OSHA: National Emphasis Program – Coronavirus Disease 2019 (COVID-19)

Mary Madison, RN, RAC-CT, CDP
Clinical Consultant – Briggs Healthcare

The National Emphasis Program is the latest OSHA initiative in response to the coronavirus pandemic.  The NEP is a new enforcement program, effective for the next 12 months unless canceled or extended by a superseding directive.  Note the effective date of March 12, 2021.

“This Direction describes policies and procedures for implementing a National Emphasis Program (NEP) to ensure that employees in high-hazard industries or work tasks are protected from the hazard of contracting SARS-CoV-2 (severe acute respiratory syndrome coronavirus 2), the cause of Coronavirus Disease 2019 (COVID-19). The NEP augments OSHA’s efforts addressing unprogrammed COVID-19-related activities, e.g., complaints, referrals, and severe incident reports, by adding a component to target specific high-hazard industries or activities where this hazard is prevalent. The NEP targets establishments that have workers with increased potential exposure to this hazard, and that puts the largest number of workers at serious risk. In addition, this NEP includes an added focus to ensure that workers are protected from retaliation, and are accomplishing this by preventing retaliation where possible, distributing anti-retaliation information during inspections, and outreach opportunities, as well as promptly referring allegations of retaliation to the Whistleblower Protection Program.”

The high-hazard industries are identified in the following tables found in Appendix A.  The Table of Contents follows those tables in this blog.

“The goal of this NEP is to significantly reduce or eliminate worker exposures to SARSCoV-2 by targeting industries and worksites where employees may have a high frequency of close contact exposures and therefore, controlling the health hazards associated with such exposures. This goal will be accomplished by a combination of inspection targeting, outreach to employers, and compliance assistance. In each Region, the goal of this NEP is to continue performing a high percentage of COVID-19 inspections (at least 5 percent) of the Region’s total assigned inspection goal (which is approximately 1,600 inspections OSHA-wide), focusing Agency resources on workplace exposures to SARS-CoV-2 in certain critical industries until further notice.

Unprogrammed COVID-19-related inspections will continue to be conducted at worksites where employees have a high frequency of close contact exposures. OSHA anticipates that the majority of the inspections will continue to occur in general industry, particularly in healthcare, based on current OSHA enforcement data showing higher COVID-19-related complaints, referrals and severe incident reports at healthcare worksites. To ensure abatement and to monitor the effectiveness of OSHA’s enforcement and guidance efforts, certain follow-up inspections from worksites previously inspected for COVID-19-related hazards will be included as part of the targeting strategy.”  [Bolding added by me.]

Please be aware that Assisted Living facilities, Skilled Nursing facilities and Continuing Care Retirement Communities are among the OSHA targets.

The OSHA NEP directive should be reviewed by all owners, managers, administrators and their teams.  An OSHA team could well be entering your facility so be prepared.