Hunton Employment & Labor Perspectives

The Centers for Disease Control and Occupational Safety and Health Administration collaborated to release new guidance for employers in the meat processing industry on April 26.

OSHA and the CDC noted several unique facets of meat processing work that exposed workers to increased likelihood of COVID-19 transmission at work, including close contact, the duration of the close contact, shared tools and surfaces and the frequency of ride-sharing and community-based interactions among employees.  As a result, the organizations released additional guidance to help employers keep employees safe, even as they continue to work to keep the food supply chain running.

The guidance first urges employers to create a COVID-19 assessment and control plan. Among other things, it suggests that employers make sure all employees know who to contact if they have questions about COVID-19 protocols, or to report symptoms or concerns about potential community spread.  The plans should also consider the proper role of testing and symptom check protocols.

Next, the guidance suggests several engineering and administrative controls meat processing employers can implement.  First, it suggests engineering controls, including modifying production lines so that employees are six feet apart.  It also suggests using physical barriers, like plastic guards or sheets, to separate employees.  Employers should also install additional handwashing stations and spread out seating in break rooms and shared areas.

For administrative controls, the guidance asks employers to encourage single-file movement through the facility, designate workers to monitor and assist with social distancing on processing floors, stagger break times to avoid groupings, stagger arrival and departure times to avoid congregations, and provide visual cues to remind employees to maintain social distance and follow other infection prevention protocols.  Employers are also encouraged to review leave and incentive policies so that employees know they will not be penalized for staying home if they are sick.

Employees should also wear cloth face coverings at work.  The face coverings should fit snugly over the nose and mouth, include multiple layers of fabric and allows for breathing without restriction.

The guidance provides that employers should follow strict and thorough cleaning protocols, particularly in tool-intensive operations.  For example, employers should wipe down frequently touched workspaces or surfaces at least once per shift, and every time workers change workstations.  Employers also should screen and monitor employees for symptoms of COVID-19, including temperature checks at the start of each shift, and provide additional personal protective equipment for employees when appropriate, including face shields.

Two days after the guidance issued, President Trump used to Defense Production Act to order the USDA to take steps to keep meat processing plants open.  The CDC/OSHA guidance will assist employers and public officials with following this mandate while keeping employees safe.