Board Converting News, March 1, 2021


period to ensure compliance and instead compliance is mandatory immediately. COVID-19 Prevention Plans OSHA guidance strongly recommends the develop- ment and implementation of a written COVID-19 pre- vention plan, or the addition of a COVID-19 – epidemic/ pandemic section to existing injury and illness prevention programs (IIPP). Implementation of the following actions are advised with respect to your company’s written plan: • Communicate the company COVID-19 prevention poli- cies and procedures to employees. • Perform a Hazard Analysis Critical Control Points (HAC- CP) to identify, evaluate and correct COVID-19 hazards. • Provide physical distancing of at least six feet. • Mandate the use of face coverings. • To reduce transmission risk, practice hazard prevention and control using OSHA Hierarchy of Controls: First -

COVID-19 within two weeks. The EO also instructed the agency to consider establishing a COVID-19 emergency temporary standard (ETS) by March 15. OSHA issued stronger workplace guidance on Janu- ary 29. “Protecting Workers: Guidance on Mitigating and Preventing the Spread of COVID-19 in the Workplace” provides updated guidance and recommendations. The guidance is not a standard or regulation, but that may still come in the form of an ETS. Below is some information on ETS and COVID-19 prevention plans that could be helpful for box manufacturers. Emergency Temporary Standard - ETS Under certain limited conditions, OSHA is authorized to set emergency temporary standards that take effect im- mediately and are in effect until superseded by a perma- nent standard. Unlike regular rulemaking, there is no time

engineering solutions (including elimina- tion or substitution), followed by safe work practices, administrative controls, and fi- nally, PPE. • Document and implement procedures to investigate and respond to COVID-19 cases in the workplace. If any employees contract COVID-19, ensure that any cases that are determined not reportable are thoroughly documented. • Provide employees with COVID-19 train- ing that is customized per company pol- icies and considers their work situations. • Exclude COVID-19 cases and exposed employees from the workplace until they are no longer an infection risk. • Establish recordkeeping of COVID-19 cases and reporting of serious illnesses and multiple cases as locality dictates, such as Cal/OSHA and the local health department. Sample COVID-19 Prevention Plans The sites below are some sample COVID-19 prevention plans that you can cus- tomize for your company or plants. While these are good resources, we encourage you to craft your plan specifically to your plant/company. • Cal/OSHA model prevention plan • San Bernardino County COVID-19 Busi- ness Operation Plan Template • Michigan Department of Labor & Eco- nomic Opportunity (MIOSHA) COVID-19 Preparedness & Response Plan for Lower and Medium Exposure Risk Employers Mary Drain is the Director of Technical Ser- vices at Fibre Box Association (FBA). Reach her at


March 1, 2021

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