How to Create a COVID-19 Exposure Control Plan

For as long as COVID-19 remains a threat, businesses—both essential and nonessential—won’t be allowed to re-open and remain open unless they implement a plan to control workplace infection risks. While infection control is nothing new for labs, the challenges posed by COVID-19 are unprecedented and unique and you probably won’t find any great templates in your current policy folders and binders. As a result, you’ll need to build your plan from the ground up. Here’s a step-by-step strategy and Model COVID-19 Exposure Control Plan containing the necessary elements that you can use to accomplish that objective.

The Exposure Control Plan & Why You Need It

An exposure control plan is a set of measures to protect workers, patients, contractors, visitors and other people at your workplace against exposure to COVID-19 infection and ensure compliance with your obligations under OSHA laws, CDC and other public health guidelines.

Best Practice: Designate the lab manager or another competent individual who understands the OSHA laws and public health guidelines to serve as COVID-19 coordinator responsible for creating and implementing the plan. Although the COVID-19 exposure control plan is something novel, you can base it on your current OSHA policy templates, starting with a statement describing the plan’s purposes (Plan, Sec. 1) and an allocation of roles and responsibilities (including management, the COVID-19 coordinator, supervisors and workers) (Plan, Sec. 2).

The 9 Key Safety Measures

The heart of the COVID-19 exposure control plan are its nine sets of safety measures.

1. COVID-19 Hazard Assessment

As with any other health and safety hazard, the starting point is to identify and assess the COVID-19 hazards at your lab. While no workplace is exempt from infection risks, the nature and degree of risk does vary from workplace to workplace. OSHA guidelines recommend basing the COVID-19 hazard assessment on job classification and ranking exposure level as Very High, High, Medium and Low considering the following COVID-19 risk factors:

• Physical distance of workers from co-workers, patients and other persons at the site;
• Effectiveness of current ventilating, air circulation and HVAC systems;
• Operations requiring close contact, e.g., sharing of vehicles;
• Age, respiratory or immune disorders, or other chronic medical conditions or physical characteristics making persons at the site unusually susceptible to COVID-19 infection; and
• Availability of respirator masks and other necessary PPE.

Labs would likely fall into the Very High or High classification, particularly if they perform testing on samples of patients who have or are suspected of having COVID-19 (Plan, Sec. 3.1).

2. COVID-19 Field Level Hazard Assessment

In addition to the job classification assessment, a competent worker or supervisor at the lab should carry out a field level assessment before the shift to verify that the required safety measures are in place and immediately notify the person in charge of safety if something is amiss. Work shouldn’t begin until the field assessment comes back clean or the cited problems are properly corrected (Plan, Sec. 3.2).

3. COVID-19 Safety Controls

The next phase of COVID019 exposure control is to select measures to address identified infection hazards based on the findings of the job classification exposure assessment following the standard “hierarchy of controls,” i.e.:

• Totally eliminating the hazard if reasonably practicable, e.g., ceasing all operations requiring workers to have close contact;
• If elimination isn’t reasonably practicable, using engineering controls like air-circulating and ventilating systems or physical partitions, to minimize hazards;
• Using safe work procedures and other administrative controls affecting how hazardous operations are carried out instead of or in combination with engineering controls to minimize exposure; and
• As a last resort where COVID-19 hazards can’t be eliminated via engineering and administrative controls, requiring exposed lab workers to use PPE.

4. Social Distancing Measures

Labs must ensure that people at the workplace maintain the required 6 feet of separation from each other. The exposure control plan should describe all the things you’re going to do to meet that massive challenge, e.g., physical workplace configuration, occupancy limits, bans on large meetings or gatherings, etc. (Plan, Sec. 5).

5. Medical Screening

Public health agencies, the EEOC, privacy commissions and other regulators have reluctantly given the green light for employers to medically screen workers and others seeking entrance to the facility for COVID-19 symptoms as long as screening measures are safe, fair, consistent, nondiscriminatory and as minimally privacy invasive as possible. So, make sure your exposure control plan explains your screening measures and the safeguards taken to keep them within the legal limits (Plan, Sec. 6). (See, “How to Create a Legally Sound Medical Screening Policy,” LCA, April 27, 2020).

6. Self-Isolation & Quarantine Measures

Explain the policies and procedures you’ll use to bar employees (or others) who test positive for, exhibit symptoms of or are at otherwise at high risk of infection due to travel or direct and recent contact with a person that has COVID-19 from entering or remaining in the lab. Such procedures should also provide for removal, transport, communication and ultimately return to work of workers in self-isolation (Plan, Sec. 7).

7. Sanitation & Infection Control Measures

Describe the sanitary, cleaning and disinfection measures you’ll take to minimize COVID-19 infection risk, which at a minimum should include:

• Frequent and regular cleaning and disinfection of surfaces, equipment, door knobs, sinks, handles, keyboards, light switches and other touch points with EPA-approved products;
• Keeping wash rooms accessible, clean and amply supplied with soap, water and paper towels;
• Requiring workers to wash their hands frequently while at and immediately before leaving the lab;
• Posting notices demonstrating proper hand washing techniques in wash areas;
• Implementing safe work procedures for the handling of mail, packages, materials and goods entering and exiting the lab; and
• Requiring all workers to use “respiratory etiquette” and properly cover their mouth when they cough and sneeze.

(Plan, Sec. 8)

8. PPE

PPE is an absolute must, particularly where encounters between people closer than the prescribed social distancing 6 feet can’t be avoided. In most workplaces, the vast majority of workers will fall into the Medium or Low exposure risk classifications requiring only a non-medical face mask and perhaps protective gloves. However, COVID-19 testing and other healthcare workers who treat or are near to COVID-19 patients will fall into the Very High and High risk classification requiring more elaborate PPE, including at a minimum, an N95 or other tight-fitting particulate respirator, gloves and an apron. Workers who make direct and close contact with COVID-19 patients or handle lab specimens will also need face masks, goggles, protective clothing and, in some cases, more elaborate respiratory protection, e.g., SCBA respirators (Plan, Sec. 9).

9. Safety Training & Instruction

All lab workers exposed to COVID-19 infection risks should receive safety information and training covering, at a minimum:

• How the virus spreads;
• The fact that there’s currently no vaccine for COVID-19;
• How to reduce the risk of infection;
• The measures you’ve taken to minimize infection risks; and
• What workers should do and whom they should call if they believe they’ve been exposed.

(Plan, Sec. 10)

Takeaway

 The stakes are higher than you may realize. If you don’t have the right exposure control plan in place, OSHA and public health inspectors can hit you with hefty fines and even shut you down. Failure to implement an effective plan also heightens the risk of liability and lawsuits by persons claiming to have contracted COVID-19 at your facility, including massive class action suits if you experience outbreaks or clusters of infections.