The Occupational Safety and Health Administration released guidance to help employers prepare their workplaces for an outbreak of COVID-19 — along with a reminder that any incidents of employees contracting the novel coronavirus at work are recordable illnesses, subject to the same rules and failure-to-record fines as other workplace injuries and illnesses.
While OSHA specifically exempts employers from recording incidents of employees contracting common colds and the flu in the workplace, COVID-19 is not exempt, the agency noted on a newly added website providing OSHA guidance for preventing occupational exposure to the rapidly spreading virus.
The guidance, while not a standard or regulation, outlines safety standards that employers whose workers are at high risk of contracting COVID-19 should implement to remain in compliance with the Occupational Safety and Health Act’s general duty clause.
The report also advises employers to develop an infectious disease preparedness and response plan, implement basic infection prevention measures and develop policies for the identification and isolation of ill individuals.
OSHA recently unveiled the top 10 violations of 2019. It was no surprise that familiar violations from the past few years crowded the list. Fall protection led the list with more than 6,000 violations, followed by more than 3,500 violations of the hazard communication standard.
- Fall Protection – General Requirements – 6,010 violations. This is the ninth year in a row this Construction standard has had the most OSHA violations. Among those most cited: roofing contractors, masonry contractors, and commercial and home builders.
- Hazard communication – 3,671 violations. Problems that come up the most: no hazcom program, no worker training on hazcom, and lack of safety data sheets (SDSs). Employers most cited: masonry contractors, painting and wall covering contractors, machine shops, and general contractors.
- Scaffolding – 2,813 violations. Where companies are going wrong: Using cross-braces as scaffold access, not fully planking, scaffolds not on firm foundations, and no guardrails. Employers most cited: masonry contractors, roofing contractors and commercial builders.
- Lockout/tagout – 2,606 violations. Companies cited don’t have LO/TO rules for specific machines, employees aren’t trained, there’s no periodic evaluation of the program, and LO/TO devices aren’t affixed. Among industries most cited: product manufacturing and sawmills.
- Respiratory protection – 2,450 violations. Companies aren’t providing employees with a medical evaluation before they use respirators, they don’t have a respiratory protection program, and employees don’t receive a fit test. Most cited: Auto maintenance, masonry contractors, cut stone contractors and painting and wall covering contractors.
- Ladders – 2,345 violations. Problems inspectors find most: ladders not extending at least three feet above a landing, using the wrong type of ladder, employees using the top step, and ladder structural defects. Most cited: Roofing, framing, siding and painting contractors.
- Powered Industrial Trucks – 2,093 violations. Problems inspectors find most: trucks not operating in a safe manner, operators not re-evaluated every three years, no certificate of training, and trucks in unsafe condition. Most cited: warehouses, framing contractors and machine shops.
- Fall protection – Training requirements – 1,773 violations. Inspectors find employees weren’t provided training, there’s no written certification, training is inadequate, and employees don’t retain training. Most cited: roofing, framing, siding, commercial and residential contractors.
- Machine guarding – 1,743 violations. Employers aren’t guarding points of operation; equipment isn’t anchored properly and fan blades aren’t guarded. Most cited: machine shops and metal shops.
- Personal protective equipment – eye and face protection – 1,411 violations. Workers aren’t protected from flying parts, liquid chemicals and radiant energy (welding), and there’s no side protection for eyes. Most cited: roofing, framing, masonry and siding contractors.
Historically, the Occupational Safety and Health Administration (OSHA) has not payed a great deal of attention to the Golf and Country Club industry in comparison to other “high-hazard” industries. OSHA officials admit that in the past, reasons for most of their inspections at clubs was due to either employee complaints or employee injury/fatalities.
More recently, OSHA has been focusing on the club industry and hitting clubs with more and more citations for violating OSHA standards. Not only are these citations frustrating, but they are financially costly to the club as well.
Here are the Top 5 Most Common Golf and Country Club OSHA Citations from 2019:
- Hazard Communication
- Maintenance, Safeguards, and Operational Feature for Exit Routes
- General Requirements: Personal Protective Equipment
- Respiratory Requirements
- Portable Fire Extinguishers
For additional OSHA compliance resources visit www.osha.gov or contact the local OSHA office.
At Gulfshore Insurance, we specialize in insurance and risk management for golf and country clubs. We work with more than 50 clubs throughout Florida and we are happy to assist you with training materials, safety programs, and insurance for your club.
Jeffrey Sanders, TRIP is Client Advisor at Gulfshore Insurance. Jeff works with a wide range of business clients to deliver strategic risk analysis, guidance, and insurance. Comments and questions are welcome at jsanders@gulfshoreinsurance.com
OSHA has developed this interim guidance to help prevent worker exposure to COVID-19 (Coronavirus). The guidance also addresses considerations that may help employers prepare for more widespread, community outbreaks of COVID-19, in the event that this kind of transmission begins to occur. The guidance is intended for non-healthcare settings; healthcare workers and employers should consult guidance specific to them.
Measures for protecting workers from exposure to, and infection with, the novel coronavirus, COVID-19 depend on the type of work being performed and exposure risk, including potential for interaction with infectious people and contamination of the work environment. Employers should adapt infection control strategies based on a thorough hazard assessment, using appropriate combinations of engineering and administrative controls, safe work practices, and personal protective equipment (PPE) to prevent worker exposures. Some OSHA standards that apply to preventing occupational exposure to COVID-19 also require employers to train workers on elements of infection prevention, including PPE.
OSHA recommends employers remain aware of the evolving outbreak situation and adapt infection control measures as needed. The highest risk for worker exposure is in the following industries:
- healthcare,
- deathcare,
- laboratory,
- airline,
- border protection,
- solid waste and wastewater management operations, and
- international travel to areas with ongoing, person-to-person transmission of the novel coronavirus, or COVID-19.
Click here to view the full release for OSHA.
It’s time to electronically submit injury summaries to OSHA. March 2, 2020 is the deadline for electronically reporting your OSHA Form 300A data for calendar year 2019.
Who has to report?
Establishments with 250 or more employees that are currently required to keep OSHA injury and illness records, and facilities with 20-249 employees that are in certain industries must submit info from Form 300A electronically to OSHA.
There are three options to submit the data on OSHA’s website:
- Enter the data into a webform
- Upload a CSV file to process single or multiple facilities at the same time, or
- Transmit an API file.
Starting this year, employers must include their facilities’ Employer Identification Numbers.
Other OSHA rules for Forms 300, 300A and 301 aren’t changed by the electronic requirement.
