2020 - How to Prepare for the New OSHA Requirements Under the HEROES Act for COVID-19 Prevention: An Employer’s Guide

OVERVIEW
The COVID-19 outbreak has already caused enormous human and economic damage, and is making a dangerous resurgence because people are letting their guard down, not using face masks, and ignoring social distancing guidelines much as they did in 1918. The disease has also undergone mutations that make it more contagious and may defeat the vaccines that are in the pipeline.
The best way for getting your workplace ready for COVID-19 while protecting employees and other stakeholders is to implement controls that impede the disease's propagation. This makes their implementation imperative regardless of when and if the HEROES Act becomes law. The best controls eliminate the hazard through measures like telecommuting, distance education, and distance conferencing, all of which have proven highly successful. Engineering controls such as partitions and air handling systems suppress the hazard and do not rely on vigilance and compliance, while administrative controls like social distancing require people to pay attention to them. Personal protective equipment (PPE) such as face masks and respirators are a last line of defense but they can be a very effective one.
WHY SHOULD YOU ATTEND
The good news is that most jobs defined as medium risk (and this encompasses most jobs outside health care and emergency response) per "Guidance on Preparing Workplaces for COVID-19" will not require respiratory protection but those that do require not just the availability of NIOSH compliant respirators, but also a respiratory protection program that meets OSHA requirements. Jobs that do not require this level of protection, as well as the general public, can make do with face masks, but not all face masks are equal. The webinar will offer substantial guidance along these lines.
AREAS COVERED
1. The HEROES Act will require OSHA to develop regulations for worker protection against COVID-19, and workplaces will have to comply with these regulations. Even if the HEROES Act does not become law, workplaces need to implement programs and activities to protect workers and other stakeholders and ensure continuity of operations should COVID-19 ever make a comeback, as it is already doing in mid-2020, in its current form or a mutated one.
2. Planning principles
• Planning should encompass two major contingencies; contagion from a cough, and contagion from contaminated surfaces. Countermeasures against a cough will also work against ordinary speech and respiration, but not necessarily the other way around.
• Create a risk register of activities and/or locations where people might be exposed to contagion. Seek input from workers and others who are positioned ideally to recognize risks.
• Hierarchy of controls, from most to least effective: eliminate the hazard, reduce the hazard, engineering controls that do not rely on vigilance or compliance, administrative controls that do, and personal protective equipment (PPE).
3. Eliminate the hazard through telecommuting, distance education, and remote conferencing. Contagion over phone lines and the Internet is physically impossible. This approach also eliminates costs associated with physical office space or classrooms, commuting, and lodging.
4. Reduce the hazard, e.g. with drive-up rather than in-office banking.
5. Engineering controls do not rely on vigilance and compliance.
• Distance between respiratory tracts can be added with partitions, and without the need for more floor space per person or customer.
• Air handling systems can play a major role in suppressing contagion, and ASHRAE offers extensive guidance.
6. Administrative controls rely on vigilance and compliance to work.
• Staggered shifts reduce the number of people present at any given time.
• Wearable devices (proximity sensors) promote social distancing by telling people when they are too close to one another.
7. Personal protective equipment (PPE)
• Most jobs are "moderate risk" as defined by OSHA's "Guidance on Preparing Workplaces for COVID-19" and should therefore not require respiratory protection.
• Where respiratory protection is required, face masks will not do. Respirators (e.g. N95 and better) that meet NIOSH requirements are required along with a respiratory protection program that meets OSHA requirements.
• Face masks can be used for individual protection where respirators are not required, but not all face masks are equal. Surgical masks that meet ASTM requirements are known quantities and their performance can arguably be enhanced with surgical mask sealers and face mask tighteners that improve the seal between the face and the mask.
• Beware of counterfeit PPE, especially respirators that claim to be N95 (or better) and may use the names and model numbers of reputable manufacturers.
Attendees will receive a copy of the slides and accompanying notes, and a handout on respiratory protection. Disclaimer; no part of this presentation constitutes formal engineering or occupational health and safety advice. Attendees are encouraged to consult the material from OSHA, ASHRAE, and the other sources that will be cited in the presentation.
LEARNING OBJECTIVES
The HEROES Act (Health and Economic Recovery Omnibus Emergency Solutions Act) will require employers to comply with new OSHA regulations for workforce protection against COVID-19 and similar contagious diseases. This webinar will cover the likely (as shown by OSHA Guidance on Preparing Workplaces for COVID-19) requirements along with off-the-shelf countermeasures against COVID-19, most of which are already being deployed with substantial success. It will also cover the use of respirators and face masks for individual as well as workplace protection.
WHO WILL BENEFIT
All people with responsibility for reopening businesses in the aftermath of the COVID-19 outbreak, as well as people with responsibility for occupational health and safety (OH&S) compliance along with building layouts and heating, ventilation, and air conditioning (HVAC).
SPEAKER
Years of Experience: 30+ years
Areas of Expertise: Statistical Process Control, Lean Manufacturing, Quality, ISO 9001, Design Of Experiments, Non-Normal Distributions, Quality Management Systems
William Levinson is the principal of Levinson Productivity Systems, P.C. He is an ASQ Fellow, Certified Quality Engineer, Quality Auditor, Quality Manager, Reliability Engineer, and Six Sigma Black Belt. He holds degrees in chemistry and chemical engineering from Penn State and Cornell Universities, and night school degrees in business administration and applied statistics from Union College, and he has given presentations at the ASQ World Conference, ISO/Lean Six Sigma World Conference, and others.
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