There has been a lot of understandable panic and confusion around the new 74 page Oregon OSHA rules, and we agree, they’re kinda confusing. Whenever a document is that long with that many paragraphs, subsections, references back to definition pages, appendices, etc., it’s never easy to see exactly what applies to you and your business. So we’ve tried to simplify it a bit to help you quickly react and make sure you’re in compliance. We’ll go section by section to clarify what exactly this all means and what you need to do.
OAR 437-001-0744 Addressing COVID-19 Workplace Risks
Today’s Oregon OSHA rules seek to clarify exactly what is expected from employers and employees. However, a majority of these guidelines have been directly translated from the existing Oregon Health Authority guidelines that have been slowly evolving over the course of the pandemic. To see the whole new rules document from OSHA click the button below:
View Complete New OSHA Rules Document
Rules Document Outline:
This first part covers who is affected by the rules, and basically says all workplaces are required to abide by Section 3 of this document, and that some workplaces have extra rules based on their proximity to the virus itself. It then goes into a bunch of different definitions for everything, which can be useful to reference back to every now and then as you work through the document. If you do that though, be sure to remember what page you were on, since the original document doesn’t have page numbers on it. Actually, hold on a sec. Let’s add some page numbers so it’s not so hard.
Rules Document with Page Numbers Added
Section 3 Rules:
Section 3 is where we get to the actual rule changes for probably 95% of all businesses. As far as things go, this is basically OSHA-ifying the preexisting Oregon Health Authority Guidelines which we’ve all been abiding by since we entered Phase 2. However, there are a few added steps to ensure and document that all businesses are following the guidelines. Here are the things it goes over:
- Physical Distancing
- Masks and Face Coverings
- Cleaning and Sanitation
- Poster Guidelines (OSHA will apparently be providing a poster)
- Requirements for Commercial Landlords
- HVAC Guidelines
- Exposure Risk Assessment (Which is a new self-administered test to make sure your business is safe)
- Infection Control Plan (Which is a plan informed by the Risk Assessment)
- Employee Training
- COVID-19 Infection Notification Process
- Testing for workers
- Medical Removal of a worker from a workplace
- Sector Specific Appendices
So that’s basically it for Section 3. It goes into a lot of detail about what’s required for which business, as well as deadlines for each, but they also provided a super handy checklist for what’s required for each business type. For instance, the Exposure Risk Assessment doesn’t have to be written down unless you have over 10 employees. So if you want to see what is required for your business, click the first link below, which will take you to the Overview Table checklist, then if you want to see just Section 3 of the document, click the second link.
Section 4 Rules:
Section 4 is just for businesses that are at “Exceptional Risk” which are defined as:
- Direct Patient Care
- Environmental decontamination in a healthcare setting
- Aerosol-generating healthcare or postmortem procedures
- Direct Client service in residential or assisted living facilities
- Emergency First Responder Activities
- Personal Care activities that involve close contact with individuals
- Handling, processing, or transporting human tissue specimens
So if your business doesn’t do any of those, then Section 4 doesn’t apply to you.
Appendices:
After Section 4 comes sector specific appendices. We’ll link each of the specific sector appendices below, so you can easily find the one that applies to your business directly! Each of these has both broad and specific things your business needs to do, as well as links to different resources that can help you accomplish those goals. So find your sector’s name below and click on the link to find your specific appendix.
Restaurants, Bars, Brewpubs, Etc.
Indoor Outdoor Entertainment Facilities
Outdoor Recreation Organizations
In Conclusion:
Ok, how you holding up? That was a lot right? So let’s sum up. These new OSHA Rule changes are basically just the OHA guidelines, but more codified with more accountability.
Each of the new requirements have hard deadlines, each of which are in Section 3 of the document. Section 3 is the place where all the new rules for 95-ish percent of businesses are located, with Section 4 being for those businesses that are at Extreme Risk.
After you go through Section 3, you’ll go through the Appendix section that has to do with your business sector.
Easy as pie right? You’ve got this. If you need any help discerning what all you should be doing, don’t hesitate to give the OSHA office a call at 503-231-2017 (our OSHA office is the one in Portland). We might also be able to help a bit, so you can give us a call at 541-923-5191, even though we are by no means experts ourselves! We’re all gonna get through this and we’ll all be back to normal in no time!
