Worker infection prevention recommendations are based on an approach known as the hierarchy of controls. This approach groups actions by their effectiveness in reducing or removing hazards. In most cases, the preferred approach is for management to:
- Eliminate a hazard or processes (e.g., screen and monitor workers and exclude sick workers from the workplace).
- Install engineering controls (e.g., modify workstations, use physical barriers and ventilation).
- Establish and ensure employees follow administrative controls, including implementing appropriate cleaning, sanitation, and disinfection practices, and safe work practices that reduce exposure or shield workers.
- Use personal protective equipment (PPE), in accordance with the employer’s hazard assessment, to protect workers from hazards not controlled by engineering and administrative controls alone.
Onshore and offshore worksites, particularly in areas where community transmission of SARS-CoV-2 is occurring, should consider developing and implementing a comprehensive strategy aimed at preventing the introduction of COVID-19 into the worksite.
Strategies for preventing the introduction of COVID-19 into the worksite include screening for fever, symptoms of and exposure to COVID-19; staying at home and self-monitoring for symptoms for 14 days prior to initial entry to the worksite; testing for SARS-CoV-2, as described in more detail below; and cooperating with federal and SLTT health authorities to facilitate contact tracing if exposures or infections warrant such.
Quarantine before entry to the worksite:
Employers operating offshore worksites (e.g., vessels), in particular, should consider having workers quarantine and self-monitor for symptoms for 14 days prior to initial entry (i.e., boarding a vessel) as a strategy to prevent SARS-CoV-2 transmission onboard the vessel. To ensure adherence, employers should consider providing paid leave during the period of quarantine or should consider the quarantine time as worktime. Note that employers with fewer than 500 employees are eligible for 100% tax creditsexternal icon for Families First Coronavirus Response Act COVID-19 paid leave provided through December 31, 2020, up to certain limits. Offshore workers are in close proximity to one another continuously while working and off duty but otherwise may be isolated from outside exposures to SARS-CoV-2. Onshore worksites may experience similar situations when seasonal workers live in congregate housing, especially in remote and rural areas where they do not have contact with individuals outside of their own cohort. Follow SLTT guidance on quarantine and testing procedures.
Testing of workers:
Testing after a COVID-19 case is identified
CDC’s “Testing Strategy for Coronavirus (COVID-19) in High-Density Critical Infrastructure Workplaces after a COVID-19 Case is Identified” presents options for testing exposed coworkers for use when public health organizations and employers determine testing is needed to help support existing disease control measures. Note that CDC advises that critical infrastructure workers may be permitted to continue workpdf icon at their regular duties following potential exposure to COVID-19, provided they remain asymptomatic and additional precautions are implemented to protect themselves, their coworkers, and the community, including continued screening for symptoms. However, if tested, their results must be negative for them to continue working. (See CDC’s Interim Guidance for Implementing Safety Practices for Critical Infrastructure Workers Who May Have Had Exposure to a Person with Suspected or Confirmed COVID-19pdf icon.)
A risk-based approach to testing co-workers of a person with confirmed COVID-19 may be applied. Such an approach should take into consideration the likelihood of exposure, which is affected by the characteristics of the workplace and the results of contact investigations. One approach to testing is to establish a priority for testing (for example, CDC’s tiered approach) based on an assessment of risk in the workplace and other factors such as high rates of COVID-19 transmission in the surrounding community or workers’ households. The highest priority would be for testing of co-workers who were exposed to a worker with confirmed COVID-19, beginning 2 days before the individual with COVID-19 became symptomatic (or, for asymptomatic workers, 2 days prior to specimen collection) until the time of isolation. Other co-workers could be tested based on an assessment of risk in the workplace, such as the layout and size of the room, the design and implementation of engineering controls, adherence to administrative controls2, and movement of workers within the area. Other strategies could involve testing all co-workers if a worker tests positive for COVID-19 or testing all co-workers upon identification of an individual with symptoms consistent with COVID-19. Testing can also be used in assessing whether workers who have been quarantined due to COVID-19 can return to work.
Testing asymptomatic workers without SARS-CoV-2 exposure
A strategy aimed at reducing introduction of SARS-CoV-2 into the work setting through early identification could reduce the risk of widespread transmission. CDC has recommended guidelines for testing for asymptomatic individuals without known or suspected SARS-CoV-2 exposure for early identification in special settings. This guidance can be found here. High-density critical infrastructure workplaces, such as seafood processing vessels and facilities where continuity of operations is a high priority, are settings for which these approaches could be considered.
Employers are encouraged to work with SLTT health departments to help inform decision-making about broad-based testing. Before testing large numbers of asymptomatic individuals without known or suspected exposure, the facility should have a plan in place for how it will modify operations based on test results.
