Updated: August 21, 2020
In today’s Recommendations for Industry, we provide some best practices and advice in providing reasonable accommodations for workers who are – validly – unable to wear masks. Read more here.
To support human and animal food operations during the COVID-19 pandemic, the FDA & OSHA have come together to develop the Employee Health and Food Safety Checklist for Human and Animal Food Operations During the COVID-19 Pandemic [PDF]. This checklist allows businesses to assess their operations, including “re-starting operations after a shut down or when reassessing operation[al]” changes resulting from the health crisis. Although not an exhaustive list, “some or all of this checklist may be useful to persons growing, harvesting, packing, manufacturing, processing, or holding human and animal food regulated by FDA.” Use this list alongside CDC guidance to ensure you have the basics covered. Finally, this checklist provides a guide for non-US facilities or businesses who “manufacture, process, pack, or hold food for consumption in the United States”. The checklist can be downloaded here.
There may soon be a policy reversal for COVID-19 data reporting from the Department of Human and Health Services (HSS) back to the U.S. Centers for Disease Control and Prevention (CDC). This comes after July’s White House policy of shifting hospital reporting of COVID-19 from CDC to HSS resulted in backlogs, inconsistent data, and various errors. Dr. Deborah Brix discussed this update on Monday. When the change will occur is not yet known.
A recent CDC MMWR finds that “mass testing in 16 U.S. prisons and jails identified 12 times more cases of COVID-19 than when testing was offered based on symptoms alone”; in fact, there is up to an 86% prevalence in some jails. Read the report here.
If you or your employees are considering traveling abroad (or arriving from abroad) for business or personal reasons, you can see the current Travel History, Restrictions, and Opening Statuses of any country using an MIT-based application, called Covid Controls. Check it out!
An evaluation of household transmission for SARS-CoV-2 has found that “thirty-two (55%) of 58 households [studied] had evidence of secondary infection among household contacts.” Secondary infection rates were “29% overall, 42% among children <18 years old, and 33% among spouses and partners. Household contacts to COVID-19 patients with immunocompromised conditions had increased odds of infection. Household contacts who themselves had diabetes mellitus had increased odds of infection”. As household contacts are close-contacts, it can be concluded that there is, “substantial evidence of secondary infections among household contacts. People with COVID-19, particularly those with immunocompromising conditions or those with household contacts with diabetes, should take care to promptly self-isolate to prevent household transmission.” You can find the study here.
Recommendations for Industry
Reasonable Accommodations for Workers Unable to Wear Masks
Q. We have some workers with breathing difficulties, such as asthma, who have stated they are unable to wear masks. We know that the safest strategy is for all to wear a mask, but would you have any advice or industry best practices for providing accommodation for employees whose health conditions prohibit them from wearing one?
A. Although we have not seen any advice from the ADA on this, CDC provides a list of adaptations and alternatives to be considered to increase the feasibility of wearing a mask. But if these are still not applicable, TAG recommends the following which have been implemented by some food companies:
Before conceding to a request, companies with a mandatory mask policy should consider asking the individual to get a medical assessment, showing proof of the condition that prohibits the wearing of masks. While it may seem excessive in some cases, requesting validation from an independent health professional helps ensure that those who just don’t want to wear one won’t be able to exploit an accommodation without a valid medical reason.
For those with the validation, a face shield can be an option; but you will need to include a disclaimer that it’s not as effective as a face mask that covers the nose and mouth.
You can also consider changing the worker’s responsibilities to enable them to work in a more isolated environment that allows for further distancing from others. One large food company was able to retain all its workers by moving people off the line to different parts of the business – such as driving a forklift
For other options, TAG advises that you work with your HR team, legal team, union representative, and consult EEOC guidance, etc. to provide reasonable accommodations as set by the CDC Office of Equal Employment Opportunity (OEEO).
Also remember that masks are only one part of a multi-step process (see Risk Mitigation Hierarchy) to keep oneself and others safe.
As of August 19, 2020 (11:14 ET), there are over 22,726,000 cases (>794,000 deaths) worldwide.
Due to the increasing number of cases in the United States, TAG will move from reporting counts per country to focus on the United States, please see here for the data. For further information regarding worldwide numbers, please refer to John Hopkin University’s aggregate map.
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