We are hearing from PRISM members across the state that Cal/OSHA enforcement activity related to COVID-19 is prevalent. It has been reported that the majority of these enforcement actions (letters or unannounced visits) are responding to employee complaints received by the Division. Cal/OSHA may ask to see a copy of your agency’s written COVID-19 Prevention Plan and ensure that you have performed a comprehensive risk assessment of all work areas and tasks. To assist PRISM members with this, a COVID-19 IIPP Addendum sample for public agencies has been drafted and can be found on the PRISM COVID-19 Resources page.
The following are some specific areas of plan implementation that Cal/OSHA may want to evaluate:
Employee Training
Employers must train employees on how to limit the spread of COVID-19, including how to screen themselves for symptoms and to stay home if they have any symptoms. Cal/OSHA may ask for training records and course information associated with meeting this training requirement.
Our partner TargetSolutions has developed a series of 7 online Coronavirus Courses including, Coronavirus 101: What You Need to Know, that covers this basic information.
Required Use of Face coverings
Does your workplace specific COVID-19 prevention plan address the requirements around face coverings? Are employees and others entering the establishment complying with your plan?
Individual Control Measures and Screening
This includes social distancing protocols, use of face coverings, handwashing and signage to remind workers of these prevention measures.
Cleaning and Disinfecting Protocols
Maintenance and cleaning in common areas should be increased. The Division may ask for copies of your cleaning logs as well as what disinfectants are in use and if safety data sheets (SDS) have been made available for those products. Employers should use products approved for use against COVID-19 found on the EPA approved list.
Cal/OSHA has provided guidance on all of the topics listed above in their industry specific guidance documents. The most general of these documents is for office settings, COVID-19 Industry Guidance: Office Workspaces. The Division has also created a related Checklist for Office Workspaces, that can be used to check your agency compliance with the guidance.
Compliance with Local Health Orders
Do your policies and practices align with the local and current public health orders? You may be asked you to provide a copy of the local order with your response.
Contact Risk Control for additional information about these resources or if we can be of further assistance.