COVID-19 Prevention Plans: What you need to know
Do I need a Covid-19 Prevention Plan (CPP)?
Yes. The Department of Labor and Industries’ DOSH (Dept. of Safety and Health), compliance inspectors will be asking you for your CPP if they come on your jobsite to investigate a violation or accident. The Dept. also receives many complaints regarding this issue on a daily basis.
Do I need a site specific CPP?
No. But your CPP will need to address your overall plan and possibly need to be modified if a specific jobsite has conditions outside of the normal scope of your CPP.
Do I need to post the CPP on my jobsite?
No. But you will be required to produce your CPP as part of your Accident Prevention Program (APP), or as a separate safety program when documents are requested by a DOSH inspector.
How will DOSH inspectors go about determining if my CPP is effective in practice?
DOSH inspectors will want to assess your CPP and may interview you and your employees to get a general sense of what your company is actually doing to address the Dept’s. latest guidance, https://lni.wa.gov/forms-publications/F414-164-000.pdf regarding the spread of Covid-19.
What information should be included in my CPP?
The following information contains guidance for DOSH inspectors when investigating your CPP. This information comes directly from DOSH and should be used as a template to build your company’s own CPP.
Remember, your CPP must be more than just a document, it must be effective in practice as well.
1 – Accident Prevention Program (APP):
a. Does the employer’s APP address COVID-19, or do they have a separate COVID-19 safety program?
b. Does it cover how employees will be educated on the hazards of COVID-19?
c. Does it cover the requirement for use of face coverings or more protective masks regardless of vaccination status?
d. Does it address the requirement for regular workplace cleaning/sanitizing?
e. Does it cover ensuring sick employees are not present in the workplace
2 – Vaccinations
a. Is this business in an industry where vaccination of all employees has been mandated?
b. If “yes”, then does the employer have a process in place to verify employee vaccination status?
c. If “yes”, is the employer taking steps to ensure only staff who are vaccinated or exempt are working at the location?
3 – Masking and Social Distancing:
a. Is the employer taking steps to prevent COVID-19 transmission, to include requiring face coverings or more protective masks for employees regardless of vaccination status?
b. Is the employer requiring and enforcing mask use and social distancing for unvaccinated employees and those whose vaccination status is unknown?
c. Are barriers or shields present in areas where social distancing cannot otherwise be accomplished between employee work locations, and other locations as appropriate (such as checkout in grocery and retail)?
d. If the business is “public facing,” is there appropriate signage in place regarding use of masks by visitors/public?
e. If the business is “public facing,” are there procedures established and followed to provide curbside service or somehow accommodate visitors/public who are unable to wear masks?
4 – Is sufficient cleaning/sanitizing for the prevention of COVID-19 and other communicable diseases being done?
5 – Handwashing:
a. Are hand washing facilities available in sufficient quantity?
b. Are hand washing facilities appropriately supplied with soap and water?
c. Where employers cannot provide unlimited access to full hand washing facilities at all times, have they provided alternate means for frequent hand cleaning (portable wash stations, wipes or towelettes with water and soap, or hand-sanitizer solutions)?