pharmaceutical interventions (NPIs) and provide links to the authoritative sources in question.

What Will You Learn?

1.    The bad news is that Covid-19 is making a comeback, and one company was shut down after an outbreak. The good news is however that OSHA’s "Guidance on Preparing Workplaces for COVID-19" (March 2020) gives us a good idea of what to expect in a standard or regulation. Its contents can be used immediately, and have been used in workplaces around the country.

2.    Planning considerations are relatively simple and straightforward, although any OSHA regulation is likely to require a documented program for Covid-19 prevention. Planners need to account for two very specific risks:

·         Contagion from a cough is probably the most dangerous risk as it can project contagious aerosols to 10 or more feet (as determined in 1918 in the context of the worldwide flu epidemic). Countermeasures against a cough will protect against contagion from ordinary respiration and speech, but not necessarily the other way around.

·         Contagion from contaminated surfaces is a secondary risk.

·         Create a risk register of activities (processes) and/or locations that might expose people to these risks. "By location" may be better because many locations, such as elevators, are not part of any workplace process.

·         The good news is that most jobs outside of health care and emergency response seem to fall into "medium risk" as defined by OSHA, for which a formal respiratory protection program (and respirators as opposed to face masks) will not be required.

3.    Hierarchy of controls, in order of preference

·         Eliminate the risk.

·         Reduce the risk

·         Engineering controls protect us regardless of vigilance or compliance

·         Administrative controls, such as admonitions to stay 6 feet or more away from other people, rely on vigilance and compliance, and often do not work (although they can be improved to some degree)

·         Personal protective equipment (PPE) is a last line of defense and not a license to engage in risky behavior such as large gatherings.

4.    Eliminate the hazard

·         Coronavirus cannot travel across phone lines or the Internet so telecommuting, distance education, and distance conferencing reduce the risk to zero.

·         Organizations that have been forced to resort to telecommuting and distance educations have discovered that these approaches eliminate substantial costs, and there are strong business arguments for continuing them even after a vaccine becomes available as expected in 2021. They can, for example, eliminate the cost of doing business in a large city.

5.    Reduce the hazard

·         Home delivery, curbside pickup, and drive-up banking all serve to reduce the risk although they do not eliminate it entirely.

6.    Engineering controls

·         Distance (between respiratory tracts) is our friend. Distance can be added with partitions, e.g. between restaurant tables, without the need for more floor space.

·         Improved ventilation reduces the amount of contagious material present. Ultraviolet air disinfection has been around for roughly 70 years and is a readily available off the shelf solution. ASHRAE's web site offers extensive guidance.

7.    Administrative controls

·         Social distancing relies on vigilance and compliance, which appear to drop off in stores (except in checkout lanes where markers tell people where to stand). Personal care (e.g. barber shop) by appointment, however, reduces the number of people waiting which improves convenience while reducing the risk of getting Covid-19.

·         Staggered work shifts reduce the number of people present in the workplace at any time.

·         Attendance policies should discourage people who might have the disease from going to work, as opposed to making them feel compelled to do so to avoid missing paychecks or other negative consequences. Temperature checks are good but not certain because many asymptomatic people do not run fevers.

8.    Personal protective equipment (PPE)

·         When a job requires respiratory protection (as defined by OSHA), face masks will not do. A formal respiratory protection program is required, and this includes not just provision of respirators (e.g. N95 or better) but also a fit testing program and other considerations. The good news is however that medium risk jobs are unlikely to require this.

·         Respirators—and N100 or P100 is more than 150 times as good as N95—offer the best protection not only due to the fact that their filters will stop 95% (N95) to 99.97% (N100 or P100) of challenge particles but also the fact that they seal completely around the user's nose and mouth.

·         Face masks offer protection that ranges from extremely good (e.g. ASTM Level 2 and Level 3 surgical masks) to practically useless depending on the material of construction. Their failure to seal around the nose and mouth detracts substantially from their performance but this can be addressed inexpensively with mask tighteners and mask braces, e.g. as described by FixTheMask.com. The Durand hospital mask of 1918, which fastened behind the head, was meanwhile far superior to the ear loop masks in use today, at least in terms of preventing leakage around the sides.

·         Beware of counterfeit and substandard PPE. Unscrupulous sellers are offering counterfeit respirators, and also face masks with dubious claims, to people who are rightly frightened of Covid-19.

·         Face protection, such as face shields and chemical protective goggles, may reduce the risk three-fold by protecting the eyes from contagious aerosols. (Gillespire, Claire. 2020. "Should You Wear Goggles to Protect Against Coronavirus? Here's What Experts Told Us."  https://www.health.com/condition/infectious-diseases/coronavirus/goggles-covid and Dr. Fauci also has recommended this.)

Disclaimer; nothing in this presentation constitutes formal engineering or occupational health and safety advice.

Benefits for Attending:

Attendees will learn, and be able to deploy, a wide array of highly effective actions, e.g. as offered by OSHA, ASHRAE, and other sources, to protect workers and other stakeholders from Covid-19 to ensure stakeholder safety along with continuity of operations. These include engineering and administrative controls, and personal protective equipment (PPE), when it is not possible to eliminate the risk completely through work-from-home, distance education, and remote conferencing.

Who Should Attend?

·         C-level Executive

·         OSHA Professionals

·         EHS Personals.

·         All Managers

·         Safety/ Security Professionals

·         Office layout planner, and others with responsibility for mitigation of COVID-19 risks.

·         Human Resource Professionals

·       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).

(NOTE: Attendees will receive a copy of the slides and accompanying notes, including links to the cited references, as a pdf handout)