California: Updated Cal/OSHA Guidance on COVID-19 Safety Practices and Requirements

Mandatory IIPP Changes

Cal/OSHA published updated Interim General Guidelines on Protecting Workers from COVID-19. Of particular note, the Guidelines state that “[f]or most California workplaces, adopting changes to their IIPP is mandatory since COVID-19 is widespread in the community.” California businesses are already required to have Illness and Injury Prevention Plans (IIPP) in place. Cal/OSHA is now saying that employers must incorporate infection control measures, including applicable and relevant recommendations from the Centers for Disease Control and Prevention (CDC), in their IIPPs. The Guidelines also published an extensive list of specific infection prevention measures and training topics for employers to implement.

While the Guidelines say that they do not “impose new legal obligations,” Cal/OSHA relies on the fact that COVID-19 is a workplace hazard, which is a topic covered by IIPP requirements. Employers are instructed to determine if COVID-19 infection is a hazard in their workplace and take action accordingly.

Industry-Specific Safety Practices

Cal/OSHA published updated COVID-19 infection prevention guidelines for employers in agriculture, childcare, construction, grocery store, logistic, and mortuary and funeral home industries.  The updated guidelines are completely new, as a number of the topics included (e.g., employee training, sanitation practices, physical distancing) have been covered in prior Cal/OSHA publications.  Nevertheless, employers in the aforementioned industries should review the Cal/OSHA recommendations, as well as the newly released daily and general checklists for agricultural and grocery employers.

The general safety topics applicable for all employers are summarized below:

• Employee Training. Training should contain information published by the CDC, such as how COVID-19 is transmitted, symptoms and when to seek medical attention, and how to prevent or limit infection through frequent handwashing, cleaning, physical distancing, wearing of face coverings. Employers should consider updating their Injury and Illness Prevention Plans (IIPP) to include COVID-19 training.
• Cleaning and Disinfecting. Employers should implement cleaning and disinfecting procedures, especially for commonly touched surfaces.  Handwashing stations should be well-stocked and readily available.  Employees must be permitted sufficient time to wash hands.
• Sanitation Practices. Restrooms should be kept clean and sanitary, stocked with soap and single-use towels, and handwashing facilities should be located nearby.
• Physical Distancing. Where it is not possible for employees to work remotely, physical distancing between workers and the general public should be implemented. Additional recommended measures include staggering shifts, break times, and meal periods to allow employees to maintain the recommended six feet of distance.

Employers in the specified essential businesses should carefully review Cal/OSHA’s updated guidelines, as they contain additional guidelines specific to each industry. For example, grocery employers have recommendations on how to manage self-checkout, encouraging patrons to limit physical handling of product, and marking distances on the floor in checkout lines to facilitate physical distancing.

Note that Cal/OSHA’s COVID-19 resource page and the guidelines and materials contained therein are subject to change as more information about the pandemic is received and the situation continues to evolve.  Employers are recommended look for more information as it comes.

Action Items