On April 26, 2020, the Centers for Disease Control and Prevention (CDC) and the Occupational Safety and Health Administration (OSHA) issued guidance for planning, controls, and related steps to address the risk of COVID-19 facing meat and poultry industry. The interim guidance supplements previous guidance from these agencies recognizing the need for food and agriculture businesses to continue operations during the COVID-19 pandemic as part of the United States’ critical infrastructure.
The interim guidance provides recommendations and practices to mitigate the unique risks these workers face — at the workplace and in social circumstances (e.g., transportation, living arrangements). The guidance recommends creating and implementing assessment and control plans that take into account the challenges specific to operating meat and poultry processing facilities.
Recommendations in the interim guidance focus on a hierarchy of issues, including engineering and administrative controls. Examples of engineering controls include configuring work environments to minimize contact among workers. Administrative controls include tactics such as worker education, staggering scheduled arrival and departure times, reminders of best practices, and a review of sick leave policies. In creating these assessment and control plans, facilities should coordinate with state and local public officials responsible for health and occupational safety to help determine the appropriate role for testing and workplace contact tracing.
Although this interim guidance is specific to meat and poultry processing workers, it provides useful information for all food and agriculture businesses operating during the COVID-19 pandemic. There are references throughout the interim guidance to the prior CDC Critical Infrastructure Guidance that covers points such as personal protective equipment and monitoring worker health. Also, OSHA reminds employers about the need to follow standard OSHA requirements, such as recordkeeping rules for questionnaires.
As the number of cases around the world grows, Faegre Drinker’s Coronavirus Resource Center is available to help you understand and assess the legal, regulatory and commercial implications of COVID-19.