Author Archives: Rory McKinnon

Reporting Occupational Illness during COVID-19 Pandemic

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OSHA has issued interim guidance that went into effect on 26 May 2020 regarding the reporting of occupational illnesses, specifically COVID-19.  The interim guidance will remain in effect until further notice and is intended to coincide with the current public health threat.  Following OSHA’s recordkeeping guidance, COVID-19 is a recordable illness and must be documented by the employer if the case is:

  1. A confirmed case of COVID-19, as defined by the Centers for Disease Control and Prevention (CDC);[2]
  2. Work-related as defined by 29 CFR § 1904.5;[3] and
  3. Involves one or more of the general recording criteria set forth in 29 CFR § 1904.7.[4]

Because there has been difficulty in determining the origin of the illness in some workers, OSHA has also established guidelines for Compliance Safety and Health Officers (CSHO) to follow when investigating a COVID-19 case.  It would be beneficial for employers to review and understand these guidelines to ensure compliance with interim directives.  The guidelines are included in the release message located here.

OSHA Respiratory Protection Enforcement Guidance

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OSHA has released two memorandas outlining guidelines for respiratory protection during the current global pandemic. The first memorandum outlines enforcement discretion to permit extended use and reuse of respirators, along with using respirators that are beyond their manufacturer’s recommended shelf life. It provides specific guidance to healthcare personnel and workers exposed to respiratory hazards impacted by shortages of equipment due to COVID-19. Memorandum 2 provides guidance on the use of N95 respirators that are not approved by NIOSH if all of the provisions in memorandum 1 have been exhausted.

All employers are being asked to re-evaluate engineering and administrative controls to determine any changes that could reduce respiratory protection dependency. If respiratory protection is still necessary, employers should look for alternatives to N95 respirators that would provide the same or more protection. If an employer can demonstrate that all options under these guidelines were exhausted, then reuse or the use of expired N95s approved by NIOSH could be considered.

OSHA’s prioritization of product usage is as follows:

  • NIOSH-certified equipment; then
  • Equipment certified in accordance with standards of other countries or jurisdictions except the People’s Republic of China, unless equipment certified in accordance with standards of the People’s Republic of China is manufactured by a NIOSH certificate holder; then
  • Equipment certified in accordance with standards of the People’s Republic of China, the manufacturer of which is not a NIOSH certificate holder; then
  • Facemasks (e.g., medical masks, procedure masks).

There are some concerns by Industrial Hygiene professionals that OSHA does not offer guidance on enforcement for those non-healthcare companies that are following the recommendations of the Federal government to donate their supplies of N95 respirators. It is important for each employer to review the interim guidance and make a strong assessment of their respiratory protection needs.

March HAZWOPER Challenge

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The March HAZWOPER Challenge is now closed. Thank you for participating. Please come back April 1st for our next HAZWOPER Challenge!

We stumped you again for the month of March!

Please note that all the answers were available in our refresher study guide, the OSHA standards, the 2016 ERG, or online.

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