Employers planning to incorporate testing into their COVID-19 prevention efforts should ensure the worksite has a testing plan in place based on contingencies informed by the Centers for Disease Control and Prevention (CDC).
At minimum, the plan should consider the following components:
- The priorities for testing of workers, such as the tiered approach described above.
- The capacity for workers to receive a single baseline COVID-19 test and receive the results before entering the worksite. Similarly, the capacity for all workers to be tested upon identification of an individual with symptoms consistent with COVID-19, or if a worker tests positive for COVID-19. Capacity for continuance of re-testing, as needed, based on the situation.
- An arrangement with laboratories to process tests. The test used should be able to detect SARS-CoV-2 virus (e.g., polymerase chain reaction (PCR)) with greater than 95% sensitivity, greater than 90% specificity, with results obtained rapidly (e.g., within 48 hours). Antibody test results should not be to the sole basis for diagnosing someone with an active SARS-CoV-2 infection.
- A procedure for addressing workers that decline or are unable to be tested (e.g., symptomatic worker refusing testing in a worksite with positive COVID-19 cases should be treated as positive).
- Testing of new entrants into the workplace and/or those re-entering after a prolonged absence (e.g., one or more days).
Adaptations to other guidance after quarantine and testing:
In worksites in which both quarantine and testing strategies have been implemented, and workers have no contact with individuals outside of their own cohort (e.g., a vessel crew, an isolated population of workers in congregate housing in remote/rural areas with no contact with the community), employers may be able to relax some engineering and administrative control measures, if those measures are otherwise infeasible in the work environment. For example, onboard vessels it may not be feasible to rearrange workstations or modify sleeping quarters. If new members are introduced to a cohort of workers, such as the exchange of a crewmember onboard a vessel, then it may not be appropriate to continue with relaxed infection prevention strategies, unless that new member has also been quarantined and tested as described above.
Consider a program of screening3 workers before they enter the worksite, excluding sick workers from the worksite, and using criteria to ensure safety when workers return to work. This type of program, described in more detail below, should be coordinated to the extent possible with local public health authorities and could consist of the activities described below.
Screening workers for COVID-19
Screening seafood processing workers for COVID-19 signs and symptoms (such as temperature checks) is an optional strategy that employers may use. If implemented for all workers, policies and procedures for screening workers should be developed in consultation with SLTT health officials and occupational medicine professionals.
Options to screen workers for COVID-19 symptoms include:
- Screen them before they enter the worksite or board the processing vessel.
- Provide verbal screening in appropriate languages to determine whether workers have had a fever, respiratory symptoms, or other symptoms 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, as described in the next section.
- Do not let employees enter the worksite if they have a fever of 100.4°F or greater (or reported feelings of feverishness), or if screening results indicate that they are suspected of having COVID-19.
- Encourage sick workers to self-isolate and contact a healthcare provider.
- Provide information on the worksite’s return-to-work policies and procedures to sick workers.
- Inform human resources, employer health unit (if in place), and supervisor about sick workers (so workers can be moved off schedule during illness and replacements can be assigned, if needed).
For both onshore and offshore employees, ensure that personnel performing screening activities, including temperature checks, are appropriately protected from exposure to potentially infectious workers entering the worksite:
- Implement engineering controls, such as physical barriers or dividers or rope and stanchion systems, to maintain at least six feet of distance between screeners and workers being screened.
- If screeners need to be within six 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 (see below) 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 1910.134external icon).
Managing sick workers
When onshore workers report or have symptoms (e.g., fever, cough, or shortness of breath) upon arrival at work or who become sick during the day, immediately separate them from others at the worksite and send them home.
When offshore workers report or have symptoms, immediately separate them from others on the vessel. Vessel medical staff, management, and telemedicine providers should discuss the disembarkation of patients suspected or known to have COVID-19 with applicable federal, SLTT, and port authorities to ensure the safe disembarkation and medical transportation of the patient.
If workers dwell in employer-provided housing or shared living quarters, it may not be possible to safely send them home to isolate and recuperate. In such instances, develop isolation plans for workers who are suspected of having COVID-19 or who are COVID-19-positive to recuperate without infecting others (i.e., designate a private sleeping space):
- In shared living quarters, consider establishing areas for sleep/rest that accommodate single occupancy during the pandemic and a separate bathroom (if available).
- Direct vessels to plan for medical evaluation of potentially sick workers. Vessel medical staff, management, and telemedicine providers should discuss the disembarkation of patients suspected or known to have COVID-19 with applicable federal, SLTT, and port authorities to ensure the safe disembarkation and medical transportation of the patient.
