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According to the CDC, COVID-19 vaccines are safe and effective. Some individuals may experience side effects, but they are typically short lived. For the most part, the benefits of the vaccine far outweigh the short lived side effects. With more Americans receiving the vaccines every day it is important to start planning for the post vaccine era. These guidelines are intended to help you do just that, but it is likely that they will change several times over the coming months, so please continuously watch for updates from MCAA.   

What We Do NOT Know About the Vaccines

There is still much that we do not know about the vaccines, so even fully vaccinated individuals need to follow COVID-19 safety protocol while working just about anywhere. Here is why:

• We do not know whether the vaccines keep vaccinated individuals from spreading the virus;
• We do not know how long the vaccine protects vaccinated individuals against the virus; and
• We do not know how effective the vaccines are against variants of the virus.

Fully Vaccinated Individuals

An individual is “fully vaccinated” when he or she has had both doses of the Pfizer or Moderna vaccines, or a single dose of the Johnson & Johnson vaccine, AND two full weeks have passed since the last injection.

Fully Vaccinated Individuals at Work

Fully vaccinated employees on jobsites, in fabrication shops, in office buildings and in other public areas performing regular duties that do not require specialized or additional personal protective equipment should:

• Wear a two-ply face covering that completely covers the nose and mouth;
• Practice proper hand hygiene by frequently washing hands and/or using hand sanitizers; and
• Maintain a social distance of at least 6 feet from all other individuals.

When social distancing requirements must be suspended, such as when two workers are needed for the safe manual handling of materials, the affected workers should continue to wear their face coverings, don face shields, wear work gloves, and limit the amount of time they will be working together closer than 6 feet to less than 15 minutes.

Employers

Affected employers should:

• Require all employees to comply with the protocol;
• Enforce employee compliance with the protocol; and
• Ensure that routine environmental cleaning is performed on affected surfaces at least once daily and more frequently when needed.

More frequent cleaning or disinfection should be performed if/when:

• There is a high transmission of COVID-19 in or around a workplace;
• The workplace is in an area where people are not wearing masks;
• The frequency and/or quality of hand hygiene is inadequate for any reason; and/or
• Individuals with increased risk of severe illness from COVID-19 are working in the area.

Fully Vaccinated Individuals Not Working

Once fully vaccinated, individuals outside the workplace can start to do some of the things that have not been acceptable since the pandemic began, such as:

• Visit inside a home or private setting without a mask with fully vaccinated people of any age;  
• Visit inside a home or private setting without a mask with one household of unvaccinated people who are not at risk for severe illness;
• Travel domestically without a pre-or post-travel test;
• Travel domestically without quarantining after travel;
• Travel internationally without a pre-travel test depending on the destination; and
• Travel internationally without quarantining after travel.

GUIDELINES PDF

MCAA and much of the construction industry will be participating in COVID-19 Vaccine Awareness Week in Construction during the week of April 19-23, 2021. MCAA encourages you to join us and participate! The purpose of the safety week is to support the CDC’s campaign to raise awareness about the safety, effectiveness, and benefits of receiving a COVID-19 vaccine. The CDC is providing an Essential Workers COVID-19 Vaccine Toolkit to help affected employers educate their workers about COVID-19 vaccines. The toolkit includes:

• A customizable letter you can send to your employees with information about vaccine awareness educational offerings;
• Content for company newsletters and social media sources;
• A PowerPoint presentation on COVID-19 vaccines; and
• Key messages for all affected workers.

MCAA encourages you take advantage of these materials. Setting aside a few minutes during the safety week to bring your workers up to speed on the vaccines could be very beneficial to your company. A few options to consider for delivering the information to your workers include:

• A COVID-19 vaccine awareness safety meeting;
• A short duration vaccine awareness safety talk each day throughout the week;
• A COVID-19 vaccine awareness safety Lunch & Learn; and/or
• Worker access to the Wednesday, April 21, 2021 vaccine awareness webinar, which will be presented by the CDC and NIOSH from 2:00 p.m. to 3:00 p.m. ET by way of NIOSH Zoom. REGISTER

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MCAA and much of the construction industry will be participating in COVID-19 Vaccine Awareness Week in Construction during the week of April 19-23, 2021. MCAA encourages you to join us and participate! The purpose of the safety week is to support the CDC’s campaign to raise awareness about the safety, effectiveness, and benefits of receiving a COVID-19 vaccine. The CDC is providing an Essential Workers COVID-19 Vaccine Toolkit to help affected employers educate their workers about COVID-19 vaccines. The toolkit includes:

• A customizable letter you can send to your employees with information about vaccine awareness educational offerings;
• Content for company newsletters and social media sources;
• A PowerPoint presentation on COVID-19 vaccines; and
• Key messages for all affected workers.

