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Coronavirus / COVID-19 Update for California Employers # 12 – Cal-OSHA Updated Guidance Re Injury and Illness Plans

by D. Gregory Valenza | | May 28, 2020

Employers preparing to re-open after government imposed shutdowns or operations reductions have many tasks to accomplish. One of them is to ensure adequate, legally compliant, safety standards are updated, and implemented.

Cal-OSHA, the state agency responsible for worker safety, previously issued “Interim Guidance” that you can find here. It is important to note the agency’s inclusion of COVID-19 / Coronavirus as part of every employer’s duty to provide a safe workplace.

Coronavirus law, most employers must prepare and maintain an Injury and Illness Prevention Plan or IIPP.  Now, the IIPP must address preventing the spread of Coronavirus at work.  The agency provides guidance as to what should be included in the IIPP (see the link above).

Employers are required to determine if COVID-19 infection is a hazard in their workplace. If it is a workplace hazard, then employers must implement infection control measures, including applicable and relevant recommendations from the Centers for Disease Control and Prevention (CDC), Interim Guidance for Businesses and Employers to Plan and Respond to Coronavirus Disease 2019 (COVID-19), and Coronavirus Disease 2019 (COVID-19): How to Protect Yourself & Others. For most California workplaces, adopting changes to their IIPP is mandatory since COVID-19 is widespread in the community.

Cal-OSHA identifies employee training is an important issue for compliance. Cal-OSHA lists in the linked guidance what Coronavirus training must include.  Of note, training must be provided in a readily understandable language for the workers being trained.

The Cal-OSHA guidance addresses other information such as protective equipment, washing facilities, and more.  So, employers should review it carefully to ensure they are ready for re-opening in compliance.  This is especially important as some workers may resist returning to the workplace based on perceived unsafe conditions.

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