OSHA Updates Guidance on Preventing COVID-19 at Construction Sites | Practical Law

OSHA Updates Guidance on Preventing COVID-19 at Construction Sites | Practical Law

The Occupational Safety and Health Administration (OSHA) issued updated voluntary guidance for the construction workforce as part of the federal government's continuing efforts to reduce the risk of exposure to and spread of the 2019 novel coronavirus (COVID-19) where construction activities are continuing.

OSHA Updates Guidance on Preventing COVID-19 at Construction Sites

Practical Law Legal Update w-025-9329 (Approx. 4 pages)

OSHA Updates Guidance on Preventing COVID-19 at Construction Sites

by Practical Law Real Estate
Published on 09 Jun 2020 • USA (National/Federal)
The Occupational Safety and Health Administration (OSHA) issued updated voluntary guidance for the construction workforce as part of the federal government's continuing efforts to reduce the risk of exposure to and spread of the 2019 novel coronavirus (COVID-19) where construction activities are continuing.
On April 21, 2020, the Occupational Safety and Health Administration (OSHA) issued industry-specific alerts, including Guidelines for the Construction Workforce, to help reduce the risk of exposure to and spread of the 2019 novel coronavirus COVID-19 (see Legal Update, COVID-19: OSHA Issues Guidelines for the Construction Workforce). OSHA has now updated its guidance for preventing COVID-19 at construction sites. The updated guidance recommends the following:
  • Conducting a job hazard analysis.
  • Considering delaying non-essential activities identified to have higher exposure risk until they can be performed safely.
  • Screening calls when scheduling indoor construction work to assess potential exposures and circumstances in the work environment before worker entry.
  • Where indoor construction work is determined to be essential or emergency work, and a person suspected of having or known to have COVID-19 is present at the worksite in close proximity to where workers would be working:
    • using closed doors and walls, whenever feasible, as physical barriers to separate workers from any individuals experiencing signs or symptoms consistent with COVID-19; and
    • considering erecting plastic sheeting barriers when workers need to occupy specific areas of an indoor work site where they are in close contact (less than six feet) with someone suspected of having or known to have COVID-19.
  • Encouraging workers to:
    • stay home if they are sick;
    • cover coughs and sneezes;
    • avoid physical contact with others and directing everyone on the worksite and in work trailers to increase personal space to six feet, whenever possible; and
    • report any safety and health concerns.
  • Requesting workers to wear masks over the nose and mouth.
  • Continuing to use other normal control measures, including personal protective equipment (PPE).
  • Training workers how to properly put on, use, wear, and take off PPE.
  • Promoting personal hygiene, providing access to soap and water for handwashing, or providing alcohol-based hand rubs containing at least 60 percent alcohol.
  • Using EPA-approved cleaning chemicals from List N issued by the Environmental Protection Agency (EPA).
  • Ensuring that, before entering home environments or areas where construction is ongoing in occupied buildings, workers:
    • request that any individuals under quarantine or isolation who have been diagnosed with COVID-19 or are experiencing signs and/or symptoms of COVID-19 remain physically separated from the worker (for example, in a different room, on a different level of the home or building, or outside if weather and applicable emergency orders permit) and communicate remotely with the worker (for example, by cell phone, using internet-based payment systems and electronic signatures to confirm that work was completed);
    • ask individuals in the workplace to wear a cloth or other face covering, if available, and to cover coughs and sneezes; and
    • request that shared spaces in the construction area have good air flow, such as by turning on an air conditioner or opening windows, weather permitting, consistent with CDC recommended precautions for people in households.
  • Cleaning tools before and after use.
  • To the extent possible, screening all visitors on all construction sites in advance of their arrival on the job site for signs and symptoms of COVID-19.
  • Adopting staggered work schedules, such as providing alternating workdays or extra shifts, to reduce the total number of employees on a job site at any given time and to ensure physical distancing.
  • Identifying choke points where workers are forced to stand together, such as hallways, hoists and elevators, ingress and egress points, break areas, and buses, and implement policies to maintain social distancing.
  • In elevators and personnel hoists, ensuring six feet of distance between passengers in all directions and equipping operators with appropriate respiratory protection and other necessary PPE.
  • Coordinating site deliveries in line with the employer's minimal contact and cleaning protocols. Delivery personnel should remain in their vehicles if at all possible.
  • Instituting a rigorous housekeeping program to reduce dust levels on the job site.
  • Keeping in-person meetings as short as possible and limiting the number of workers in attendance.
  • Regularly:
    • cleaning and disinfecting portable jobsite toilets;
    • filling hand sanitizer dispensers; and
    • disinfecting frequently touched items (e.g. door pulls and toilet seats).
OSHA also identified construction tasks associated with the exposure risk levels in OSHA’s occupational exposure risk pyramid:
  • Lower. Tasks that allow employees to remain at least six feet apart and involve little contact with the public, visitors, or customers. For activities in this category, OSHA suggests that its Interim Guidance for Workers and Employers of Workers at Lower Risk of Exposure may be most appropriate.
  • Medium. Tasks that require workers to be within six feet of one another, customers, visitors, or members of the public.
  • High. Entering an indoor work site occupied by people such as other workers, customers, or residents suspected of having or known to have COVID-19, including when an occupant of the site reports signs and symptoms consistent with COVID-19. OSHA suggests that employers consider delaying this type of work according to the guidance.
  • Very High. OSHA notes that most construction work tasks are associated with no more than high exposure risks.

Practical Implications

Where construction activities continued, or are slowly being allowed to resume, the health and safety of workers should be of primary concern. Construction companies should not only implement OSHA guidance, but should carefully monitor state and local requirements for construction activities (see for example, Legal Update, COVID-19: Pennsylvania to Allow Limited Construction Activities to Resume). Project owners should request and review updated health and safety plans to ensure compliance with all applicable guidelines. The failure to comply with these requirements could result in significant fines or projects being shut down completely.
For more information on OSHA resources related to COVID-19, visit the OSHA website. For more information on COVID-19 and its implications for construction projects, see Article, COVID-19: Key Considerations for Privately Owned Construction Projects.