Circa 2015
Many employers now check employees’ temperatures upon arrival for work to identify workers potentially infected with the SARS-CoV-2 virus that causes COVID-19. Some employers even ask employees to fill out questionnaires on how they’re feeling. A guidance from OSHA and CDC pointed out that such documentation would be a “medical record” that must be retained according to 1910.1020.
Specifically, the OSHA/CDC joint guidance for meatpacking plants discussed options such as taking temperatures and performing other screening, with tips on how to perform these tasks safely. Then, a footnote to that section stated:
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.
While OSHA and CDC recommend screening workers, an employer may want to avoid documenting temperature readings and use verbal rather than written questionnaires.
Screening workers is an optional strategy. If implemented, policies and procedures should be developed in consultation with state and local health officials and occupational medicine professionals. Options to screen workers for COVID-19 symptoms include:
If a worker does not meet the screening criteria, encourage him or her to self-isolate and to contact a healthcare provider. Provide the worker with information on your return-to-work policies and procedures. Then, inform human resources, the employer health unit (if any), and the worker’s supervisor so workload adjustments can be made.
Those performing screening should be protected from exposure to potentially infectious workers entering the facility. This may include:
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