- Ensure that vessels carry a sufficient quantity of PPE and medical supplies to meet demands while at sea.
- See the section below on special considerations for shared living spaces.
Ensure that personnel managing sick employees are appropriately protected from exposure. When personnel need to be within six feet of a sick colleague, appropriate PPE may include gloves, a gown, a face shield and, at a minimum, a face mask. N95 filtering facepiece respirators (or more protective) are necessary for workers managing a sick employee 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 1910.134external icon).
If a worker is confirmed to have COVID-19, inform anyone they have come into contact with (including fellow workers, inspectors, graders, etc.) of their possible exposure to COVID-19 in the workplace, but maintain the sick employee’s confidentiality as required by the Americans with Disabilities Act (ADA)external icon. Instruct fellow workers about how to proceed based on the CDC Public Health Recommendations for Community-Related Exposure.
If a worker becomes or reports being sick, disinfect the workstation used and any tools or equipment handled by that worker.
Work with SLTT health officials to facilitate the identification of other exposed and potentially exposed individuals, such as coworkers in a facility.
On-site healthcare personnel, such as worksite nurses or emergency medical technicians, should follow appropriate CDC and OSHA guidance for healthcare and emergency response personnel.
Addressing return to work
- Critical infrastructure employers have an obligation to manage the continuation of operations and workers’ return to work in ways that best protect the health of workers, their coworkers, and the general public.
- Consider providing screening and ongoing medical monitoring of workers, ensuring they wear an appropriate source control device (e.g., cloth face coveringsexternal icon) in accordance with CDC and OSHA guidance and any SLTT requirements, and implementing social distancing to minimize the chances of workers exposing one another.
- Continue to minimize the number of workers present at worksites, balancing the need to protect workers with support for continuing critical operations.
For workers who have not had symptoms of COVID-19
- When reintegrating (bringing back) exposed workers with no COVID-19 symptoms to onsite operations, follow the CDC Critical Infrastructure Guidance. Workers who have been exposed to COVID-19 but remain without symptoms, may continue to work, provided they adhere to additional safety precautions. Consult with an occupational health provider and SLTT health officials for help developing the most appropriate plan.
- When reintegrating workers with confirmed COVID-19, including those workers who have remained symptom-free, to onsite operations, follow the CDC interim guidance, “Discontinuation of Isolation for Persons with COVID-19 Not in Healthcare Settings.” As noted above, consult with an occupational health provider and SLTT health officials for help developing the most appropriate plan.
For workers who have had symptoms of COVID-19
- Workers with COVID-19 who have symptoms and have stayed home (home isolated) should not return to work until they have met the criteria to discontinue home isolation and have consulted with their healthcare providers and SLTT health departments.
As you move forward with continuing essential work, implement strategies to prioritize positions without which critical work would stop. Include an analysis of work tasks, workforce availability at specific worksites, and assessment of hazards associated with the tasks and worksite. You may be able to cross-train workers to perform critical duties at a worksite to minimize the total number of workers needed to continue operations.
The situation is constantly changing, so employers of critical infrastructure workers will need to continue to reassess the virus’s transmission levels in their area and ports and follow recommendations from SLTT and federal officials. This guidance does not replace SLTT directives for businesses.
Configure communal work environments so that workers are spaced at least six feet apart, if possible. Current information about the spread of SARS-CoV-2 by people who are infected but have no symptoms supports the need for social distancing and other protective measures within a seafood processing work environment. Changes in production practices may be necessary to maintain appropriate distances among workers.
Modify the alignment or arrangement of workstations, including along processing lines in factories and conveyors used for loading and offloading goods (e.g., raw fish, packaged or frozen seafood), if feasible, so that workers are at least six feet apart in all directions (e.g., side-to-side and when facing one another), when possible. Ideally, modify the alignment of workstations so that workers do not face one another. Consider using markings and signs to remind workers to maintain their location at their station away from each other and practice social distancing on breaks.
Use physical barriers, such as strip curtains, plexiglass or similar materials, or other impermeable dividers or partitions, to separate seafood processing workers from each other, if feasible.
Worksites should consider consulting with a heating, ventilation, and air conditioning engineer to ensure adequate ventilation in work areas to help minimize workers’ potential exposures.
If fans, such as pedestal fans or hard-mounted fans, are used in the worksite, take steps to minimize air from fans blowing from one worker directly at another worker. Personal cooling fans should be removed from the workplace to reduce the potential spread of any airborne or aerosolized viruses. If fans are removed, employers should remain aware of, and take steps to prevent, heat hazardsexternal icon.
