By James L. CurtisMark A. Lies, IIAdam R. Young, Matthew A. Sloan, and Craig B. Simonsen

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Seyfarth Synopsis: The Occupational Safety and Health Administration (OSHA) and the Centers for Disease Control and Prevention (CDC) have jointly released coronavirus-related interim guidance for meatpacking and meat processing workers and employers. The interim guidance provides policies and precautions to reduce the risk of exposure to the coronavirus.

The meat and poultry industry has been significantly impacted by COVID-19 in several states, forcing some facilities to scale back operations or shutter entirely. OSHA and the CDC have found that  close and prolonged contact between employees on processing lines and sharing transportation to and from facilities, might be increasing workers’ risk for exposure to the virus.

In the April 26, 2020 joint announcement of the interim guidance, Principal Deputy Assistant Secretary of Labor for Occupational Safety and Health Loren Sweatt stated that “as essential workers, those in the meatpacking and processing industries need to be protected from coronavirus for their own safety and health.” Moreover, “OSHA’s newest guidance document outlines steps employers can take to provide a safe and healthy workplace for workers in the meatpacking and processing industries.”

The interim guidance includes these recommendations:

  • Implementing appropriate engineering controls, such as modifying the alignment of workstations, including along processing lines, if feasible, so that workers are at least six feet apart in all directions;
  • Implementing administrative controls, such as encouraging workers to avoid carpooling to and from work, if possible, and staggering break times or providing temporary break areas and restrooms to avoid groups of workers during breaks
  • Cleaning shared meatpacking and processing tools, at least as often as workers change workstations or move to a new set of tools;
  • Screening employees for the coronavirus before they enter work facilities;
  • Managing workers who are showing symptoms of the coronavirus;
  • Using appropriate personal protective equipment; and
  • Practicing social distancing at the workplace.

It is also important to note that several state and local emergency orders have authorized more stringent requirements and recommendations than those of OSHA and the CDC for essential employees on issues like the use of cloth face coverings, social distancing, and pre-shift employee health screening.

It is also well recognized that OSHA has no regulations on response to COVID-19 and that in compliance with the General Duty Clause (GDC), the employer has the right and obligation to determine and implement sufficient and “effective” means and methods to mitigate or reduce employee exposure to this recognized hazard. In addition, the industry is regulated by the USDA, requiring employers to implement safety and health regulations that address many of these same issues.

For more information on this or any related topic, please contact the authors, your Seyfarth attorney, or any member of the Workplace Safety and Health (OSHA/MSHA) Team.