b'Garys Corneris how each state, and perhaps even each local7. NEVER cough or sneeze without covering your community, will reopen for full business operations.face with a tissue or mask or cough and sneeze Will all states fully reopen for business as usual?into a tissue and dispose of itMany of us do not think we will go back to the wayThe above are the obvious safeguards that I it was at any time in 2020 and perhaps longer thanbelieve will remain for a while after the states have that. Social distancing is one of those restrictionsreopened. I believe these are the minimum basic that may well be with us for a long time. The samesafety considerations. Of course, as I discussed goes for other aspects of the current regulations,above, you will also need to remain up-to-date with guidelines and recommendations. When does ayour state and local regulations and guidelines and guideline or recommendation become more thankeep them as part of your site-specific COVID-19 that? This may be at the heart of the matter. In lightPandemic Protection Program.of that, I feel we must again look at the situation from two perspectivesthe safety of your employees and/ From an OSHA General Duty Clause enforcement or the avoidance of problems with state and federalperspective, it is a new day. Consider the other regulatory agencies. While these may be the same,not specifically regulated areas that are currently or very closely similar, they may necessitate differentenforced under the General Duty ClauseHeat approaches.andColdIllnessprotection,DistractedDriving, Tofulfillthegoalofprovidingasafeworkand Workplace Violence.In these areas, OSHA environment for your employees you need to lookand/or NIOSH has provided us with a short list of beyond ways to avoid providing safeguards andexpectations for employers to protect their employees. determine if what you will continue to do will fullyAlso, these areas of safety concern have been with protect your workforce, even if you can or could find aus for several years. That fact, I believe, formed the way around doing it. Also (and I may say this again),basis for the OSHRC decision in the Sturgill Roofing you will need to put the health and safety of yourcase. But I believe we have only seen a handful of employees before their importance to you becauseemployee complaints relating to employers allegedly of their skill sets, and objectively and consistentlynot protecting employees in these areas. This is apply and enforce your safety rules.probably because the OSHA and NIOSH guidelines (to the extent they exist in writing) have not been To accomplish the tasks necessary to accomplishwidely published to the general public. BUT that is the goals in the preceding paragraph, you will need toNOT the case with COVID-19. While I have not done closely follow all developments regarding protectinga scientific study, I feel that it is pretty apparent that all workers from COVID-19. I cannot predict whenat least seventy-five percent of the media frenzy you might be relieved of this obligation, but I thinkthat has overtaken the news has been devoted to you will be safe to assume it will extend, at least,COVID-19. AND, much of what the general public until the end of 2020. Let us first look at the list from(and I mean EVERYONE) is witnessing in the media the NOW section to see which may be with us afteris, if not conflicting, putting different spins on what states have reopened. I believe the following Federalwe read and see. recommendations and guidelines will be with us afterSo, everyone who works for you has the ability reopening, and perhaps until the end of 2020: to determine what they think you should be doing to 1. MAINTAIN some form of social distancing and/ protect them from COVID-19. In addition, if they do or wear masks not think you have been doing what they have decided 2. Symptomatic employees stay home and self- you should be doing, they are aware that they can call OSHA and file a complaint. OSHA has reported quarantine for fourteen days that it has received hundreds of employee complaints 3. DO NOT share tools or electronic devices concerning COVID-19 pandemic compliance. When such a complaint is made, the OSHA area office will 4. FREQUENTLY wash hands with soap and water frequently react by faxing and/or emailing you what I call an informal complaint letter. This will state 5. Disinfectworksurfacesandtoolswheneverthe employee complaint and require you to respond possible to the allegations within five business days. That 6. Take steps to protect vulnerable employees response must be posted in the workplace and a copy will be shown to the complainant by OSHA. If he/she 10 www.mrca.orgMidwest Roofer'