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OSHA Issues COVID-19 Return-to-Work Guidance for Retail, Construction, Manufacturing and Package Delivery Industries

• Apr 27, 2020

Businesses in retail, construction, manufacturing and package delivery should review recently issued industry-specific guidance from Occupational Health and Safety Administration (OSHA) as shelter-at-home orders expire and employees return to work. Following these recommendations from OSHA will help employers contain the COVID-19 pandemic while continuing to operate.

Common guidance among these industries includes encouraging workers to stay home if they are sick, allowing use of masks and other personal protective equipment (PPE), promoting safe respiratory hygiene practices such as covering sneezes and hand-washing or using alcohol-based hand rubs, and encouraging workers to report any safety and health concerns. OSHA also recommends frequent cleaning of commonly touched surfaces using chemicals approved for destroying the coronavirus. All employers should also monitor public health communications about COVID-19 recommendations for the workplace and ensure that workers have access to and understand that information.

Guidance for Retail Workers

• Practice social distancing, maintaining six feet between co-workers and customers, where possible. For example, demarcate six-foot distances with floor tape in checkout lines. Workplaces where social distancing is a challenge should consider innovative approaches, such as opening only every other cash register, temporarily moving workstations to create more distance, and installing plexiglass partitions.
• Use a drive-thru window or curbside pickup.
• Provide workers and customers with tissues and trash receptacles.
• Train workers in proper hygiene practices and the use of workplace controls.
• Maintain regular housekeeping practices, including routine cleaning and disinfecting of surfaces and equipment.

Guidance for the Construction Workforce

• Advise workers to avoid physical contact with others, and direct all people on the job site to increase personal space to at least six feet, where possible. Where work trailers are used, all workers should maintain social distancing while inside the trailers.
• Continue to use other normal control measures, including PPE, to protect workers from other job hazards associated with construction activities.
• Train workers in how to properly put on, use and wear, and take off protective clothing and equipment.
• To the extent tools or equipment must be shared, provide and instruct workers to use alcohol-based wipes to clean tools before and after use. When cleaning tools and equipment, workers should consult manufacturer recommendations for proper cleaning techniques and restrictions.
• Keep in-person meetings (including safety meetings) as short as possible, limit the number of workers in attendance, and use social distancing practices.
• Clean and disinfect portable job site toilets regularly. Hand sanitizer dispensers should be filled regularly. Frequently touched items (i.e., door pulls and toilet seats) should be disinfected.

Guidance for the Manufacturing Industry

• Establish flexible work hours such as staggered shifts, if feasible.
• Where possible, discourage workers from using other workers’ tools and equipment. To the extent tools or equipment must be shared, provide and instruct workers to use alcohol-based wipes to clean tools before and after use.
• Practice sensible social distancing and maintain six feet between co-workers, where possible.
• For work activities where social distancing is a challenge, consider limiting the duration of these activities or implementing innovative approaches, such as temporarily moving or repositioning workstations to create more distance or installing barriers (e.g., plexiglass shields) between workstations.
• Train workers on how to properly put on, use and wear, take off, and maintain protective clothing and equipment.

Guidance for Package Delivery Workforce

• Minimize interaction between drivers and customers by leaving deliveries at loading docks, doorsteps, or other locations that do not require person-to-person exposure.
• Discourage workers from using other workers’ tools and equipment.
• Establish flexible work hours (e.g., staggered shifts) where feasible.
• Practice sensible social distancing and maintain six feet between co-workers where possible.

Dysart Taylor shareholder/director Anne E. Baggott and associate Brandi Spates are experienced employment lawyers. They can be reached at [email protected] or 816-714-3022 and [email protected] or 816-714-3035, respectively.