In an effort to prevent the spread of COVID-19 at construction sites, the Occupational Safety and Health Administration (OSHA) recently released guidance for construction industry employers (available here).
These rules, summarized below, supplement the safe workplace rules for construction sites issued in early April 2020, by the Connecticut Department of Economic and Community Development (DECD) and the Connecticut Department of Public Health (DPH) pursuant to Executive Order 7V. We discussed the DECD/DPH rules in a previous alert accessible here.
The supplemental OSHA guidance builds on the general safe workplace guidance provided by OSHA for all employers and workers by providing certain specific recommendations for construction industry participants, including those engaged in carpentry, electrical, masonry, plumbing, ironwork, HVAC, earthmoving, and other trade work. The supplemental guidance is geared toward construction tasks with medium-to-high exposure risk levels, meaning tasks in which workers are required to be within six feet of one another or customers or work indoors.
Guidance for Workers
- Practice social distancing to the extent feasible.
- Wear a cloth face covering, especially when social distancing is impractical or impossible. OSHA warns that a single cloth face covering may not be adequate protection for a full shift so employers should plan accordingly.
- Most construction workers are unlikely to need Personal Protective Equipment (PPE) beyond what they already wear, i.e. hard hats, gloves, safety glasses, face masks. However, employers must evaluate the risks associated with each job to determine if additional PPE is needed.
Guidance for Job Sites
- Before work begins, evaluate whether certain tasks, especially indoor work, can be postponed or rescheduled for a time when fewer workers may be on site.
- For most outdoor tasks, workers should maintain social distancing to the extent feasible and always wear a cloth face covering.
- For indoor work that cannot be postponed, use closed doors, walls, or plastic sheeting as barriers to help maintain a safe distance between workers, especially if any person on site (worker or customer) has been exposed to COVID-19. Employers should continue to reevaluate barrier locations as work progresses to maintain effectiveness and social distancing.
- Identify "choke points" where workers are forced into close quarters (e.g., hallways, doorways, hoists) and look for ways to mitigate congestion.
- To the extent practicable, adopt staggered work schedules to reduce the number of workers on site at a time. This includes staggering breaks for rest, lunch, etc.
- Keep in-person meetings brief, socially distant, and outdoors if possible.
- Practice good housekeeping in meeting areas and restrooms. Use cleaning products approved by the EPA for use against the coronavirus, a list of which is available here.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.