What does OSHA require our warehouse and storage facility to do to protect our employees from COVID-19?

OSHA does not have a comprehensive regulation for COVID-19. It is noteworthy that:

• On November 5, 2021, the agency published in the Federal Register an emergency temporary standard (ETS) interim final rule for vaccination and testing. However, OSHA later withdrew the interim final rule on January 26, 2022, so the provisions of the rule are no longer in effect. The agency's move to withdraw the rule came after the Supreme Court stayed the rule on January 13, 2022.
• On June 21, 2021, OSHA issued a separate ETS for COVID-19, but that standard only covered healthcare employers. On December 27, 2021, OSHA withdrew non-recordkeeping portions of the June 21st Healthcare ETS. The COVID-19 log and reporting provisions, §1910.502(q)(2)(ii), (q)(3)(ii)-(iv), and (r), remain in effect.

Meanwhile, the agency continues to have the following existing regulations and laws that are related and may apply to your facility:

• 29 CFR 1904, Recording and Reporting Occupational Injuries and Illness.
• 29 CFR 1910.132, General Requirements - Personal Protective Equipment.
• 29 CFR 1910.133, Eye and Face Protection.
• 29 CFR 1910.134, Respiratory Protection.
• 29 CFR 1910.141, Sanitation.
• 29 CFR 1910.145, Specification for Accident Prevention Signs and Tags.
• 29 CFR 1910.1020, Access to Employee Exposure and Medical Records.
• Section 5(a)(1), General Duty Clause of the Occupational Safety and Health (OSH) Act of 1970.

OSHA’s Bloodborne Pathogens Standard (29 CFR 1910.1030) applies to occupational exposure to human blood and other potentially infectious materials that typically do not include respiratory secretions that may contain SARS-CoV-2 (unless visible blood is present). However, the provisions of the regulation offer a framework that may help control some sources of the virus, including exposures to body fluids (e.g., respiratory secretions) not covered by the regulation.

In addition, the agency has issued the following enforcement and guidance documents:

• Revised National Emphasis Program – Coronavirus Disease 2019 (COVID-19); OSHA directive DIR 2021-03 (CPL-03), dated July 7, 2021;
• Updated Interim Enforcement Response Plan for Coronavirus Disease 2019 (COVID-19), dated July 7, 2021;
• Protecting Workers: Guidance on Mitigating and Preventing the Spread of COVID-19 in the Workplace; OSHA guidance, dated August 13, 2021;
• Filing Whistleblower Complaints Related to COVID-19; OSHA Fact Sheet OSHA FS 4151-2021, dated September 2021
• Coronavirus: COVID-19 Guidance for the Package Delivery Workforce, OSHA 3998 – 2021, revised dated March 2021;
• COVID-19 Guidance on Social Distancing at Work, OSHA 4027-05 2020, dated May 2020;
• COVID-19 Guidance for Stockroom and Loading Dock Workers, OSHA 4029-06 2020, dated June 2020;
• COVID-19 Guidance on the Use of Cloth Face Coverings while Working Indoors in Hot and Humid Conditions, OSHA fact sheet, dated September 2020 (note that OSHA is reviewing this document and says it may not represent current OSHA guidance);
• Lessons Learned: Frequently Cited Standards Related to COVID-19 Inspections, DOL-OSHA-OOC-2020-108, dated November 2020;
• Common COVID-19 Citations: Helping Employers Better Protect Workers and Comply with OSHA Regulations, DOL-OSHA-OOC-2020-105, dated November 2020; and
• Several other guidance documents, FAQs, and posters on OSHA’s website (search the Internet for the phrase OSHA Coronavirus Disease (COVID-19)).

It should be noted that the Centers for Disease Control and Prevention (CDC) also offers:

• COVID-19 Employer Information for Warehousing, CDC webpage, dated November 2020 (CDC notes that this is an archived webpage that may not reflect CDC’s current guidance); and
• What Warehousing Workers Need to Know about COVID-19, CDC webpage, dated November 2020 (CDC notes that this is an archived webpage that may not reflect CDC’s current guidance).

Also note that your state may be more stringent than federal OSHA. Check your state laws, regulations, and workplace safety agency websites to learn more.