Evaluate the need for additional handwashing and hand sanitizing locations that are easily accessible to workers to reduce congestion during shift changes. Determine where handwashing and hand sanitization stations are needed; and consult OSHA’s Sanitation standard (29 CFR 1910.141external icon) and/or FDA’s good manufacturing practices (GMPs)external icon for food processing operations. If possible, choose hand sanitizer stations that are touch-free.
Add additional clock in/out stations, if possible, that are spaced apart, to reduce crowding in these areas. Consider alternatives such as touch-free methods or staggering times for workers to clock in/out.
Remove or rearrange chairs and tables, or add partitions to tables, in break rooms and other areas workers may frequent to increase worker separation. Identify alternative areas to accommodate overflow volume such as training and conference rooms, or using outside tents for break and lunch areas.
Employers should take the following steps to promote social distancing among workers:
Employers may determine that modifying workstations, including processing or production lines, and staggering workers across shifts would help to maintain overall seafood processing capacity while measures to minimize exposure to SARS-CoV-2 are in place. For example, a factory that normally operates on one daytime shift may be able to split workers into more than one shift throughout a 24-hour period. In some seafood processing operations, one shift may need to be reserved for cleaning and sanitizing. Workers and managers should also take steps to manage workplace fatigue.
Monitor and respond to absenteeism at the workplace. Implement plans to continue essential business functions in cases of higher than usual absenteeism.
Review leave policies and incentives:
- Review sick leave policies and consider modifying them to make sure that ill workers are not in the workplace. Make sure that employees are aware of and understand these policies.
- Analyze any incentive programs and consider modifying them, if warranted, so that employees are not penalized for taking sick leave if they have COVID-19.
- Additional flexibilities might include giving advances on future sick leave and allowing employees to donate sick leave to each other.
Consider cohorting (grouping together) workers. This can increase the effectiveness of altering the factory’s normal shift schedules by making sure that groups of workers are always assigned to the same shifts with the same coworkers. Cohorting may reduce the spread of infection in the workplace by minimizing the number of different individuals who come into close contact with each other over the course of a week. Cohorting may also reduce the number of workers quarantined because of exposure to the virus. Consider extending cohorting to transportation and communal housing where possible.
Establish a system for employees to alert their supervisors if they are experiencing symptoms of COVID-19 or if they have had recent close contact with a person who has suspected or confirmed COVID-19.
Evaluate existing handwashing/hand sanitizing requirements and practices.
Employers may need to implement a multi-step hand sanitizing procedure to ensure effectiveness against SARS-CoV-2 and conformity with GMPs. Washing hands with soap and running water for at least 20 seconds can help prevent the spread of SARS-CoV-2. However, GMPs in food processing may necessitate use of dip stations with 100-200 ppm chlorine or 12.5-25 ppm iodine to control pathogens associated with foodborne illness. Consult with the dip solution manufacturer and EPA guidanceexternal icon to determine whether the dip stations used in a particular facility are also effective against SARS-CoV-2. If alcohol-based hand sanitizer is made available for use in areas where it is allowed under GMPs and to supplement hand washing, it should contain at least 60% alcohol to be effective against SARS-CoV-2.
Food processing employers should consider developing written policies about which employees can use hand sanitizer, in what areas or parts of a processing worksite it can be used, and other considerations pertinent to the food processing environment. Hand sanitizers are not intended to replace handwashing in food production and retailexternal icon settings. Instead, hand sanitizers may be used in addition to or in combination with proper handwashing.
- Consider posting additional visual cues reminding employees of the importance of hand hygiene. Monitor the implementation of these requirements.
- Ensure workers have access to and frequently use appropriate hand hygiene facilities. Give employees enough time to wash and dry their hands, and provide accessible sinks, soap, water, and a way to dry their hands (e.g., paper towels, hand dryer). See OSHA’s Sanitation standard (29 CFR 1910.141external icon).
- Place hand sanitizers and/or drip stations in multiple locations, as appropriate, to encourage hand hygiene.
- See additional discussion of hand sanitizers in the Engineering Controls section, above.
Consider other workplace programs to promote personal hygiene, such as:
- Building additional staggered, short breaks into staff schedules to increase how often staff can wash their hands with soap and water;
- Providing tissues and no-touch trash receptacles for workers to use and ensuring workers adhere to GMPs for handwashing after blowing their noses, wiping their faces, etc.;
- Educating workers to avoid touching their faces, including their eyes, noses, and mouths, particularly until after they have thoroughly washed their hands; and
- Educating workers to wash and sanitize (i.e., in dip stations, as required) their hands upon completing work and/or removing PPE, after removing face coverings, and before and after eating, smoking, or touching their face.