OSHA has issued coronavirus-related guidance for construction employers and workers. The guidance includes recommended actions to reduce the risk of exposure to the coronavirus. This guidance supplements the general guidance for all workers and employers of workers with potential occupational exposures to SARS-CoV-2.
Employers of constructions workers (including carpenters, ironworkers, plumbers, electricians, HVAC workers, utility construction workers, and earthmoving workers) should remain alert to changing outbreak conditions, especially as related to community spread of the virus and testing availability. As states progress through the phases of the Guidelines for Opening up America Again, each workplace can likely adapt this guidance to better suit evolving risk levels and necessary control measures for specific workplaces.
Construction Work Tasks Associated with Exposure Risk Levels
Assess the hazards your workers may be exposed to, evaluate the risk of the exposure, and select, implement, and ensure workers use controls to prevent exposure. The following points describe construction work tasks associated with the exposure risk levels in OSHA’s occupational exposure risk pyramid, which may serve as a guide to employers in this sector:
- Lower Risk (Caution): Tasks that allow employees to remain at least 6 feet apart and involve little contact with the public, visitors, or customers.
- Medium Risk: Tasks that require workers to be within 6 feet of one another, or within 6 feet of customers, visitors, or members of the public.
- High Risk: Entering an indoor work site occupied by other workers, customers, or residents suspected or having, or known to have, COVID-19.
If you determine activities in your workplace have higher exposure risks, and those activities are non-essential, consider delaying them until they can be performed safely.
In the indoor construction environment, when work is determined to be essential, and a person suspected of having or known to have COVID-19 is in close proximity to where workers would be working, there are a couple precautions you could take:
- Use closed doors and walls as physical barriers to separate workers from individuals showing signs or symptoms of COVID-19.
- Consider erecting plastic sheeting barriers when workers are working within 6 feet of individuals showing signs or symptoms of COVID-19.
Throughout the pandemic, periodically reassess engineering controls to identify any changes that can be made to decrease the need for N95 respirators and other personal protective equipment ordinarily used for work activities that involve exposure to hazardous substances.
Use administrative controls to reduce or eliminate the risk of exposure. Implement and update policies to reflect: standard operating procedures that follow the CDC, OSHA, state/territorial, and local guidelines for preventing the spread of COVID-19 infection; training for employees on the spread of the disease in the geographic areas in which they work; and screening calls when scheduling indoor construction work to assess potential exposures and circumstances in the work environment, before worker entry.
Standard Operating Procedures
Implement standard operating procedures and employee training to ensure that, before entry into home environments or occupied buildings, workers: request that any individuals under quarantine or in isolation who have been diagnosed with, or have symptoms of, COVID-19 remain physically separated from the worker and communicate remotely; ask individuals in the workplace to wear a cloth or other face covering 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.
It is important to train construction workers on:
- The signs and symptoms of COVID-19, as well as how the disease is potentially spread.
- All policies and procedures applicable to the employee’s duties as they relate to potential exposures to SARS-CoV-2, as well as providing a written copy of the procedures.
- Information on appropriate social distancing and hygiene practices.
- The types, proper use, limitations, location, handling, decontamination, removal, and disposal of any PPE being used.
- The importance of staying home if they are sick.
- Wearing masks over their noses and mouths to prevent spreading the virus.
- The need to continue using normal control measures, including PPE, to protect workers from other job hazards associated with construction activities.
- Using EPA-approved cleaning chemicals from list N or that have label claims against the coronavirus for cleaning frequently touched surfaces.
- The need to report and safety and health concerns.
Below, there are three sample questions for screening work assignments before sending a worker to perform indoor construction activities in an environment that may be occupied by a homeowner, customer, worker, or another occupant, and a recommended action for each. Preface these questions by explaining that they are being asked to protect workers and minimize the spread of COVID-19.
- Is the construction work essential, urgent, or emergency work?
- If yes, proceed with a hazard assessment to determine how to proceed while minimizing exposure for the worker.
- Are there any individuals in the worksite under quarantine or isolation due to a confirmed case of COVID-19?
- If yes, closely follow recommended infection prevention measures.
- If the work is determined to be essential, urgent, or emergency work, are there any individuals or contractors on the worksite suffering flu-like symptoms?
- If yes, closely follow recommended infection prevention measures.
Safe Work Practices
To the extent possible, screen all visitors on all construction sites in advance of their arrival on the job site for signs and symptoms of COVID-19. Employers should also adopt staggered work schedules to reduce the total number of employees on a job site at any given time. It may be helpful to identify choke points where workers are forced to stand together and implement policies to maintain social distancing. Additionally, coordinate site deliveries in line with the employer’s minimal contact and cleaning protocols. It is also important to keep in-person meetings as short as possible, limit the number of workers in attendance, and use social distancing practices.
Personal Protective Equipment
Under OSHA’s PPE standards for construction, employers must consider whether their hazard and risk assessments indicate a need for the use of more protective PPE. Make every effort to protect workers through measures other than PPE. When workers need PPE, employers must comply with OSHA’s standards for PPE construction. In limited circumstances, including situations involving close contact with someone with suspected or confirmed COVID-19, respiratory protection may be needed and must be provided by the employer; this respiratory protection must comply with OSHA’s Respiratory Protection Standard.
Through our decades of experience in the construction and legal industries, we have the knowledge and experience needed to efficiently and effectively address any legal situation that might arise. For help with construction-related OSHA matters, please call (312) 894-3322 to speak with an OSHA attorney or contact us here.