Protecting Workers: Guidance on Mitigating and Preventing the Spread of COVID-19 in the Workplace - Northern Michigan University

The following is an excerpt from the United States Department of Labor / Occupational Safety and Health Administration publication "Protecting Workers: Guidance on Mitigating and Preventing the Spread of COVID-19 in the Workplace." The full guidance is available at https://www.osha.gov/coronavirus/safework#what-workers-need-to-know

SARS-CoV-2, the virus that causes COVID-19, spreads mainly among unvaccinated people who are in close contact with one another - particularly indoors and especially in poorly ventilated spaces.

Vaccination is the key element in a multi-layered approach to protect workers. Learn about and take advantage of opportunities that your employer may provide to take time off to get vaccinated. Vaccines authorized by the U.S. Food and Drug Administration are highly effective at protecting vaccinated people against symptomatic and severe COVID-19 illness and death. According to the CDC, a growing body of evidence suggests that fully vaccinated people are less likely to have symptomatic infection or transmit the virus to others. See CDC's Guidance for Fully Vaccinated People; and Science Brief.

You should follow recommended precautions and policies at your workplace. Multi-layered controls tailored to your workplace are especially important for those workers who are unvaccinated or otherwise at-risk. Many employers have established COVID-19 prevention programs that include a number of important steps to keep unvaccinated and otherwise at-risk workers safe. These COVID-19 prevention programs include measures such as telework and flexible schedules, engineering controls (especially ventilation), administrative policies (e.g., vaccination policies), PPE, face coverings, physical distancing, and enhanced cleaning programs with a focus on high-touch surfaces.

In addition, the CDC recommends that fully vaccinated people wear a mask in public indoor settings if they are in an area of substantial or high transmission. Fully vaccinated people might choose to mask regardless of the level of transmission, particularly if they or someone in their household is immunocompromised or at increased risk for severe disease, or if someone in their household is unvaccinated. Ask your employer about plans in your workplace. In addition, employees with disabilities who are at-risk may request reasonable accommodation under the ADA.

Even if your employer does not have a COVID-19 prevention program, if you are unvaccinated or otherwise at risk, you can help protect yourself by following the steps listed below:

• You should get a COVID-19 vaccine as soon as you can. Ask your employer about opportunities for paid leave, if necessary, to get vaccinated and recover from any side effects.
• Properly wear a face covering over your nose and mouth. Face coverings are simple barriers worn over the face, nose and chin. They work to help prevent your respiratory droplets or large particles from reaching others. Individuals are encouraged to choose higher quality masks so that they are providing a greater measure of protection to themselves as well as those around them. CDC provides general guidance on masks, including face coverings.
• If you are working outdoors, you may opt not to wear face coverings in many circumstances; however, your employer should support you in safely continuing to wear a face covering if you choose, especially if you work closely with other people.
• Unless you are fully vaccinated and not otherwise at-risk, stay far enough away from other people so that you are not breathing in particles produced by them – generally at least 6 feet (about 2 arm lengths), although this approach by itself is not a guarantee that you will avoid infection, especially in enclosed or poorly ventilated spaces. Ask your employer about possible telework and flexible schedule options at your workplace, and take advantage of such policies if possible. Perform work tasks, hold meetings, and take breaks outdoors when possible.
• Participate in any training offered by your employer/building manager to learn how rooms are ventilated effectively, encourage your employer to provide such training if it does not already exist, and notify the building manager if you see vents that are clogged, dirty, or blocked by furniture or equipment.
• Practice good personal hygiene and wash your hands often. Always cover your mouth and nose with a tissue, or the inside of your elbow, when you cough or sneeze, and do not spit. Monitor your health daily and be alert for COVID-19 symptoms (e.g., fever, cough, or shortness of breath). See CDC’s Daily Activities and Going Out and CDC’s Interim Public Health Recommendations for Fully Vaccinated People.
• Get tested regularly, especially in areas of substantial or high community transmission.

COVID-19 vaccines are highly effective at keeping you from getting COVID-19. If you are not yet fully vaccinated or are otherwise at risk, optimum protection is provided by using multiple layers of interventions that prevent exposure and infection.

The Roles of Employers and Workers in Responding to COVID-19

Under the OSH Act, employers are responsible for providing a safe and healthy workplace free from recognized hazards likely to cause death or serious physical harm.

CDC's Interim Public Health Recommendations for Fully Vaccinated People explains that under some circumstances, fully vaccinated people need not take all the precautions that unvaccinated people should take, except where required by federal, state, local, tribal, or territorial laws, rules and regulations, including local business and workplace guidance. However, in light of evidence related to the Delta variant of the SARS-CoV-2 virus, the CDC updated its guidance to recommend that even people who are fully vaccinated wear a mask in public indoor settings in areas of substantial or high transmission, or if they have had a known exposure to someone with COVID-19 and have not had a subsequent negative test 3-5 days after the last date of that exposure. Schools should continue to follow applicable CDC guidance, which recommends universal indoor masking for all teachers, staff, students, and visitors to K-12 schools, regardless of vaccination status.

Under OSHA guidelines, NMU should: 

1. Facilitate employees getting vaccinated. 

2. Instruct any workers who are infected, unvaccinated workers who have had close contact with someone who tested positive for SARS-CoV-2, and all workers with COVID-19 symptoms to stay home from work to prevent or reduce the risk of transmission of the virus that causes COVID-19. 

3. Implement physical distancing in all communal work areas for unvaccinated and otherwise at-risk workers. 

4. Provide workers with face coverings or surgical masks, as appropriate, unless their work task requires a respirator or other PPE. 

5. Educate and train workers on your COVID-19 policies and procedures using accessible formats, including: 
   1. Basic facts about COVID-19, including how it is spread and the importance of physical distancing (including remote work), ventilation, vaccination, use of face coverings, and hand hygiene.

   2. Workplace policies and procedures implemented to protect workers from COVID-19 hazards.

   3. In addition, ensure that workers understand their rights to a safe and healthful work environment, whom to contact with questions or concerns about workplace safety and health, and their right to raise workplace safety and health concerns free from retaliation. At NMU, contact safeoncampus@nmu.edu with questions or concerns. 

6. Suggest or require that unvaccinated customers, visitors, or guests wear face coverings in public-facing workplaces such as retail establishments, and that all customers, visitors, or guests wear face coverings in public, indoor settings in areas of substantial or high transmission. 

7. Maintain Ventilation Systems. 

8. Perform routine cleaning and disinfection. 

9. Record and report COVID-19 infections and deaths. 

10. Implement protections from retaliation and set up an anonymous process for workers to voice concerns about COVID-19-related hazards. 
    
    At NMU, contact safeoncampus@nmu.edu with questions or concerns. 

11. Follow other applicable mandatory OSHA standards.