The HEROES Act (Health and Economic Recovery Omnibus Emergency Solutions Act) states that, "Not later than 24 months after the date of enactment of this Act, the Secretary of Labor shall, pursuant to section 6 of the Occupational Safety and Health Act (29 U.S.C. 655), promulgate a final standard--(1) to protect employees" who are at occupational risk for exposure to SARS-CoV-2," also known as COVID-19, "...from occupational exposure to infectious pathogens, including novel pathogens." The legislation also requires the Department of Labor (OSHA) to develop a temporary standard within 7 days of enactment. This means that, if the HEROES Act becomes law, and perhaps even if it doesn't, organizations will have to comply with a new OSHA standard for protection from occupational exposure to contagious diseases.
UPDATE as of July 1 2020. Researchers have discovered a novel swine flu virus that could conceivably result in an additional pandemic to go with the existing COVID-19 pandemic. See for example Yeung, Jessie, "China researchers discover new swine flu with 'pandemic potential'" at CNN (June 30, 2020) https://www.cnn.com/2020/06/.... While this disease is believed less likely than not to pose a threat comparable to that of COVID-19, its existence underscores the need to prepare for illnesses for which no vaccines are available and to which humans have little resistance. The good news is that all the countermeasures that workplaces take against COVID-19 are likely to be effective against similar threats in the future.
Why Should You Attend
While the standard has yet to be issued, OSHA's existing (March 2020) "Guidance on Preparing Workplaces for COVID-19" (https://www.osha.gov/Publica...) offers a good idea of what to expect. We can also look to ASHRAE for the role of air handling systems in the prevention of contagion. We do not need to wait for the OSHA standard to position our organizations to meet its requirements and, more importantly, protect workers, customers, and stakeholders from COVID-19 and related illnesses. The controls and countermeasures we put into place can also help ensure continuity of operations by making it unnecessary to shut down operations should COVID-19 ever return in its current form, or a mutated one against which the vaccines under consideration will not work.
Areas Covered in the Session
1. Know that the HEROES Act, if enacted into law, will require OSHA to develop a standard or regulation for protection of employees from infectious diseases such as COVID-19. Even if the legislation does not become law, OSHA may do so anyway (an action the presenter would support) and, even if this does not happen, employers would do well to implement anti-contagion countermeasures anyway.
>> We should protect our employees, customers, and other stakeholders from foreseeable harm.
>> COVID-19 may return in either its present form, or a mutated one against which the pending vaccines will not work. Proactive and preventive actions can make it unnecessary to shut down operations should this happen.
2. OSHA's (March 2020) "Guidance on Preparing Workplaces for COVID-19" gives us an idea of what to expect, as well as a good framework for planning and actions.
3. Basic planning principles:
>> Create a risk register of activities or locations with opportunities for (1) contagion from a cough or (2) contagion from a contaminated surface. (Countermeasures against coughs will work against contagion from normal speech or breathing, but not necessarily the other way around. Experiments performed in 1918 show that, while contagion from even loud speech falls off beyond 4 feet, a cough can propagate it to 10 or more.) Identify, for each risk, the controls or countermeasures we have deployed against it; if there is no answer, we need to come up with one.
>> Distance (between respiratory tracts) is our friend, and can be added (e.g. with partitions) without the need for more floor space per person.
>> Air handling systems, and heating, ventilation, and air conditioning systems can play a role in safer workplaces. ASHRAE offers extensive guidance along these lines.
>> Administrative controls such as staggered shifts and one-way aisles reduce the number of people present in any given place at a given time.
>> Telecommuting and distance education are the ultimate forms of social distancing, and also eliminate costs associated with physical commuting, lodging, office space, and classroom space.
4. Personal protective equipment (PPE) includes face masks and respirators (e.g. N95).
>> Respirators that meet NIOSH requirements offer far superior protection than even surgical face masks that meet the requirements of ASTM F2100-19e1, and must be used when OSHA or other regulations call for respiratory protection. That is, if the job requires a respirator, a face mask will not do.
>> Beware of counterfeit and substandard respiratory protection that is being sold by unscrupulous suppliers who are seeking to exploit fear of COVID-19.
Attendees will receive a copy of the slides and accompanying notes in pdf form, and a handout on face masks and respirators.
Disclaimer; no part of this presentation constitutes formal engineering or occupational health and safety advice. Please refer to the authoritative sources cited (e.g. OSHA) for specific guidance on how to protect workers and others.
Who Will Benefit
>> All people with responsibility for reopening businesses in the aftermath of the COVID-19 outbreak, as well as people with responsibility for occupational health and safety (OH&S) compliance along with building layouts and heating, ventilation, and air conditioning (HVAC)
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