The emergency regulations to protect workers from COVID-19 went into effect on December 1, 2020, as announced that day in a press release from the Department of Industrial Relations.
The emergency regulations apply to most workers in California not covered by Cal/OSHA’s Aerosol Transmissible Diseases standard. The regulations do require the employer to develop a site-specific written COVID-19 prevention plan, although the employer has the alternative to incorporate the conditions into its existing Injury and Illness Prevention Program.
Regulation on Prevention Plan
Section 3205, COVID-19 Prevention, dealing with developing the CPP, is more than nine 8.5”x11” pages long.
The elements of subsection (c), that portion of the prevention regulation to be in writing, is seven pages and addresses in part masks, social distancing, medical privacy, sanitation, airborne particulates, employee interaction, infection investigation, hazard investigation/mitigation, reporting/recordkeeping, and ventilation.
For that reason, I recommend using the Cal/OSHA model plan.
Model Written Program
The posted Cal/OSHA model written COVID prevention plan is set up with introductory statements at the beginning and a leading statement as to what the employer is to address.
However, the template plan is careful to inform the user that the document is merely a suggestion and circumstances may warrant additional information to address the employer’s specific conditions.
The sections in the model plan cover subjects such as authority, identification and evaluation of COVID-19 hazards, employee preparation, employee screening, correction and control of COVID-19 hazards, masks, engineering controls, cleaning and disinfecting, investigation, communication, training, and recordkeeping.
Also included are four appendices addressing identification of COVID-19 hazards, inspections with check lists, investigating cases, and training, plus considerations for infections and outbreaks, and employer-provided housing and transportation.