b'Garys Cornercreate an obligation for all employers. In my opinion,into their elbow. that obligation will not change in the foreseeable6. Employees should avoid touching their facefuture.Those who know me know that my FIRST goal is7. Employees SHALL NOT share tools or electronic the protection of employees, not in trying to find wayscommunication devicesto avoid safety. To that end, and to keep this article8. Employees SHALL disinfect equipment before from becoming a novel, I will address my commentsusing it, when possible primarily to field work (but much of my comments will apply readily to manufacturers and others). You MUST9. Non-essentialbusinesstravelSHALLbe now have in place a COVID-19 pandemic responseeliminated (my word) or minimized and procedures policy and plan. It must include the steps you areshall be established for employees returning from taking to protect your employees from COVID-19 astravel before returning to workwell as your protocol for training your employees and 10. for enforcing the work rules you have in place. ThisDevelop procedures for workforce contact tracingprogram needs to be a permanent part of your safety11. Develop special accommodations for vulnerable program even when we have COVID-19 under control.employeesYour plan will need to become a living program. It should be in the same style as your Emergency Action12. All specific OSHA standards governing the use Plan (EAP). By this I mean you need a companyof PPE, including, but not limited to personal pandemic response plan that exists next to your EAP,respiratoryequipment,faceshields,hand which should require a site-specific plan for eachprotection, etc. shall be complied withlocation at which you have employees working. This is necessary because, not only do we have federalThese requirements shall be enforced under the OSHA/CDC guidelines and recommendations, we also__________ Company Safety Enforcement Program.have state and local orders, regulations, guidelinesA site-specific pandemic policy shall be developed and recommendations. You, your safety team, andfor each worksite. The eleven points listed in the perhaps your company doctor, need to review those__________ Company Pandemic Policy shall be that apply to you in any location at which you areaddressed in the site-specific plan along with any going to work. DO NOT forget: no matter whereState or Local laws, regulations, recommendations your company is headquartered, you are requiredor guidance. to comply with all government requirements, etc. in the state and location at which your employees willBeyond the above you need to familiarize yourself be working to satisfy the requirements of the OSHAwith any state or local regulations that apply to General Duty Clause. businesses in your state or locality and stay current At a minimum you should include the following inwith regards to them. For example, Nevada enacted your company plan/policy: a requirement several weeks ago prohibiting more than one employee from traveling in a crew cab 1. Employees SHALL use social distancing at atruck or working from a scissors or aerial lift truck. I minimum of six feet know that many employers have employees share hotel rooms when they travel for the company. This 2. Employees SHALL confirm their temperatureagain should be prohibited, whether-or-not there each day when they arrive to work is a law or regulation addressing room sharing. In 3. Employees with unacceptable temperature orsome states, a state OSHA plan is in place, and in other symptoms shall remain or be sent homeothers still under Federal OSHA control, failure to to self-quarantine for ______ days comply with a state specific regulation could result in an employee complaint to OSHA, which could (will) 4. Employees should frequently wash their handsrequire you to justify your actions to OSHA and/or with soap and water face a compliance inspection. 5. Employees SHALL never cough or sneeze withoutNEXTcovering their mouth AND nose. If masks are notSo, what is next? Here is where some crystal available, then employees shall cough or sneezeball gazing is necessary. The difficult thing to predict www.mrca.orgMidwest Roofer 9'