Best Practices

An Employer’s Guide To COVID-19 Emergency Planning

OSHA has issued general guidance for employers

This article addresses steps employers should take in emergency and business continuity planning during a pandemic such as COVID-19.[1] Although the federal Occupational Safety and Health Administration has not adopted a standard addressing employers’ obligations to safeguard employees during a pandemic, OSHA has issued general guidance for employers as a direct result of the COVID-19 outbreak in the U.S.[2]

The OSHA guidance (which is not mandatory as it does not constitute a law or regulation) encourages employers ‎to take all the following actions during COVID-19:‎

  • Create an infectious disease preparedness and response plan. This plan should:
    • Identify potential sources of infection ‎inside and outside of the workplace.
    • Identify and implement controls to reduce exposure, such as use of ‎personal protective equipment.
    • Prepare for increased absenteeism and supply chain disruptions.
    • Consider downsizing or closing operations‎.
  • Prepare and implement basic infection prevention measures not included in existing OSHA requirements. These measures should encourage:
    • Handwashing;
    • Covering coughs and ‎sneezes;
    • Social distancing; and
    • Employees to stay home if they are ill‎.
  • Develop procedures for prompt identification and isolation of ill employees and visitors.
  • Consider and implement flexible work arrangements, such as working remotely, reducing hours, and alternating ‎schedules.
  • Adhere to OSHA standards for sanitary workplace. 

Exposure-Risk Categories

On April 13, OSHA also issued a coronavirus response plan titled “Interim Enforcement Response Plan for Coronavirus Disease 2019.”[3] The plan describes the following three exposure-risk categories applicable in various work settings.‎

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