JSAs and Risk Management: Tips During the COVID-19 Pandemic

The global COVID-19 pandemic is creating serious challenges for employers, not simply because of the health risks of the disease itself to workers, but also because of the social distancing and workplace changes implemented to help slow the spread of the virus. Anxiety and urgency of response related to the COVID-19 threat is understandable, but can easily cause us to lose focus when it comes to workplace risk management — further compounding threats to our workforce.

Let’s discuss a couple of the key areas we should be focused on in order to best protect our employees during this unprecedented time.

Managing Exposure Risks to SARS CoV-2

As of this writing, more than 440,000 confirmed COVID-19 cases are known worldwide, with nearly 20,000 reported fatalities. In response, many employers are implementing work-from-home policies while others have shuttered operations entirely in an effort to limit the spread of coronavirus and COVID-19. Some governments, including Italy and a growing number of US states and cities, have removed choice from the equation and instituted mandatory lockdowns, keeping most citizens out of their normal workplaces.

However, even under a lockdown, workplaces considered to be “essential” remain open. For example, the lockdown order that went into effect for the state of Illinois on March 21^st leaves healthcare facilities, pharmacies, gas stations, banks and financial institutions, hotels, and a number of other business sectors in operation. Businesses that remain open are not only facing increased demand for their services, but also need to take extraordinary precautions to protect their workers from exposure to COVID-19.

OSHA has issued Guidance on Preparing Workplaces for COVID-19, with information for these businesses on how to minimize workplace exposure to the SARS CoV-2 virus and prevent COVID-19. We’ve already discussed some of OSHA’s basic prevention strategies in a previous blog post, but here, we’ll focus on more specific guidance for managing workplace exposure risks.

OSHA advises that employers should classify the exposure risks of their workers based on factors such as their industry type and the proximity of workers to known or potential SARS CoV-2 carriers, especially if there is a need for extended or repeated contact. Employers should then use this evaluation to categorize exposures in the workplace based on the figure below:

The guidance document defines these levels as follows:

Very high exposure risk: jobs with high potential for exposure to known or suspected sources of COVID-19 during specific medical, postmortem, or laboratory procedures. Workers in this category include healthcare workers performing aerosol-generating procedures (e.g., intubation, cough induction procedures, bronchoscopies, some dental procedures and exams, or invasive specimen collection) on known or suspected COVID-19 patients, laboratory workers collecting and handling specimens from known/suspected infected individuals, and morgue workers performing autopsies on individuals known/suspected of having COVID-19.

High exposure risk: jobs with high potential for exposure to known or suspected sources of COVID-19. Workers in this category include healthcare delivery and support staff (e.g., doctors, nurses, and other hospital staff who must enter patients’ rooms) exposed to known or suspected COVID-19 patients, medical transport workers (e.g., ambulance vehicle operators) moving known or suspected COVID-19 patients in enclosed vehicles, and mortuary workers involved in preparing (e.g., for burial or cremation) the bodies of people who are known or suspected to have had COVID-19 at the time of their death.

Medium exposure risk: jobs that require frequent and/or close contact with (i.e., within 6 feet of) people who may be infected with SARS-CoV-2, but who are not known or suspected COVID-19 patients. These jobs include workers  in areas without ongoing community transmission who may have frequent contact with travelers who may return from international locations with widespread COVID-19 transmission.

Lower exposure risk (caution): jobs that do not require contact with people known to be, or suspected of being, infected with SARS-CoV-2 nor frequent close contact with (i.e., within 6 feet of) the general public. Workers in this category have minimal occupational contact with the public and other coworkers.

The job examples provided above are not exhaustive, and employers should use them as a general guideline for assessing exposure levels based on the existence of tasks similar those described above. Based on this assessment, employers can then develop job safety analyses (JSAs) for the jobs, and determine appropriate controls to reduce exposure as detailed in the rest of OSHA’s guidance document.

Risk analysis techniques such as job safety analysis (JSA) and Bowtie Analysis are ideal for identifying and evaluating the risk of exposure when performing work tasks and other activities. Bowtie Analysis even provides a graphical framework for documenting and communicating exposure risks to help better understand their root causes, anticipate and quantify potential exposure impacts, then develop and assign more targeted exposure controls.

Risks From a Reduced Workforce

Risks have always existed in the workplace. Hopefully, most employers have developed JSAs and other risk assessments to identify and control those risks, and have trained their workers on the contents and findings of their assessments.

But there’s a new challenge now, due to changes in the workforce to help slow the transmission rate of the disease. Here are several possible ways we may be feeling the effects of these efforts, and some of the facets we should keep front of mind:

• There may be fewer workers available to perform certain job tasks. That may, in some cases, necessitate a change to the way the task is performed. This will likely trigger the need to update the corresponding JSA, perhaps updating or adding some of the risk control measures along the way. Don’t forget that updating the JSA means we should also be retraining our workers on the new assessments and controls.
• Workers who don’t usually perform job tasks may find themselves newly responsible for doing them, especially when workers who normally perform those tasks are unavailable. How will we ensure they’re fully prepared? We need begin by making sure our JSAs are up to date and readily available, and that workers are trained on them. We also need to remember that workers who’ve never performed tasks before might require additional training and attention.
• With workers more spread out due to social distancing measures, we may encounter even more difficulty than usual when accessing important EHS information including JSAs or details about corrective actions related to workplace risks. This is especially true if you’re relying on paper-based or outdated software systems that create unnecessary barriers to communication. It’s precisely because of this increased separation of workers that we need to eliminate these barriers to access. Employers should ask themselves, “Is our current system able to supply the necessary information as quickly as we need it?”

In short, be sure to keep your JSAs and other risk assessments up to date in light of recent procedural changes, make sure your workers are trained, and give them rapid access to the information they need to work safely.

Modern risk management software can help you quickly and easily perform detailed risk analysis, and keep your entire workforce up to speed with changes to your workplace as they happen.

Let VelocityEHS Help!

VelocityEHS aims to be as supportive as possible to EHS professionals like you during the COVID-19 outbreak. Our Risk Management solution gives you the tools to help keep your workforce safe, and better informed about workplace risks, and our new COVID-19 site is a free resource to help you get the most important information related to the pandemic in one place, including an SDS e-binder for disinfectants recognized by EPA as effective against SARS CoV-2.

As always, please feel free to contact us. We wish you safety and peace during this difficult time.