May 28, 2020

Agencies Release COVID-19 Guidance for Construction Industry

Separate guidance released this week by CDC and OSHA provides recommendations for protecting workers at construction sites during the COVID-19 pandemic. Construction workers, generally considered essential and therefore not subject to state stay-at-home orders, may nevertheless encounter additional exposure to the disease as other businesses open and communities become more active.

OSHA stresses that its guidance is non-binding and creates no new legal obligations. The guidance associates specific construction work tasks with the four levels of the agency’s “exposure risk pyramid,” which categorizes tasks as lower risk, medium risk, high risk, or very high risk. In the context of COVID-19, lower-risk tasks include those that allow employees to remain at least six feet apart and involve little contact with others. High-risk tasks require entering an indoor work site occupied by people suspected or known to have COVID-19. The agency does not identify tasks that have a “very high” exposure risk for the disease. According to OSHA, this category is not applicable for most construction work.

OSHA’s guidance recommends the use of engineering controls, such as plastic barriers to separate workers when working indoors, and administrative controls, such as the use of screening questions to assess the risk of work assignments in indoor environments where others may be present. The guidance also addresses training topics and includes a lengthy section on the use of cloth face coverings.

CDC’s guidance includes recommendations for employers on reducing disease transmission among workers, maintaining a healthy work environment, and maintaining healthy business operations. Like OSHA, CDC recommends staggered work shifts, physical separation of workers, restricting access to limit the number of workers in an area, reducing the number of people at meetings, and maintaining social distancing at choke points such as hallways.

The agency’s recommendations for maintaining healthy business operations include designating a “safety and health officer” at every job site with responsibility for responding to COVID-19 concerns and implementing sick leave policies. These recommendations do not appear in the OSHA guidance.

Earlier this month, through the website, AIHA released several guidance documents that address return-to-work considerations for specific industries, including construction (PDF). The AIHA guidance for construction identifies a number of potential actions that are not mentioned in either the CDC or OSHA documents, such as maintaining daily “approved visitor” logs, considering four-day work weeks, and using color-coded access stickers on work helmets to indicate which employees can access certain areas of a job site.