OSHA’s Guidance for PPE and COVID-19

While Fed-OSHA has not issued specific regulations regarding personal protective equipment (PPE) for COVID-19, employers are still required under existing rules to conduct hazard assessments to determine PPE requirements for their worksite.

Before employers consider PPEs though, they should follow workplace safety best practices by following the hierarchy of safety controls:

1. Engineering controls
2. Administrative controls
3. PPEs

Employers should first use engineering controls to protect employees from exposure. Since eliminating the threat of contagion is impossible with COVID-19, employers have to try other methods to protect workers, including improving air filtration, increasing ventilation and installing physical barriers such as plexiglass shields between workers.

After engineering controls have been put in place, the next step in workplace safety is administrative controls, which are focused on human behavior rather than physical enhancements. This can include:

• Requiring workers to stay six feet apart from one another.
• Staggering shifts.
• Training workers about COVID-19 risk factors and behaviors they can adopt to protect themselves.
• Providing resources such as face coverings, hand soap, hand sanitizers, disinfectants, and disinfectant wipes to clean work services.

After considering engineering and administrative controls as well as safe work practices, employers must determine if PPE is necessary for employees to work safely. If you are requiring PPEs for your employees, it is up to you, the employer to provide them. You should not expect your workers to procure their own PPEs.

PPEs include:

• Gloves
• Gowns
• Surgical masks
• Face shields

In OSHA’s guidance for returning to work during the COVID-19 pandemic, it has the following PPE advice for employers:

• Cloth face coverings are not PPE and not an appropriate substitute for N95 respirators, but they can still reduce the spread of COVID-19 from worker to others. According to OSHA, its General Duty Clause, Section 5(a)(1), may require employers to provide such masks as they are a feasible means of abatement in a control plan. Moreover, some state and/or local governments are requiring employees to wear face coverings at work and that employers provide them with cloth masks.

Cloth face coverings may be commercially produced or improvised (i.e., homemade) garments, scarves, bandanas, or items made from t-shirts or other fabrics.

• If you are requiring your staff to wear masks, you should provide specific written regulations about when they must be worn, how to care for them, what medical or other protected reasons are valid exceptions, and what are the consequences if employees decline to wear them and do not meet the exception criteria. During training, employees should be told that masks are not a substitute for social distancing or other administrative controls.
• If you plan to distribute N95 masks to workers, you have to comply with regulations, including training employees in their use and how to fit them properly. An ill-fitting N95 mask will not provide the same protection as one that is properly fitted. However, if a worker brings their own N95 mask you should let them wear it and you won’t be responsible for training.
• If you plan to distribute gloves for protection, they should cover the entire hand up to the wrist and employees need to be instructed on the proper way to remove gloves to avoid contamination.

Choosing the right PPE

Under OSHA guidance there are three risk categories for workers concerning the use of PPEs.

High exposure risk — Workers in high-risk jobs such as healthcare, medical transport and lab workers. They need to wear gloves, a gown, a face shield or goggles and either a face mask or a respirator.

Moderate exposure risk — These workers have frequent or close contact with the general public, such as retail or restaurant workers. OSHA recommends that these workers wear combination of masks, face shields, gloves and perhaps a gown depending on their level of potential exposure. Low exposure risk — OSHA does not recommend PPE.

If you are still uncertain, OSHA has published COVID-19 guidance that includes recommendations for engineering and administrative controls as well as PPE for a number of industries.