b'Garys CornerDuty Clause citation need to adopt a COVID19most effective COVID19 prevention programs PreventionProgram.AsIhavestatedbefore,engage workers and their representatives in the thecurrentpandemicisatextbookexampleofprogramsdevelopmentandimplementationof Congresss intention when it drafted Section 5(a) every step, and include the following elements: The (1) of the Occupational Safety and Health Act offollowing is an outline of the fifteen elements:1970. I make this comment for 2 reasons. First, unlike1.Assign a workplace coordinator to be responsible some areas in which OSHA has been successfullyfor COVID19 issues on your behalf. I feel that challenged for applying the General Duty Clause,this could be your corporate safety director, if he/such as with heat illness prevention, the COVID-19she has been sufficiently trained on COVID19 recognized hazard has existed for less than oneissues.year. So, the defense available to employers to a General Duty Clause citation that the General Duty2.Perform a thorough hazard assessment to identify Clause may not be used by OSHA as a substitute forpotential workplace hazards related to COVID19.specific rulemaking very likely will not apply to the pandemic. OSHA has issued this guidance document3.Identify the measures that are going to be necessary and may well, with the urging of President Biden,for you to limit the spread of COVID19 following issue an Emergency Temporary Standard within thetheestablishedOSHAhierarchyofcontrols. next six weeks.The second reason for my statementThis would entail: (1) eliminating the hazard; (2) is that OSHA has communicated its finding that theemploying engineering controls; (3) establishing pandemic is a recognized hazard which is causingworkplace administrative policies; (4) employing or likely to cause death or serious physical harm toPPE; and (5) prioritizing and controlling of the most employees which are the elements necessary toto least effective ways to protect workers. OSHA invoke General Duty Clause. Again, whether youexpands on these procedures which I feel repeat agree with the science that the pandemic meetsmany of the actions we have seen before. They this definition, I submit that none of you want to beare:in a position of having to defend yourself from aA. Eliminate the hazard by separating and sending General Duty Clause citation because you do nothome infected or potentially infected people.have a pandemic prevention plan for your workforce.B. Implement physical distancing in all communal Presuming that you have developed the requiredwork areas.pandemic protection program, I want to direct yourC. Install barriers where physical distancing cannot attention to the OSHA website and the coronavirusbe maintained.resources available thereon. The guidance documentD. Use face coverings.identifies 15 steps for employers to take to respond to COVID19. Review those 15 elements and identifyE. Improved ventilation.those that apply to your business and your employeesF. Use applicable PPE to protect workers from and, if you have not done so already, develop yourexposure.COVID19 prevention program and be sure youG. Provide supplies necessary for good hygiene include those elements that apply to your company.practices.But, please remember that developing the program is only 50% of what you need to accomplish. AfterH. Perform routine cleaning and disinfection.you have the program, you need to communicateThe remaining actions stated in the guidance document it to all your employees, remind them that you willinclude the following:be enforcing all the components of your program,4.Consider protections for workers at higher risk and then you MUST enforce it. And you need tofor severe illness through supportive policies and ensure that ALL your employees are abiding by thepractices.requirements of your program.Let us take a look at those 15 elements, which5.Establish a system for communicating effectively can be found under the subheading The Rolls ofwith workers and in the language they understand.Employers and Workers in Responding to COVID 6.Educate and train workers on your COVID19 policies and procedures again in the language 19. The initial step identified by OSHA is that theContinued on page 18www.mrca.orgMidwest Roofer 17'