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COVID-19 Updates To Injury Illness Prevention Plans

by | May 1, 2020 | Firm News |

DO YOU NEED TO REVIEW YOUR INJURY ILLNESS PREVENTION PLANS TO SPECIFICALLY ACCOUNT FOR THE RISK OF COVID-19?  Applying best employment practices, the answer is YES.  Every employer’s IIPP should be flexible and is governed by what is known in the OSHA-world as a “performance standard.”  The performance standard allows employers to create and tailor their IIPPs as necessary to effectively guard against hazards in each particular place of employment.  Therefore, it would behoove employers to use this time to update, train, and guard against the risk of COVID-19 in their workplace.

CAL/OSHA has disbursed guidance requiring employers adopt changes to its IIPP.  Specifically, Cal/OSHA has developed an extensive list of “infection prevention measures” employers should include in a written IIPP as well as various topics on which employers should train employees.


It is recommended that all employers review and evaluate their existing IIPP and include, as an amendment to the existing IIPP or a revised IIPP, the following infection prevention measures:

  • Actively encourage sick employees to stay home.
  • Immediately send employees home or to medical care, as needed, if they have a frequent cough, fever, difficulty breathing, chills, muscle pain, headache, sore throat, or recent loss of taste or smell.
  • Ensure employees who are out ill with fever or acute respiratory symptoms do not return to work until both of the following occur:
    • At least three full days pass with no fever (without the use of fever-reducing medications) and no acute respiratory illness symptoms; and
    • At least 10 days pass since the symptoms first appeared.
  • Provide employees with paid sick leave or expanded family and medical leave for specified reasons related to COVID-19 if required to by the Families First Coronavirus Response Act;
  • Ensure employees that return to work following an illness promptly report any recurrence of symptoms.
  • Encourage employees to telework from home when possible.
  • Practice physical distancing by canceling in-person meetings, using video or telephonic meetings, and maintaining a distance of at least 6 feet between persons at the workplace when possible.
  • Provide employees with cloth face covers or encourage employees to use their own face covers for use whenever employees may be in workplaces with other persons. Cloth face coverings are not personal protective equipment (PPE), but combined with physical distancing of at least six feet, they may help prevent infected persons without symptoms from unknowingly spreading COVID-19.
  • CDC recommends that the general public not use surgical masks or N-95 respirators, so that these critical supplies are available to health care workers and first responders.
  • Avoid shared workspaces (desks, offices, and cubicles) and work items (phones, computers, other work tools, and equipment) when possible.
  • If they must be shared, clean and disinfect shared workspaces and work items before and after use.
  • Establish procedures to routinely clean and disinfect commonly touched objects and surfaces such as elevator buttons, handrails, copy machines, faucets, and doorknobs. Surfaces should be cleaned with soap and water prior to disinfection. These procedures should include:
    • Using disinfectants that are EPA-approved for use against the virus that causes COVID-19.
    • Providing EPA-registered disposable wipes for employees to wipe down commonly used surfaces before use.
    • Following the manufacturer’s instructions for all cleaning and disinfection products (e.g., safety requirements, PPE, concentration, contact time).
    • Ensuring there are adequate supplies to support cleaning and disinfection practices.
  • If an employee is confirmed to have COVID-19 infection:
    • Inform employees of their possible exposure to COVID-19 in the workplace but maintain confidentiality as required by the Americans with Disabilities Act (ADA). Please see further information on protecting the privacy of persons with COVID-19 from the California Department of Fair Employment and Housing.
    • Temporarily close the general area where the infected employee worked until cleaning is completed.
    • Conduct deep cleaning of the entire general area where the infected employee worked and may have been, including breakrooms, restrooms and travel areas, with a cleaning agent approved for use by the EPA against coronavirus. It should ideally be performed by a professional cleaning service.
      • Any person cleaning the area should be equipped with the proper PPE for COVID-19 disinfection (disposable gown, gloves, eye protection, mask, or respirator if required) in addition to PPE required for cleaning products. See below for further information on PPE.
  • Advise employees to avoid non-essential travel if possible and check CDC’s Traveler’s Health Notices prior to travel.

For employers in industries such as retail sales or service industries, to protect those employees with frequent contact with the public, arrange work and implement measures that account for the possibility that the public is a possible contamination source, including:

  • Conduct even more frequent cleaning and disinfection of surfaces touched by the public such as credit card machines, touch screens, shopping carts and doors.
  • Protect cashiers and other workers who have frequent interaction with the public with engineering controls such as Plexiglas screens or other physical barriers, or spatial barriers of at least six feet, if feasible.
  • If exposures to the general public cannot be eliminated with engineering controls, require or encourage customers to wear face coverings, which are mandatory in some jurisdictions.
  • Schedule work to allow frequent hand washing by employees handling items (cash, credit cards, merchandise, etc.) touched by members of the public.  Notably, Executive Order N-51-20 requires that employees working in food facilities (as defined by the California Retail Food Code) must be permitted to wash their hands every 30 minutes and additionally, as needed.
  • Enforce physical distancing by limiting the number of customers in retail space.
  • Ask customers to take precautions such as only touching items they intend to purchase, and provide hand sanitizer stations.
  • Provide workers handling items touched by the public with PPE (i.e., disposable gloves).


  • General description of COVID-19, symptoms, when to seek medical attention, how to prevent its spread, and the employer’s procedures for preventing its spread at the workplace.
  • How an infected person can spread COVID-19 to others even if they are not sick.
  • How to prevent the spread of COVID-19 by using cloth face covers, including:
    • CDC guidelines that everyone should use cloth face covers when around other persons.
    • How cloth face covers can help protect persons around the user when combined with physical distancing and frequent hand washing.
    • Information that cloth face covers are not protective equipment and do not protect the person wearing a cloth face cover from COVID-19.
    • Instructions on washing and sanitizing hands before and after using face coverings, which should be washed after each shift.
  • Cough and sneeze etiquette.
  • Washing hands with soap and water for at least 20 seconds, after interacting with other persons and after contacting shared surfaces or objects. As noted above, Executive Order N-51-20 requires that employees working in food facilities (as defined by the California Retail Food Code) must be permitted to wash their hands every 30 minutes and additionally, as needed.
  • Avoiding touching eyes, nose, and mouth with unwashed hands.
  • Avoiding sharing personal items with co-workers (i.e., dishes, cups, utensils, towels.
  • Providing tissues, no-touch disposal trash cans and hand sanitizer for use by employees.
  • Safely using cleaners and disinfectants, which includes:
    • The hazards of the cleaners and disinfectants used at the worksite.
    • Wearing PPE (such as gloves).
    • Ensuring cleaners and disinfectants are used in a manner that does not endanger employees.