COVID-19, EHS Management, Fire Safety, Training

When Is COVID-19 Recordable, and How Do You Comply with Hands-On Training Requirements During the Pandemic?

Our experts at® have been busy answering subscribers’ questions related to EHS management during the COVID-19 pandemic. Read on for their answers regarding recordable cases of COVID-19, plus information on how the pandemic has affected hands-on safety training, specifically as it relates to compliance requirements for fire extinguisher training.

COVID-19 coronavirus

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COVID-19 and Your OSHA 300 Log

COVID-19 can be a recordable illness if a worker is infected as a result of performing their work-related duties. However, employers are only responsible for recording cases of COVID-19 if all of the following are true:

  1. The case is a confirmed case of COVID-19 (see CDC information on persons under investigation and presumptive positive and laboratory-confirmed cases of COVID-19);
  2. The case is work-related (as defined by 29 CFR 1904.5); and
  3. The case involves one or more of the general recording criteria set forth in 29 CFR 1904.7 (e.g., medical treatment beyond first aid, days away from work).

What About Hands-On Fire Extinguisher Training?

Complete question: With the Covid-19 pandemic, I have not been able to schedule hands on fire extinguisher training for our team members. I understand that OSHA requires the employee to be knowledgeable and trained on fire extinguishers if they are within their work area and are authorized to use them. Are there any requirements of hands on training that entail employees discharging the fire extinguishers? Could I complete a refresher with my team on the utilization of fire extinguishers without discharging the median and still be compliant with the training standard?

Answer: You are correct that employers that provide portable fire extinguishers for employee use must provide an educational program to familiarize employees with the general principles of fire extinguisher use and the hazards involved with incipient stage firefighting. Training must occur upon initial employment and at least annually thereafter. Employees who have been designated to use firefighting equipment as part of an emergency action plan must be trained in the use of the appropriate equipment upon assignment and at least annually thereafter.

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Employees who are designated to use portable fire extinguishers must be provided with hands-on training in the use of the fire extinguishing equipment. However, OSHA allows the employer to determine how hands-on training will be provided. Discharging fire extinguishers and simulated or actual fires are not mandatory parts of the definition of “hands-on,” but are voluntary.

In addition, it is worth mentioning OSHA’s enforcement memo dated April 16, 2020 titled “Discretion in Enforcement when Considering an Employer’s Good Faith Efforts During the Coronavirus Disease 2019 (COVID-19) Pandemic.” In part, the memo states, “During the course of an inspection, OSHA Area Offices will assess an employer’s efforts to comply with standards that require annual or recurring audits, reviews, training, or assessments…Compliance Safety and Health Officers (CSHOs) should evaluate whether the employer made good faith efforts to comply with applicable OSHA standards and, in situations where compliance was not possible, to ensure that employees were not exposed to hazards from tasks, processes, or equipment for which they were not prepared or trained…CSHOs should evaluate whether the employer thoroughly explored all options to comply with the applicable standard(s) (e.g., the use of virtual training or remote communication strategies).  CSHOs should also consider any interim alternative protections implemented or provided to protect employees, such as engineering or administrative controls, and whether the employer took steps to reschedule the required annual activity as soon as possible. In instances where an employer is unable to comply with OSHA-mandated training…requirements because local authorities required the workplace to close, the employer should demonstrate a good faith attempt to meet the applicable requirements as soon as possible following the re-opening of the workplace. “

In light of both the fire extinguisher standard and the enforcement memo, it is likely that you will be able to conduct a refresher with your team on the utilization of fire extinguishers without discharging them and still be compliant.

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