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

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

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

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

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.