YOUR TESTING EXPERTS: WSS is committed to providing the knowledge your team needs to create a safer workplace.
What are the recommendations for the manufacturing industry from OSHA and the CDC?
The following information is from the CDC, released May 20, 2020.
Screening* and monitoring workers
Workplaces, particularly in areas where community transmission of COVID-19 is occurring, should consider developing and implementing a comprehensive screening and monitoring strategy aimed at preventing the introduction of COVID-19 into the work site. Consider a program of screening workers before entry into the workplace, criteria for exclusion of sick workers, including asymptomatic workers who have tested positive for COVID-19; and criteria for return to work of exposed and recovered (those who have had signs or symptoms of COVID-19 but have gotten better). This type of program should be coordinated to the extent possible with local public health authorities and could consist of the following activities.
Screening of workers for COVID-19
Screening manufacturing workers for COVID-19 symptoms (such as temperature checks) is an optional strategy that employers can use. If implemented for all workers, policies and procedures for screening workers should be developed in consultation with state and local health officials and occupational medicine professionals. Options to screen workers for COVID-19 symptoms include:
- Screen before entry into the facility.
- Provide verbal screening in appropriate language(s) [spoken by the employees] to determine whether workers have had symptoms including a cough, shortness of breath or difficulty breathing, fever, chills, repeated shaking with chills, muscle pain, headache, sore throat, and new loss of taste or smell in the past 24 hours.
- Check temperatures of workers at the start of each shift to identify anyone with a fever of 100.4°F or greater (or reported feelings of feverishness). Ensure that screeners:
- Are trained to use temperature monitors and monitors are accurate under conditions of use (such as cold temperatures); and
- Wear appropriate PPE.
- Do not let employees enter the workplace if they have a fever of 100.4°F or greater (or reported feelings of feverishness), or if screening results indicate that the worker is suspected of having COVID-19.
- Encourage workers to self-isolate and contact a healthcare provider;
- Provide information on the facility’s return-to-work policies and procedures; and
- Inform human resources, employer health unit (if in place), and supervisor (so the worker can be moved off schedule during illness and a replacement can be assigned, if needed).
Protect Personnel that Screen Your Workers
Ensure that personnel performing screening activities, including temperature checks, are appropriately protected from exposure to potentially infectious workers entering the facility:
- Implement engineering controls, such as physical barriers or dividers or rope and stanchion systems, to maintain at least 6 feet of distance between screeners and workers being screened.
- If screeners need to be within 6 feet of workers, provide them with appropriate PPE based on the repeated close contact the screeners have with other workers.
- Such PPE may include gloves, a gown, a face shield, and, at a minimum, a face mask.
- N95 filtering facepiece respirators (or more protective) may be appropriate for workers performing screening duties and necessary for workers managing a sick employee in the work environment…if that employee has signs or symptoms of COVID-19. If respirators are needed, they must be used in the context of a comprehensive respiratory protection program that includes medical exams, fit testing, and training in accordance with OSHA’s Respiratory Protection Standard (29 CFR 1910.134).
* Employers should evaluate the burdens and benefits of recording workers’ temperatures or asking them to complete written questionnaires. These types of written products become records that must be retained for the duration of the workers’ employment plus 30 years. See OSHA’s Access to Employee Exposure and Medical Records standard (29 CFR 1910.1020).
When and how will Texas re-open for business?
May 1 is the beginning of Stage 1. For more about the stages, recommendations, and requirements, see the Governor's Open Texas plan, released April 27, 2020.
What are the employer obligations as we mobilize the American workforce?
Develop and implement appropriate policies, in accordance with Federal, State, and local regulations and guidance, and informed by industry best practices, regarding:
- Social distancing and protective equipment
- Temperature checks
- Use and disinfection of common and high-traffic areas
- Business travel
Monitor workforce for indicative symptoms. Do not allow symptomatic people to physically return to work until cleared by a medical provider.
Develop and implement policies and procedures for workforce contact tracing following employee COVID+ test. Source 4.22.2020
Do you perform CDC recommended on-site temperature checks?
The CDC is recommending that all essential employers whose employees may have been exposed to COVID-19 be screened daily before entering the workplace.
In an effort to Increase Safety and Productivity and Reduce Liability™, Workplace Safety Screenings is offering onsite temperature checks for your employees.
- Deploy a healthcare professional to your site, in coordination with your shift hours, to take each employee’s temperature as they enter your facility.
- Provide written documentation per employee will be provided.
- Refer employees who present with elevated temperature to their primary care physician and the company contact will be notified.
Our medical personnel will have their own equipment and PPE. All we require is a separate space to perform testing.
What are the CDC recommendations for employers?
The recommendations from the CDC can be found here.
As of May 6, 2020, the CDC added the following recommendations:
- Updated strategies and recommendations for employers responding to COVID-19, including those seeking to resume normal or phased business operations:
- Conducting daily health checks
- Conducting a hazard assessment of the workplace
- Encouraging employees to wear cloth face coverings in the workplace, if appropriate
- Implementing policies and practices for social distancing in the workplace
- Improving the building ventilation system
- A table outlining the engineering controls, administrative controls, and personal protective equipment (PPE) that employers may use to help prevent the spread of COVID-19 in the workplace
What are the reporting requirements pertaining to COVID-19?
