CDC issues detailed COVID-19 guidance for manufacturers | Vigilant

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May 14, 2020

CDC issues detailed COVID-19 guidance for manufacturers

The Centers for Disease Control and Prevention (CDC), in partnership with the federal Occupational Safety and Health Administration (OSHA), has issued interim guidance for manufacturers to protect workers from COVID-19 (coronavirus). The CDC partnered with OSHA to create the guidance. The guidance explains that workers in manufacturing may have an increased risk of contracting the virus because it’s typical for them to work in close proximity to each other for 8 to 12 hours a day, gather in groups for meals and breaks, and carpool together.

Develop a plan: The CDC recommends identifying a qualified person to be in charge of each facility’s COVID-19 assessment and control plan. You should ensure all workers know how to contact that person with any concerns. The CDC guidance contains detailed ideas for controlling COVID-19 hazards in a manufacturing environment.

Engineering controls: The section on engineering controls includes a diagram on how to align manufacturing work stations. Among other steps, the CDC recommends improving ventilation but cautions against using pedestal fans that may blow contaminated breath from one worker to another.

Administrative controls: The section on administrative controls includes recommendations such as encouraging single-file movement with six-foot physical distance between workers, when possible, and to mark the floor or use other visual cues to maintain separation.

Cloth face coverings: At last, the CDC (together with OSHA) has confirmed that cloth face coverings aren’t personal protective equipment (PPE). The cloth face coverings are intended to protect others from the wearer’s germs, while PPE protects the wearer. The guidance acknowledges that “wearing a single cloth face covering for the full duration of a work shift (e.g., eight or more hours) in a manufacturing facility may not be practical if the face covering becomes wet, soiled, or otherwise visibly contaminated during the work shift. If cloth face coverings are worn in these facilities, employers should provide readily available clean cloth face coverings (or disposable facemask options) for workers to use when the coverings become wet, soiled, or otherwise visibly contaminated.” If you determine that workers should wear cloth face coverings to protect their coworkers from exposure, the guidance says you should ensure they fit over the nose and mouth snugly but comfortably, are secured with ties or ear loops, have multiple layers of fabric, allow the employee to breathe without restriction, can be laundered and machine dried each day without losing their shape, aren’t used if they become wet or contaminated, are replaced by you as the employer as needed, and are handled as little as possible. They shouldn’t be used as a substitute for or in addition to respiratory protection when safety regulations require respiratory protection (such as protecting workers from dust particles).

Education and training: You should train supervisors and workers on how to avoid exposure to COVID-19. The guidance provides numerous links to training materials and posters.

Additional recommendations: The guidance reiterates advice about cleaning and disinfection of the workplace, screening for COVID-19 symptoms, monitoring sick workers, and managing their return to work. The guidance includes recommendations for handling PPE for workers who need it, and adds detailed advice about using face shields. The guidance ends by reminding employers that workers have a protected right to bring up safety concerns.

Tips For Employers: If you operate a manufacturing facility, review the CDC’s new recommendations to ensure you’re considering all available ideas for protecting your workers from the spread of the virus. The guidance isn’t mandatory, but states or local jurisdictions could incorporate it in their own standards. Also, failing to follow the guidance could subject you to safety complaints under OSHA’s general duty clause, especially if the suggested protective measures are feasible. If you have any questions, contact your Vigilant safety professional.

This website presents general information in nontechnical language. This information is not legal advice. Before applying this information to a specific management decision, consult legal counsel.
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About The Author

Karen Davis

Senior Employment Attorney Vigilant Law Group
  • Colorado College, B.A. in Chemistry
  • Lewis & Clark College, Northwestern Law School, J.D.
  • Attorney licensed in Oregon and California
  • Former competitive swimmer and current birder

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