The pandemic is changing workplace behavior in many important ways; use of PPE is only one of them. We briefly discuss special considerations for construction workers and then focus upon respiratory protection under the silica construction standard in the context of COVID-19 response. The pandemic does not change requirements for PPE use but may impact the OSHA mandated exams and testing. Also, pandemic-related changes in workplace practices may distract workers from the need to take routine precautions.
Special considerations for construction workers:
- Work is often done in variable settings, where access to standard wash facilities is limited. Adequate opportunity to frequently wash should be provided.
- Large job sites often include many contractors, subcontractors, and individual craftspeople. For coordination of COVID-19 protections, a site coordinator should be designated.
- Employers and construction unions share common goals and need to work together.
- Worker training must be provided in a language understood by the workers.
- Construction workers may be reticent to stay home from work if they have been exposed or feel ill. A non punitive approach, ideally including paid leave, to workers reporting COVID-19 exposure, diagnosis, or symptoms will help to encourage appropriate social distancing.
- Tools are often shared. Make changes in work practices to allow for cleaning between users.
- Areas used for lunch and rest breaks, whether designated or ad hoc, must enforce social distancing so that workers remain over 6 feet apart.
- Commuting and onsite ridesharing should be reduced where possible, and vehicle cleaning is needed between uses.
OSHA provides specific non-binding guidance for the construction industry3. In addition, useful resources are provided by CPWR-Center for Construction Research and Training, American Road and Transportation Builders Association, Laborers’ Health & Safety Fund of North America, and a tool vendor 4,5,6,7,8,9.
Continue to provide required PPE:
The pandemic has not reduced the hazards presented by crystalline silica exposures, nor does it change the protections required by OSHA1. The silica standard can be found here. A small entity compliance guide for the construction industry can be found here. Respirators that meet the OSHA standards to protect workers from silica exposure would also be expected to protect them from COVID-19.
Scheduling Exams and Fit Testing:
The pandemic may create difficulties for some employers in scheduling employee respirator evaluations. OSHA recognizes that mandatory periodic surveillance testing may be delayed if necessary10. They require “good faith” efforts, and therefore employers and OH clinicians should carefully document the basis for any temporary deferrals. While periodic surveillance testing may be reasonably delayed, workers who have experienced facial changes impacting the respirator seal, and those using new PPE, should still be fit tested. Workers new to a respiratory protection program should also be fit-tested, and an examination should be performed if indicated by questionnaire responses. Spirometry, though part of the exam, should be deferred given infection control concerns during the pandemic.
Sanitation: Respirator users should wash or sanitize their hands immediately before and after donning or doffing the respirator. If immediate access to a sink is unavailable, hand sanitizer must be provided.
Use of cloth masks: Routine cloth mask use has been recommended for all workers in most workplaces to protect workers and should be worn whenever workers are not wearing respirators. Cloth masks should not be considered personal protective equipment and in no way substitute for OSHA certified respirators. Employers may need to identify alternative eye protection that can be used in combination with cloth masks to minimize fogging.
Exhalation valves: N95 or N99 respirators do afford partial protection for the wearer against respirable silica and also against viral aerosols and droplets. When equipped with exhalation valves, workers need to be aware that the valve releases unfiltered air which is NOT protective of OTHER persons nearby who are not wearing respirators.
Increased use of process/ engineering controls: Construction sites should adopt work practices such as wet methods and ventilation/ enclosure to reduce the need for respirators.
Availability: Due to inadequate supplies of N95 and other respirators for healthcare workers, employers and workers should consider use of elastomeric respirators. N95s should not be shared. If shared use of other types of respirators is absolutely necessary, cleaning and sanitizing protocols must be followed. Additional employee and supervisor training will be necessary.
In summary, construction workers should continue to receive protection as required, including respiratory PPE.