OSHA(Occupational Safety and Health Administration)-the body established in 1971 in the U.S., at the Department of Labor, to improve worker safety-has published guidelines for dealing with the Covid-19 era. (1) A structured but easy-to-read document, where it is possible to find some details that the restraint measures defined by the social partners in Italy lack instead (2,3). Useful insights and critical issues to follow.
OSHA Guidance on Preparing Workplaces for COVID-19
OSHA guidelines provide concrete guidance on how to go about analyzing the risk of SARS-CoV-2 infection in different work settings. Precisely on the basis of the risk analysis–also taking into account good industrial hygiene practices and traditional infection prevention acts already developed by OSHA–employers must organize effective procedures. Then plan reorganization of work, systematic use of personal protective equipment(PPE or PPE, Personal Protective Equipment), technical and administrative controls.
Covid-19, the key concepts
It is imperative, first of all, to share the key concepts related to SARS-CoV-2, which, it is stressed, is a highly contagious virus. The only one, among the 103 coronaviruses sequenced in recent years, whose transmission even by asymptomatic or paucisymptomatic people is established.
The mode of transmission merits special precautions. Direct contact is the primary route that is intended to be prevented in the U.S., it should be noted, by definition of an interpersonal safety distance twice that established in Italy (6 feet, almost 2 meters, instead of 1). (4)
Specific attention should be paid, we add, to the persistence of SARS-CoV-2 on surfaces. A recent study by the Universidade Federal de Minas Gerais (Brazil) revealed the presence of the virus in 16.8 percent of 101 samples taken in public places (bus stations, plazas and streets, spaces near hospitals). (5) In addition to other experimental research already published (6,7,8). These also deserve consideration when updating HACCP plans to ensure food safety. (9)
Prevention plan
Each employer must inform and train all employees on the above elements and compliance with the procedures adopted in the company to reduce the risk of exposure to SARS-CoV-2 of workers (and visitors, including suppliers of goods and services, e.g., maintenance, cleaning, transportation, surveillance).
Therefore, a preparedness plan needs to be developed that includes both preventive measures and corrective actions to be taken under hazardous conditions (symptoms and virus positivity, at-risk contacts with sick or suspected people). And therefore:
– analysis of the risk levels associated with the various work sites and environments (of which preliminary classification is provided, see last paragraph below) and the work tasks performed by individuals,
– Infectious disease preparedness and response by taking protective actions against COVID-19, based on the specific risks identified,
– Timely interception of those at risk of infection (travelers, unprotected health care workers in contact with sick or suspected patients),
– Sharing of non-occupational risk factors (at home and in social settings),
– consideration of workers’ individual risk factors (advanced age, comorbidities, with special regard to immunocompromising conditions, pregnancy, etc.),
– reorganization. Social distancing, staggered shifts, rescheduling of production levels, smart working, carrying out essential operations with a reduced workforce, training workers toward different stages of production to maintain continuity even in the event of staff reductions,
– Updating and supplementing the plan in relation to organizational changes or external factors, (10)
Hygienic precautions
The prevention plan based on risk analysis is supplemented by a set of basic hygiene precautions:
– Frequent and thorough hand washing, (7)
– Respiratory hygiene (including by providing paper tissues to customers/public and providing closed containers for their disposal),
– use of N95 respirators, also known as FFP3) or masks and other PPE, depending on the sites and activities performed,
– Restrict staff movement within the premises,
– Develop, implement and communicate flexibility tools at work,
– Discourage sharing of phones, desks, offices. Discourage turnover of people on the same tools and equipment,
– Maintain regular cleaning practices of surfaces, equipment, work environments,
– Use disinfectants active against emerging viral pathogens.
