OSHA COVID-19 Inspections: What to Expect and Why Now?

On March 12, 2021, the Occupational Health and Safety Administration (OSHA) took two major steps in the COVID-19 battle: it enacted a COVID-19 National Emphasis Program (NEP) and an Updated Interim Enforcement Response Plan for Coronavirus 2019 (ERP). OSHA will focus on industries whose workers have an increased risk of COVID-19 exposure and those that put the most workers at risk. One of the biggest challenges for companies is the requirement to implement or maintain standards to protect worker safety as the number of cases continue to drop and restrictions ease across most regions.

When OSHA arrives for an inspection under the NEP, it will ask for your written COVID-19 protocols and response plan. If you haven’t already, begin to formalize your COVID-19 workplace policies in written form. Having written materials makes training employees on your policies easier and more effective. OSHA’s next area of inquiry will focus on how your COVID-19 protocol has been communicated to employees. Begin training employees now on any COVID-19 policies you have in place, whether verbally or in writing. Communicating with employees regarding the measures you have taken to keep them safe will not only help with handling an OSHA inspection, but also ease any concerns employees may have about their potential exposure to COVID-19. During the OSHA inspection optics are crucial, if the OSHA inspector sees poor housekeeping when they arrive your workplace will be viewed in a negative light. If you have increased your facility’s cleaning schedule during the pandemic, maintain the current number of cleanings. To protect your employees, ensure commonly touched surfaces such as doorknobs, buttons, restrooms, and break rooms are frequently cleaned and sanitized. You will also want to continue social distancing as the lack of proper spacing between employees will be easily discernible and will be viewed as a hazard. Throughout the inspection, ensure the OSHA inspector is provided the correct personal protective equipment, such as face coverings, goggles, or other items to keep them safe.

The COVID-19 pandemic is not over, and OSHA is making a push to conduct additional inspections concerning the coronavirus in the next several months. Hopefully, most companies are at least somewhere on the path to pandemic protection of their employees, however it will take each company to provide resources to not only reassess their current efforts being made, but also to provide additional resources to close the gaps. This will not only create a safer workplace, but also prepare you for an OSHA inspection under the safety agency’s new COVID-19 emphasis program.

Michelle Burnette is the Human Resources Director at Carolina HR. 

Stephen H. Murphy, SPHR, is the president and founder of Carolina HR. He has been active in Human Resource management and consulting for over thirty years and brings his experience in a wide variety of HR situations to his clients.


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