MCAA encourages you take advantage of these materials. Setting aside a few minutes during the safety week to bring your workers up to speed on the vaccines could be very beneficial to your company. A few options to consider for delivering the information to your workers include:

• A COVID-19 vaccine awareness safety meeting;
• A short duration vaccine awareness safety talk each day throughout the week;
• A COVID-19 vaccine awareness safety Lunch & Learn; and/or
• Worker access to the Wednesday, April 21, 2021 vaccine awareness webinar, which will be presented by the CDC and NIOSH from 2:00 p.m. to 3:00 p.m. ET by way of NIOSH Zoom.

MCAA will provide you with the webinar registration information as soon as it becomes available.

The new administration is putting a lot of pressure on OSHA to perform COVID-19 related inspections and enforce the agency’s guidance to prevent the spread of COVID-19 in the workplace. OSHA’s new Special Emphasis Program (SEP) on COVID-19 gives the agency the impetus it needs to do just that. Employers should prepare for the possibility of unprogrammed and programmed COVID-19 inspections.

Unprogrammed Inspections:

To start, make sure you know your rights as an employer, so that you will not unnecessarily provide OSHA with information that could result in a citation. Unprogrammed inspections typically result from the mandatory reporting of a fatality, an employee complaint, or a referral from another government agency. When an inspection is unprogrammed you can limit the scope of the compliance officer’s inspection to the reason for the unprogrammed inspection. For example, if an employee complains to OSHA that the portable toilets are not being regularly sanitized, and that complaint results in an unprogrammed inspection, you can limit OSHA to inspecting only those toilets and prevent the compliance officer from seeing other areas of the jobsite. However, compliance officers can issue citations for safety violations they identify while on the way to inspect the subjects of unprogrammed inspection, so choose the path and mode of transportation to that subject area wisely.  

• Compliance officers are required to hold pre-inspection conferences. Make sure the conference occurs. There have been cases where compliance officers have omitted this required step in the process;
• Make sure your company is represented at the conference by someone who knows what to ask and understands how to respond;   
• The instant the conference begins your company representative should ask the compliance officer for the reason for the inspection;
• If it is an unprogrammed inspection, limit the compliance officer to the area of the jobsite where the incident that resulted in the inspection occurred, i.e., where the fatality occurred, the specific area of the employee complaint, or the specific area stated in the referral; and  
• Never leave a compliance officer alone to wander the jobsite. Even though it is an unprogrammed inspection, if a compliance officer sees a violation, he or she can still issue a citation that is unrelated to the reason for the unprogrammed inspection.

Programmed Inspections:

Programmed inspections are randomly selected by OSHA from Dodge Reports. Get  prepared ahead of time in case your company is working on a project that comes up for a programmed COVID-19 inspection. To get prepared, consider what the compliance officers are most likely to look for during the inspection process, and what standards that they are most likely to cite.

Based on OSHA’s most recent COVID-19 compliance directive its compliance officers will be looking specifically for the following items during COVID-19 inspections:

• Evidence of retaliation against workers for actions related to the virus;
• Use of face coverings or masks throughout the workplace;
• Active encouragement of workers to stay home if they are sick;
• Proper social distancing and accommodating workers with telework where possible;
• Emphasis on proper respiratory etiquette;
• Emphasis on proper hand hygiene;
• Routine environmental cleaning; and
• Planning for possible infectious disease outbreaks in the workplace.

Since OSHA does not currently have a COVID-19 standard, the agency uses existing standards to enforce worker COVID-19 protection. When performing COVID-19 inspections the agency is most likely to issues citations from provisions in the following standards and its general duty clause.

Mechanical Service and Fabrication Shops:

• 29 CFR 1904 – Recording and Reporting Occupational Injuries and Illnesses;
• 29 CFR 1910.132 – General Requirements – Personal Protective Equipment;
• 29 CFR 1910.134 – Respiratory Protection;
• 29 CFR 1910.141 – Sanitation;
• 29 CFR 1910.145 – Specification for Accident Prevention Signs and Tags;
• 29 CFR 1910.1020 – Access to Employee Exposure and Medical Records;
• 29 CFR 1910.1030 – Bloodborne Pathogens; and
• Section 5(a)(1) – General Duty Clause – From the OSH Act of 1970.

Mechanical Construction:

• 29 CFR 1904 – Recording and Reporting Occupational Injuries and Illnesses;
• 29 CFR 1926.28 – General Requirements – Personal Protective Equipment;
• 29 CFR 1926.33 – Access to Employee Exposure and Medical Records;
• 29 CFR 1926.51 – Sanitation;
• 29 CFR 1926.103 – Respiratory Protection;
• 29 CFR 1926.200 – Accident Prevention Signs and Tags; and
• Section 5(a)(1) – General Duty Clause from the OSH Act of 1970.

If you have any questions or need any assistance protecting your workers from COVID-19 orpreparing your company for possible OSHA COVID-19 related enforcement, please contact Pete Chaney at pchaney@mcaa.org or 301-990-2214.