Cal/OSHA Issues Guidance on Coronavirus

On February 3, the California Division of Occupational Safety and Health (Cal/OSHA) issued interim guidance covering the safety and health requirements when providing care for patients with suspected or confirmed cases of the 2019 novel coronavirus (2019-nCoV) and laboratories testing samples for the pathogen.

California has an Aerosol Transmissible Diseases (ATDs) standard (CCR, Title 8, §5199) requiring employers in the state protect employees from diseases and pathogens transmitted by aerosols and droplets. 2019-nCoV is an airborne infectious disease covered by the state standard. While there is a federal Bloodborne Pathogens (BBPs) standard, there is no federal standard for airborne pathogens.

Covered workplaces include healthcare facilities, laboratories, public health services, and police services, as well as other locations where employees may be expected to be exposed to confirmed or suspected cases of ATDs.

The California ATD standard requires employers to provide training on the:

• Signs and symptoms of 2019-nCoV;
• Modes of transmission of the disease and infection control procedures;
• Work activities and tasks that may expose an employee to 2019-nCoV;
• Uses and limitations of methods to prevent or reduce exposure to the disease, including decontamination and disinfection procedures;
• Selection of personal protective equipment (PPE); its uses and limitations; and the types, proper use, location, removal, handling, cleaning, decontamination, and disposal of protective equipment;
• Proper use of respirators; and
• Available vaccines, when they become available.

There are no vaccines effective against 2019-nCoV, according to the World Health Organization (WHO), and influenza and pneumococcal vaccines do not provide protection against the coronavirus.

The ATD standard also requires employers to plan for any exposure incidents that may occur and potential surges in infection and train employees in the details of those plans.
Written exposure control plan and procedure requirements include:

• A description of the source control measures—such as a procedure, an engineering control, a device, or material that minimizes the spread of airborne particles and droplets from a possible infected individual—to be implemented at the worksite and methods of informing people entering the worksite of those source control measures.
• Procedures to identify, temporarily isolate, and move suspected cases to airborne infection isolation rooms or areas; these procedures must include methods to limit employee exposure to patients when they are not in an airborne infection isolation room or area.
• Procedures to communicate with employees and other employers regarding the suspected or confirmed infectious disease status of persons to whom employees are exposed in the course of their duties.
• Procedures to ensure there is an adequate supply of PPE and other equipment necessary to minimize employee exposures to airborne infectious diseases, in normal operations and in foreseeable emergencies.
• Procedures to identify potential employee exposures, evaluate each exposure incident, determine the cause, determine which employees had a significant exposure, provide medical follow-up for exposed employees, and revise existing procedures to prevent future incidents.
• Procedures, including work practices, decontamination facilities, and appropriate PPE for surge events, which are large and rapid increases in the number of cases.
• Employers that have employees designated to provide services in surge conditions must have such procedures, and surge procedures extend beyond direct patient care and include tasks such as laboratory studies and epidemiological investigations.

“It is vital that employers take the necessary steps to protect workers in health care settings where they may be at risk of exposure to 2019 Novel Coronavirus,” Cal/OSHA Chief Doug Parker said in an agency statement. “Cal/OSHA will provide guidance and resources on how to protect workers from this airborne infectious disease.”