Human Resources
Human resource management should follow the following criteria:
– Use flexible working modes/timetables (telecommuting, staggered shifts) to increase the physical distance between employees,
– Encourage non-punitive temporary leave of non-essential workers,
– Develop policies and procedures for rapid identification and isolation of sick people. Therefore, encourage employees to independently monitor signs and symptoms of COVID-19 and report any symptoms or reports of illness,
– Encourage workers to stay home if positive or sick,
– Ensure flexible policies that allow employees to stay home to care for family members, children and sick relatives.
Checks
Audits of the effectiveness of the preparedness plan must consider the various logistical and organizational aspects.
– infrastructure. It must be verified that workplaces and equipment are in themselves suitable to reduce the risk of infection. Without without relying on workers’ behavior.
▶️ Installing high-efficiency air filters, and increasing the ventilation rate in the working environment. Aspects still ignored in Italy, although transmission of the virus through ventilation systems is already established. (9) Physical barriers for sneeze guards and protected counters for customer services should also be checked,
– organization and training. Contacts between workers and clients should take place through virtual rather than physical meetings, encouraging telecommuting and rarefied attendance on the premises. Provide for maintaining constant distance between people, stop non-essential travel/transfers, develop emergency communication plans, provide workers with up-to-date education/training on risk factors and essential precautions, training on how to properly wear/remove PPE,
– Safe work practices and proper use of personal protective equipment (gloves, goggles, face shields, face masks and respiratory protection). Suitability of selected PPE with respect to identified hazards, its sanitization and periodic replacement, storage and disposal.
Risk classification
Occupational exposure to SARS CoV-2 is subject to a risk classification (very high, high, medium or low). The level of risk depends on the production sector and the inevitability of proximity between people, <2 meters, in enclosed spaces.
Very high risk jobs are those referred to healthcare personnel (physicians, nurses, dentists, paramedics, technicians) called to handle emergencies, bronchoscopies, dentistry, examinations or invasive specimen collection on known or suspected COVID patients.
High risk of exposure is identified in jobs with exposure to known or suspected sources of Covid-19. Health and support staff to enter the rooms of patients, positive or suspected to be positive for the new coronavirus.
▶️ Medium exposure risk is identified in activities that postulate frequent and/or close contact (within 2 meters) with people ‘at risk Covid’. That is, almost all public contact work.
In these cases, in addition to physical barriers, access restrictions and rare attendance, it is recommended that the combination of gloves/clothing/face mask and/or goggles be provided as PPE.
Low risk of exposure is found in places with minimal interpersonal contact. The focus here, in OSHA’s view, should be on training and monitoring of staff health conditions. (10)
Critical issues in the U.S. production system
OSHA’s efforts, which are distinguished by intensive standardization efforts, among other things, are unfortunately not matched by U.S. federal and state policy. Data on occupational injuries, illnesses and deaths are indeed still significant, in general terms. (11) And the Bureau of Labor Statistics has already announced the ‘difficulty’ — or nolont — of compiling data on the incidence of Covid-19 in this regard. (11)
Mexico then represents perhaps the most serious flaw in the U.S. production system. U.S.-based corporations–following the entry into force of theNorth American Free Trade Agreement (NAFTA) on 1.1.94–have largely relocated industrial production to Mexico. Cars and planes, weapons and appliances, and more.
The NIMBY(Not in my back yard) policy that has always inspired the globalization of community and ecosystem exploitation is now thus being operated to force Mexican workers in factories owned by or serving the U.S. economy not to stop operations. When even the working conditions do not allow for their safety (12,13).
Dario Dongo, Sarah Lanzilli, Amaranta Traversa, Claudio Biglia
Notes
(1) OSHA(Occupational Safety and Health Administration).
