Seyfarth Synopsis: In two recent guidance documents, OSHA recommends that employers encourage workers to wear cloth face coverings to reduce the spread of COVID-19. OSHA further addresses the challenges posed by cloth face coverings for workers in hot and humid environments or while performing strenuous activities.
Since the CDC issued its April 2020 recommendation that individuals wear masks to stem the spread of the pandemic, we have blogged on the various guidelines and challenges employers face. See Heat Illness – A Phantom Menace: Sweatt Blogs on Safety Measures and Heat Illness in the Workplace, Heat Illness Strikes Back: Return to Work’s Untold Story, OSHA Updates FAQs on Face Masks in the Workplace, and DOL Issues FAQs About Face Coverings, Surgical Masks, and Respirators in the Workplace.
In its new guidance documents, OSHA recommends that employers follow the best practices to protect against the spread of COVID-19 and the risk of heat-related illness, including:
- Acclimatize new and returning workers (through rotation between jobs that require face coverings and those that do not) to environmental and work conditions while wearing cloth face coverings.
- Prioritize the use of cloth face coverings when workers are in close contact with others (less than 6 feet), such as during group travel or shift meetings.
- Allow workers to remove cloth face coverings when they can safely maintain at least 6 feet of physical distance from others.
- Evaluate the feasibility of wearing cloth face coverings for each worker and consider alternatives (e.g., face shields) when appropriate.
- Increase the frequency of hydration and rest breaks in cooled environments.
- Incorporate at least 6 feet of physical distancing into break areas by staggering breaks, spacing workers, or limiting the number of workers on break at a time, where feasible.
- Encourage workers to use cloth face coverings that optimize fit and comfort and are made out of breathable, moisture-wicking materials.
- Encourage workers to change cloth face coverings when wet, as wet face coverings make it more difficult to breathe and are not as effective. Provide clean replacement cloth face coverings or disposable face masks, as needed, for workers to change into throughout the work shift.
- Plan for heat emergencies and train workers on heat stress prevention and treatment.
- Avoid scheduling strenuous tasks during the hottest parts of the day and alter work shifts to cooler parts of the day, when possible.
- Allow workers to utilize personal passive cooling devices such as ice vests.
- Increase the frequency of communication to workers and encourage workers to monitor themselves and others for signs of heat illness.
Employers should consider the application of the individual guidance for your particular workplace. The Use of Cloth Face Coverings while Working Outdoors in Hot and Humid Conditions. (September 2020), and The Use of Cloth Face Coverings while Working Indoors in Hot and Humid Conditions. (September 2020).
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.