To Roofing Professionals,
As a service to the Roofing Industry, MRCA would like to provide you a suggested policy for construction companies to provide safeguards for your employees during the current coronavirus pandemic.
OSHA has advised businesses that it will be enforcing health and safety measures for employees to protect them from the coronavirus/COVID-19 under the OSHA General Duty Clause.in stating this, OSHA is indication that it has identified the coronavirus/COVID-19 as a recognized hazard that is causing or likely to cause death or serious physical harm to your employees. While some may disagree with me, I feel that this is an appropriate use to the general duty clause. But, neither OSHA or the CDC have established requirements for employers to take. Instead they have issued recommendations and/or guidance for employers.
While OSHA has not stated which of its recommendations you must adopt, you must take some action. We have added a few items that have not been spelled out by OSHA such as the use of crew cabs and ride sharing. Some of these areas have been addressed by individual states. For example, Nevada has issued a prohibition regarding ride sharing and crew cabs. While we have not included it in the attachment Nevada has also issued a guideline that employees shall maintain the six feet of social distancing when working in all elevated work platforms such a scissors lifts, aerial lifts, etc. This is a Nevada state requirement (each state may have its own rules) but may be also be contemplated in the OSHA guidance regarding social distancing.
The bottom line is that you DO NEED a policy. Your policy should contain whatever work rules you feel are technically feasible and are necessary to protect your employees and prevent the spread of the Coronavirus/COVID-19. You will be receiving a toolbox talk format in addition to the suggested company policy. While we feel that your policy contains all of these eleven requirements, what you decide to include is ultimately up to you. You MUST enforce whichever rules you chose to include in your policy. You MUST also train your employees in whatever policy you chose to construct for your company. You should pay close attention to all laws, rules and guidelines published for the state in which your business is located and in any state in which you do work. Your policy and rules should remain in effect until the national and state emergencies have been withdrawn or cancelled.
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A benefit of MRCA membership is the association’s Legal Services Plan available to assist you on questions related to COVID-19 and other safety and health or labor and employment law issues that you encounter in your business. Join MRCA to receive the full benefits of membership!
Stay Safe & Healthy MRCA Friends!