The association is pleased to offer the following recommendations for re-opening the country:
• ISEA believes OSHA should make clear for employers the various and appropriate sections of CDC's guidance documents that are appropriate to the reopening of the economy. Small employers do not likely have the time to pore through the numerous CDC guidance documents. In addition, OSHA should point how and where CDC guidance documents fall under OSHA regulations.
• OSHA should follow CDC recommendations on infection control for contract, droplet and airborne exposures. However, if the regulatory requirements for a Respiratory Protection Program are modified for employers in response to the outbreak, those modifications should be clearly communicated.
• OSHA and DOL should encourage employers to obtain PPE from trusted sources. OSHA and DOL should announce to employers the NIOSH site for International Respirator Assessment Request (https://www.cdc.gov/niosh/npptl/respirators/testing/NonNIOSH.html). Under this program, NIOSH will test the filtration efficiency of foreign respirators. This service allows for some level of validation of products before purchases are made.
• OHSA should reference CDC sources, and EPA's List N for guidance on cleaning and decontaminating PPE. This will assist employers as they seek to keep workplaces free from contact exposure to COVID.