Under OSHA’s recordkeeping requirements, #COVID-19 is a recordable illness, and employers are responsible for recording cases of COVID-19, if: (1) the case is a confirmed case of COVID-19, as defined by Centers for Disease Control and Prevention (CDC); (2) the case is work-related as defined by 29 CFR § 1904.5; and (3) the case involves one or more of the general recording criteria set forth in 29 CFR § 1904.7. On March 11, the World Health Organization (WHO) declared COVID-19 a global pandemic, and the extent of transmission is a rapidly evolving issue.
Are there changes to the DOT drug and alcohol testing policy?
No. The DOT is continuing to test and to require all safety sensitive testing for all businesses and employees that fall under Rule 49 CFR Part 40. All 5 modes are continuing to test. Read their guidance statement here.
- Pre-employment & return to duty testing continues to be required. A negative drug test must be on file prior to working.
- Post-accident and reasonable suspicion testing must also continue; the alcohol and drug tests is to be as soon as possible. The testing should be completed within two hours, after eight hours only the drug test is required to be completed, and the drug test must be completed within 32 hours. If you are unable to complete the DOT testing, document why testing was not completed including your “reasonable effort”.
- Random Testing must be ‘spread reasonably throughout the calendar year’. WSS suggests reducing selections during emergency (DON’T tell anyone). Then pick-up the numbers in Q3 and Q4.
Specific guidance has also been released for the FMCSA. Read the guidance here.
What are the changes to the I-9 verification?
Physical presence and inspection is not required, but the documents must still be reviewed virtually. Don't forget, employers must begin using the new I-9 form, released Oct. 2019, no later than May 1. For more, click here.
Are physicals still required?
- PFT’s have been suspended, respiratory questionnaire are being continued.
- Quantitative Fit tests can be completed if the worker brings their own filer cartridge and not shared common filters. We can complete Qualitative Fit testing.
What are the requirements on DOT FMCSA medical cards?
- Continue to be required for:
- If given 90 days to deal with a disqualifying medical condition
- Renewals are encouraged to be completed timely if a service provider is available (WSS), but will not be penalized until June 30, 2020.
More guidance from the DOT on COVID-19?
What should I do if I am symptomatic?
The CDC offers recommendations for individuals as well, and we'd recommend all employers post this in their office and share with all employees.
What should I do if I am asymptomatic?
In the updated guidance (as of April 17 per the NLR), the CDC states that the asymptomatic individuals with laboratory-confirmed COVID-19 may discontinue isolation or quarantine when at least seven days have passed since the date of their first positive COVID-19 diagnostic test, provided: (1) they have had no subsequent illness; and (2) they remain asymptomatic. While the CDC has not changed its general recommendations for social distancing and wearing masks or face coverings, the CDC recommends that asymptomatic individuals, for a period of 3 days following leaving home isolation per this guidance, stay 6 feet away from others and wear a cloth face covering (which in general and community settings need not be a medical/surgical mask or a respirator) whenever they are in the presence of others.
ON-SITE TESTING: FAQ
Are you still performing on-site testing?
Yes. Drug testing is considered an essential service, and we will continue to be available to our clients 24/7/365.
Do you do collection only?
Yes. WSS is partnered with many third-party administrators around the country.
How far do you travel for on-site collections?
We travel throughout Houston and its 12 surrounding counties. Wherever you are, we will come to you.
What are the benefits of on-site testing?
DOT regulations have nothing to do with the hiring or firing process. It is up to the discretion and company policy to determine if the employee needs to be removed. The employer’s responsibility is to immediately remove an employee from a safety sensitive operation. An employee may be subject to losing certain certifications or licenses needed to perform such jobs.
Are you doing post-COVID-19 Return to Duty testing?
Yes, as of April 16, 2020. However, please follow these safety guidelines to protect your employees and our on-site staff.
EXPOSED: Anyone who has been exposed by COVID-19 or suspects being exposed, are then mandated by the CDC to self-quarantine for two weeks; longer if they live with the person who has been exposed. Then it would be two weeks after the person has recovered, again mandated by the CDC.
ILLNESS: Prior to returning to work after an illness that includes COVID-19 Symptoms – especially fever – should have a return to duty release. At least 3 days (72 hours) have passed since recovery defined as resolution of fever without the use of fever-reducing medications and improvement in respiratory symptoms (e.g., cough, shortness of breath); and, at least 7 days have passed since symptoms first appeared.
Persons who have COVID-19 who have symptoms and were directed to care for themselves at home may discontinue home isolation under the following conditions:
Resolution of fever without the use of fever-reducing medications and
Improvement in respiratory symptoms (e.g., cough, shortness of breath) and
Negative results of an FDA Emergency Use Authorized molecular assay for COVID-19 from at least two consecutive nasopharyngeal swab specimens collected ≥24 hours apart** (total of two negative specimens).
Individuals with laboratory-confirmed COVID-19 who have not had any symptoms may discontinue home isolation when at least 7 days have passed since the date of their first positive COVID-19 diagnostic test and have had no subsequent illness.
WSS can do a return to duty check AFTER a person has recovered from an illness only if the worker did not test positive and has been without fever for 72+ hours without medication.
Are you testing asymptomatic drivers?
Yes, we are testing all asymptomatic individuals who need to return to work. This includes but is not limited to:
- Department of Transportation (DOT) physical exams and certification for all commercial driver’s license (CDL) holders
- Breath alcohol testing (BAT) and urine drug screening (UDS) collections for controlled substance testing, which is still required under FMCSA regulations for the following situations:
- Pre-employment testing
- Post-accident testing
- Reasonable suspicion
- Follow-up testing