Compliance Perspectives

A 5-Step Game Plan for Protecting Lab Employees from COVID-19 Infection

In this time where so much is riding on diagnostic testing, labs face the imperative of safeguarding their employees against risks of COVID-19 infection. Here’s a quick overview of the applicable laws and a strategy to comply with them, based on new OSHA guidelines.

The OSHA Duty to Prevent Workplace COVID-19 Infection

Under OSHA, employers have a duty to protect workers against workplace health and safety hazards. OSHA has made it abundantly clear that such hazards include the SARS-CoV-2 virus that causes COVID-19, even though the regulations don’t mention it by name. The source of the obligation is Section 5(a)(1) of the Occupational Safety and Health Act, aka the “general duty clause,” which requires employers to provide a workplace “free from recognized hazards” likely to cause death or serious physical harm. The duty is also implied under other OSHA standards that come into play when dealing with SARS-CoV-2, including the Personal Protective Equipment (PPE) standards (29 CFR 1910 Subpart I), which require use of gloves, eye, face and respiratory protection.

The 5 Things You Must Do to Comply

While the stakes are high, COVID-19 control and response shouldn’t be a challenge you’re not prepared to face. If your lab already has a general plan in place to deal with and contain infectious diseases, COVID-19 response measures should be selected and carried out in accordance with that general framework. But the OSHA guidance provides useful information in applying general infectious disease response principles to the unique characteristics of and risks posed by the highly contagious SARS-CoV-2 virus. Specifically, there are five basic steps you must take to control infection hazards and ensure compliance with OSHA requirements.

 Step 1: Do a COVID-19 Hazard Assessment

As with any other work hazard, the first stage in controlling COVID-19 risks is to perform a hazard assessment. The guidelines call on employers to use a four-level risk classification pyramid for assessing worker exposure risks, as summarized in Table 1.

Table 1. COVID-19 Exposure Risk Job Classifications

Risk Classification Jobs Included in Classification
Very High Healthcare workers, including lab personnel that collect or handle specimens from known or suspected COVID-19 patients (“COVID-19 patients”)
High *Healthcare delivery and support staff, e.g., hospital phlebotomists who must enter a COVID-19 patient’s room

*Medical transport workers moving COVID-19 patients in enclosed vehicles, e.g., ambulance operators

Medium Jobs requiring frequent and/or close contact with (i.e., within 6 feet) people who may be infected with SARS-CoV-2, but aren’t known or suspected COVID-19 patients, e.g., airports, retail stores
Lower Jobs not requiring frequent and/or close contact with (i.e., within 6 feet) people who may be infected with SARS-CoV-2

Step 2: Implement Engineering Controls

The next step is to select appropriate measures to manage the COVID-19 risks of staffers based on their particular risk classification. But while the measures required will vary by classification, with very high risk jobs requiring the greatest degree of protection, the approach to selection of control measures is the same across all classifications. The first line of defense is to use engineering controls that physically eliminate or isolate the hazard. Table 2 lists examples of the engineering controls to consider for each risk classification.

Table 2. Engineering Controls for SARS-CoV-2 Exposure

Risk Classification Appropriate Engineering Controls
Very High
*Ensure appropriate air-handling systems are installed + maintained
*Placing COVID-19 patients in an airborne infection isolation room (AIIR), if there is one
*Using isolation rooms, if available, to perform aerosol-generating procedures on COVID-19 patients
*Using special precautions associated with Biosafety Level 3 when handling specimens from COVID-19 patients
Medium Installing physical barriers, like clear plastic sneeze guards, if feasible
Lower None

Step 3: Implement Administrative Controls

Administrative, aka work controls involve making the work safer by adjusting the methods used to carry it out, e.g., implementation of safe work practices.

Table 3. Engineering Controls for SARS-CoV-2 Exposure

Risk Classification Appropriate Administrative Controls
Very High
* Policies that reduce exposure, like cohorting (i.e., grouping) COVID-19 patients when single rooms aren’t available
*Signs asking patients and family members to use disposable masks and immediately report symptoms of respiratory illness
*Offer enhanced medical monitoring of workers during COVID-19 outbreaks
*Provide all workers job-specific education and training on preventing COVID-19 transmission
*Make psychological and behavioral support available to address employee stress
* Provide emergency responders and other personnel who may be exposed while working away from fixed facilities hand rubs containing at least 60% alcohol for decontamination
Medium *Offer face masks to ill employees and customers until they can leave the workplace
*Keep customers informed about COVID-19 symptoms and ask them to minimize contact with workers, e.g., by posting signs in pharmacies where COVID-19 patients may visit
*If appropriate, limit customers’ and public access to the worksite, or restrict it to only certain workplace areas.
*Consider strategies to minimize face-to-face contact, e.g., drive-through windows and telework
*Communicate availability of medical screening or other worker health resources
Lower *Monitor public health communications about COVID-19
recommendations and ensure that workers have access to information
*Collaborate with workers to designate effective means of
communicating important COVID-19 information

Step 4: Provide Proper PPE

The final line of defense is making sure workers have and use appropriate personal protective equipment.

Table 4. PPE for SARS-CoV-2 Exposure

Risk Classification Appropriate PPE
Very High
*Gloves + gown + face shield or goggles + either:
>A face mask; or
>A respirator if worker works in contact with or within
6 feet of patients known to be, or suspected of being, infected with SARS-CoV-2
*Workers in labs may also need medical/surgical gowns, fluid resistant coveralls, aprons or other disposable or reusable clothing protecting additional against blood, body fluids, chemicals and other
materials to which they may be exposed
Medium Combination of gloves, a gown, a face mask, and/or a face shield or goggles depending on job and degree of exposure
Lower None

Step 5: Provide COVID-19 Training

As it has during previous outbreaks, OSHA has stated that training workers exposed to infection risks is an essential part of COVID-19 response. By the time they complete their training, exposed workers must understand:

  • What COVID-19 is;
  • How the SARS-CoV-2 virus is spread;
  • The risks of exposure and infection;
  • How to protect themselves from those risks;
  • How to recognize the signs and symptoms of COVID-19; and
  • What to do if they experience such symptoms.



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