The Occupational Safety and Health Administration has released guidance in the form of an interim enforcement response plan to assist area offices and compliance officers with how to respond to complaints, referrals, and employer-reported fatalities and hospitalizations with a possible relation to COVID-19. The agency stated initial complaints involved reports of personal protective equipment-related issues and a lack of training regarding virus-related matters in workplaces. A protocol for when and how to respond was needed.
To prioritize local OSHA office resources, each area director is expected to evaluate the complaint in terms of the work tasks performed in relation to the risk level of virus exposure. The agency references the Occupational Risk Pyramid from an earlier publication that establishes four risk categories of tasks based on the potential exposure to the virus: very high, high, medium and low.
The very high and high categories of risk are set out based on tasks performed by—for example—health care, medical transport, mortuary and laboratory workers. In these cases, compliance officers are advised to first conduct a remote document review, such as via email. For example, such review would involve examining the written pandemic plan, hazard assessments and protocols for PPE use, and the respiratory protection program and then determining whether an on-site inspection of the workplace is required.
However, complaints from non-health care and non-emergency response establishments will be processed using the “non-formal phone/fax” approach, which clearly is a less serious protocol but one that demands attention. Most roofing worksites are likely to fall into the low or medium risk levels because they involve minimal contact with the public and co-workers. As such, a roofing job site rarely would be the focus of an on-site COVID-19 inspection.
It appears OSHA’s main focus is on health care and emergency services workplaces. However, it is advisable to include virus exposure protocols in written roofing job-site hazard assessments.
