The OSHA COVID-19 ETS was published in the Federal Register on June 21, 2021 and requires the completion of training elements by July 21, 2021 in states under Federal OSHA jurisdiction. South Carolina OSHA continues to receive and review feedback about the new standard from stakeholders and has not published their plan for implementation. For additional details to determine whether the ETS applies to you see OSHA’s fact sheet “Is Your Workplace Covered by the ETS”.
Training is one of the seven core elements of an effective safety program. Through education employees, managers and supervisors become better able to recognize and control workplace hazards and more effectively participate in your safety and health program. The COVID ETS lays out the required training elements in section 1910.502(n & o) clearly:
- How the disease is transmitted (including pre-symptomatic and asymptomatic transmission)
- The importance of hand hygiene to reduce the risk of spreading the virus
- Use of a covering over the nose and mouth to reduce the risk of spreading the virus
- Signs and symptoms of the disease
- Risk factors for severe illness, and when to seek medical attention
2. Employer-specific policies and procedures on patient screening and management
3. Tasks and situations in the workplace that could result in COVID-19 infection
4. Workplace-specific policies and procedures to include cleaning & disinfection, health screening & medical management, and prevention of the spread applicable to the employee’s duties
5. Employer-specific multi-employer workplace agreements related to infection control policies and procedures, the use of common areas, and the use of shared equipment
6. Employer-specific policies and procedures for PPE worn to comply with this section, including:
- When PPE is required
- Limitations of PPE
- How to properly put on, wear, and take off PPE
- How to properly care for, store, clean, maintain, and dispose of PPE
- Any modifications to donning, doffing, cleaning, storage, maintenance, and disposal procedures needed to address COVID-19 when PPE is worn to address workplace hazards other than COVID-19;
7. Available sick leave policies, any COVID-19-related benefits to which the employee may be entitled under applicable federal, state, or local laws, and other supportive policies and practices (e.g., telework, flexible hours)
8. The identity of the safety coordinator(s) specified in the COVID-19 plan
9. The requirements of this standard and how they can obtain copies of the standard and any employer-specific policies/procedures developed for this standard, including the written COVID-19 plan, if required
10. Anti-retaliation information:
- Employee’s rights under the standard
- Prohibition of employers to discharge or discriminate against any employee exercising their rights under this standard or acting in compliance with the same
Training must be conducted by someone knowledgeable about both COVID-19 and how it relates to the employee’s job duties. Training is required to be provided during scheduled work times, at no cost to the employee, delivered in a “language and literacy level” the employee understands, and have an interactive element that allows for employee questions. This is substantially similar to the training requirements in the Bloodborne Pathogen standard, so whatever effective means an employer has in place to provide that training could prove useful for COVID training. Finally, while a demonstration of comprehension (documented or not) is not required, it is strongly suggested that you do one and document it for each employee trained.
Some good news is that if you have already trained your employees on all the required elements and in the manner listed above, you don’t need to retrain the employees. The training does not have to be completed in one sitting. If elements of this training were completed prior to the issuance of the standard, document what was covered, when, and provide new training only for the gaps.
Additional training is required under the following circumstances:
1. Changes occur that affect the employee’s risk of contracting COVID-19 at work (e.g., new job tasks)
2. Policies or procedures are changed
3. There is an indication that the employee has not retained the necessary understanding or skill.
Finally, the ETS offers an option for a mini respiratory protection program in 1910.504. If your establishment is utilizing this option, employees covered by the program must be trained on each of the following prior to its first use under the same parameters as described above (language/literacy level, at no cost, etc.):
1. Inspection, donning, doffing and respirator use
2. Limitations and capabilities of the respirator
- Especially important when the respirator has not been fit tested
3. Procedures and schedules for storing, maintaining, and inspecting respirators
4. Method of performing a user seal check (1910.504(d)(2))
5. Medical signs and symptoms that may limit or prevent the effective use of respirators and what the employee should do if they experience any them.