b'Garys CornerContinued from page 17they understand. effectively implemented in their branch locations and/7.Instruct workers who are infected or potentiallyor on ALL jobsites. The same is true for manufacturers infected to stay at home and isolate or quarantine. and distributors that operate from several locations. 8.Minimize the negative impact of quarantine onOSHA continues to receive employee complaints with isolated workers. regards to their employers failure to have an effective pandemic prevention program. Such complaints may 9.Isolate workers who show symptoms at work. not be universal as to the company, but rather may 10. Perform an enhanced cleaning and disinfectionbe focused only on an individual location. Frequent after people with suspected or confirmed COVIDcomplaints have been tied into the employers failure to19 have been in the facility. enforce the proper use of face coverings, maintaining 11. Provide guidance on screening and testing. social distancing, and the availability of handwashing and or sanitizing stations on individual jobsites. Now 12. RecordreportedCOVID19infectionsandthat the January 29, 2021 OSHA guidance document deaths. This must be done under the recordkeepinghas been issued, your performance may be scrutinized procedures found in 29 CFR 1904.by your employees for many of the additional elements 13. Implement protections from retaliation and setstated in the guidance document. You need to ensure up an anonymous process for workers to voicethat all portions of your program are being effectively concerns about COVID19 related hazards. implemented at every job location. Whether you do 14. Make a COVID19 vaccine or vaccination seriesthis by in person audits or implementation reports available at no cost to all eligible employees. from your various locations, be sure you keep a written record at your corporate headquarters that 15. Donotdistinguishbetweenworkerswhoaredemonstrates the effectiveness of your pandemic vaccinated and those who are not. protectionprogramandyourenforcementofit. This article does not permit me to go into theTypically, employee complaints to OSHA in these details necessary to supplement each of the pointssituations result in either an informal complaint letter listed above. I urge you to go to the OSHA website andfrom the local area office of OSHA or a rapid response review the entire guidance document and determineinvestigation. In both cases response time is usually which of the preceding 15 steps are necessary forlimited to 5 business days. Do not forget that your your employees, whether they work at your office,response to OSHA will be passed by the complainant, construction work locations or manufacturing facilities.and if he/she challenges any of the assertions you Based on my experience dealing with OSHA, if youmade in your response, you will most likely receive are inspected, you will be judged on the effectivenesseither a follow-up inquiry from the OSHA area office of your program in protecting your employees fromor a formal OSHA inspection.COVID19 exposure. Remember, this document,The preceding comments may just be the tip of includingeverythingIhavelistedaboveandthethe proverbial iceberg. Remember, President Bidens supporting detail, has been posted on the OSHAExecutive Order is titled Executive Order on Protecting website and therefore is available for review by yourWorker Health and Safety. While the Executive Order employees and their designated representatives. Thefocuses much of its direction to protecting employees message here is that you may well be measured byfrom COVID19, I believe we can expect to see an your employees by how you have addressed eachincrease in OSHAs enforcement activities as well as of these 15 points at your company. If they feel thatthe proposal of new standards and the issuance of your compliance with this guidance document isfinal rules concerning those issues currently in a formal lacking, they may well file an employee complaintrulemaking process. We will attempt to keep you up with OSHA against your company. Which brings meto date on these matters as they develop as well as to my last paragraph. any new developments concerning COVID19 and I have found that while many contractors haveOSHA.establishedpandemicpreventionprograms,not many contractors are making sufficient efforts to ensure that all aspects of their programs are being 18 www.mrca.orgMidwest Roofer'