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You May Not Be as Protected as You Think

By Darcy Cook, Safety Trainers

If you received a Rapid Response Letter from OSHA or a call from Department of Public Health [DPH] for a COVID-19 related complaint would you have the documents that they expect?  
We continue to field calls from companies who did not write a COVID-19 Control Plan that meets the expectations of DPH or OSHA nor do they have the supporting documentation to submit. Do not let this be you.

Did you use the template that the State of Massachusetts posted on its website as your COVID-19 Control Plan? If yes, you are not as protected as you think.

Massachusetts is not an OSHA State. That means all businesses in State of Massachusetts must follow all OSHA federal laws for the workplace. The template on mass.gov website is more like a checklist to assist you in writing a detailed control plan that clearly explains your process to the Department of Public Health and/or OSHA. Checking the box does not tell your story.

When an employee calls OSHA to complain about unsafe conditions due to COVID-19 in the workplace, you can expect a rapid response letter requesting a written response and supporting documents be submitted within 5 days. Would you have it? Or, would you be in a panic to respond within 5 days?

We have responded to several calls from companies in a panic who did not have the documents they need to send.

Why? Because most companies using the template on mass.gov did not write supporting procedures in the four areas outlined in the document to include social distancing, hygiene protocols, staffing and operations and cleaning and disinfecting.

Can you show me in writing and clearly describe your screening process, how you have restricted employee contact, what surfaces are cleaned routinely, how often and who is disinfecting after identification of a positive employee case? Do you have disinfecting logs, a contact tracing report, and a corrective action statement for each employee who was in your buildings within the two-day window of an employee testing positive? And, can you show documentation indicating all of the training you have done with your employees to date on COVID-19 related topics?

When we write our COVID-19 Control Plans, the average number of pages is 14. We recently received a copy of a COVID-19 Control Plan for the State of California and it is 42 pages long. What’s my point, the two-page check list on mass.gov website is not adequate.

On his first full day in office, President Joe Biden ordered OSHA to reconsider whether an emergency temporary standard for COVID-19 is necessary, and if so, to issue one by March 15.

All businesses will need a COVID-19 Control Plan. So, I ask you, would you be able to answer questions and provide supporting documentation to DPH or OSHA?

If you are unsure, there are workshops and trainings available through AIM HR Solutions and Mass MEP to help you comply, educate you, and help you plan for the future. The COVID-19 conversation and infectious control is not going away anytime soon.


OSHA Guidance and Mitigating and Preventing the Spread of COVID-19 in the Workplace – January 29, 2021.

Darcy Cook, CHSO, SHS, PTA, is President of Safety Trainers, a division of Cook Professional Resources, Inc. (Worcester, MA). She can be reached at (508) 799-2857 or at [email protected] or www.safetytrainers.com

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