Guidance on Preparing Workplaces for COVID-19
. OSHA Document 3990-03 2020, https://www.osha.gov/Publications/OSHA3990.pdf
(2) Dario Dongo. Coronavirus, containment measures in work environments. Protocol 14.3.20. GIFT (Great Italian Food Trade). 14.3.20, https://www.greatitalianfoodtrade.it/sicurezza/coronavirus-misure-di-contenimento-negli-ambienti-di-lavoro-protocollo-14-3-20
(3) Amaranta Traversa, Sarah Lanzilli, Claudio Biglia, Dario Dongo. Covid-19 and occupational safety, Protocol 24.4.20. THE ABC’S. GIFT (Great Italian Food Trade). 1.5.20, https://www.greatitalianfoodtrade.it/sicurezza/covid-19-e-sicurezza-sul-lavoro-protocollo-24-4-20-l-abc
(4) Dario Dongo.
Safety distances, the key to curbing Covid-19.
. Égalité. 3/31/20, https://www.egalite.org/distanze-di-sicurezza-la-chiave-per-arginare-covid-19/
(5) Jonatas Santos Abrahao, Livia Sacchetto Pengo et al.
Detection of SARS-CoV-2 RNA on public surfaces in a densely populated urban area of Brazil.
MedRxiv(pre-published study, before peer-review). doi: https://doi.org/10.1101/2020.05.07.20094631
(6) Dario Dongo, Martina Novelli.
Coronavirus persists for a long time on surfaces, here’s how to inactivate it
. Égalité. 3/15/20, https://www.egalite.org/il-coronavirus-persiste-a-lungo-sulle-superfici-bisogna-sanificare-anche-gli-smartphone/
(7) Martina Novelli, Dario Dongo. Covid-19, hydro-alcoholic hand sanitizers. How to sanitize surfaces, bathrooms, fabrics. Égalité. 4/23/20, https://www.egalite.org/covid-19-disinfettanti-idro-alcolici-per-le-mani-come-sanificare-superfici-bagni-tessuti/
(8) Dario Dongo, Andrea Gazzetta, Fabrizio De Stefani. Covid-19 and food safety, preventive and corrective actions. GIFT(Great Italian Food Trade). 6.5.20, https://www.greatitalianfoodtrade.it/sicurezza/covid-19-e-sicurezza-alimentare-azioni-preventive-e-correttive
(9) Dario Dongo, Martina Novelli. Masks for everyone? The scientific studies in favor. Égalité. 7.4.20, https://www.egalite.org/coronavirus-mascherine-per-tutti-gli-studi-scientifici-a-favore/
(10) Updated information at www.osha.gov, www.cdc.gov, www.cdc.gov/niosh
(11) U.S. Bureau of Labor Statistics (BLS).
Census of Fatal Occupational Injuries (CFOI) – Current and Revised Data.
, https://www.bls.gov/iif/oshcfoi1.htm#2018
(12) US Bureau of Labor Statistics (BLS). Effects of COVID-19 Pandemic on Workplace Injuries and Illnesses, Compensation, and Occupational Requirements Statistics. 4/30/20, https://www.bls.gov/bls/effects-of-covid-19-on-workplace-injuries-and-illnesses-compensation-and-occupational-requirements.htm
(12) Viri Ríos. Coronavirus Has Mexico’s Workers Pinned Between U.S. Business Interests and Their President’s Obsessive Austerity. The Intercept. 1.5.20
(13) Natalie Kitroeff. As Workers Fall Ill, U.S. Presses Mexico to Keep American-Owned Plants Open. The New York Times. 30.4.20
Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.
Veterinarian, specialist in the inspection of food of animal origin. He participates in several research projects in food safety and microbiology. She co-authored numerous monographs on food safety and over thirty scientific publications.
Veterinary surgeon, specializing in the inspection of food of animal origin. Since 1982 he has been a public veterinarian, since 1990 he has taught at the Universities of Turin and Teramo. He is the author of over seventy scientific publications and co-author of various texts on microbiology, radiocontamination of food, surveillance, health and food law, trade in public areas and communication in health emergencies.
Veterinary manager ASL Città di Torino, specialist in Inspection of food of animal origin, expert in food law, has published in international journals and deals, among other things, with food delivery and hygiene of collective catering.
