Yesterday, OSHA issued guidance aimed at educating workers and employers on how to properly use face coverings at work during the COVID-19 pandemic. Structured as a series of frequently asked questions with answers, the guidance is the latest word from OSHA on measures workplaces can and should take to protect against the spread of COVID-19.
The FAQs begin with a description of the differences between cloth face coverings, surgical masks, and respirators. OSHA makes it clear that cloth face coverings are not considered PPE and will not protect the wearer from airborne infectious agents. Surgical masks may protect against splashes and sprays, and they may be considered PPE when used for that purpose. Respirators, which may be necessary to protect workers performing certain jobs, contain proper filtering material and must be properly fitted and used by the wearer.
Because cloth face coverings are not considered PPE, OSHA’s existing PPE standards do not require that employers provide them to workers. However, relying on CDC recommendations, “OSHA generally recommends that employers encourage workers to wear face coverings at work.” Cloth face coverings may be appropriate, depending on the work environment and particular job functions, and the use of cloth face coverings may conserve PPE, such as surgical masks, for healthcare settings in which they are needed the most.
There may be instances where cloth face coverings are not appropriate, however, such as when a job function might exacerbate the hazard (e.g., the face covering could become contaminated with chemicals or infectious material). In those cases, employers may need to consider PPE, such as surgical masks or face shields. Employers should also consider whether they need to provide masks with clear windows in cases where an employee or members of the public may need to lip-read to communicate.
OSHA makes it clear that face coverings do not eliminate the need for social distancing in the workplace.
Notably, the FAQs state that the General Duty Clause requires employers to furnish a workplace that is free from recognized hazardous that may cause death or serious physical harm. “Control measures may include a combination of engineering and administrative controls, safe work practices like social distancing, and PPE.”