The Governor of Michigan has begun releasing geographic areas of the state to resume “normal” operations.  This Executive Order, 2020-114 can be found HERE along with all other official Executive Orders.  There are a lot of steps and requirements for those companies resuming operations.  Note that, employers MUST create a written control response plan before reopening. Below is a guide to assist you in creating your written control response plan. If you need assistance, please reach out to HRPro’s HR Consulting department at 248-543-2644 or email newbiz@hrpro.com.

Opening for Business:

As the curve flattens and and businesses begin to open their doors, the Michigan Occupational Safety and Health Administration (MIOSHA) within the Dept. of Labor and Economic Opportunity (LEO) issued workplace guidelines that include several helpful resources and mandated requirements for reopening. MIOSHA is also providing further clarification for employers in the construction and manufacturing sectors to protect those employees returning to work.

COVID-19 Workplace Guidelines:

Employer’s Guide.
Employee’s Guide
Manufacturing Industry
Construction Industry

COVID-19 Workplace Guidelines YouTube Walkthrough Videos

Employer Guide Video Walkthrough
Employee Guide Video Walkthrough

MIOSHA has also created a new hotline, 855-SAFEC19 (855-723-3219) to answer guideline questions and further protect Michigan’s workforce from the spread of COVID-19. The new toll-free number will provide additional support, utilizing experienced MIOSHA staff, to best answer questions from employers and workers to quickly respond to inquiries related to COVID for all involved. Employers and employees with questions regarding workplace safety and health may contact MIOSHA using the new hotline.

MIOSHA has also published enforcement guidance considerations, specifically related to COVID-19. Relevant MIOSHA Standards include:

• Personal Protective Equipment Part 33 (OSHA 1910 Subpart I)
• Hazard Communication Part 430 (OSHA 1910.1200)
• Respiratory Protection Part 451 (OSHA 1910.134)
• Recordkeeping Part 11 (29 CFR 1904)
• Sanitation Part 474 (OSHA 1910.141)
• General Duty MIOSHA Act 154 Section 11(a) (OSHAct Sec 5(a)(1))

Action Items:

On a scale from low to very high, exposure determination is the leading factor to the level of precaution an employer should take to protect their employees and can vary within the same facility.

Develop and Implement an Exposure Control Plan which includes exposure determination and outlines measures that will be taken to prevent employee exposure to COVID-19.

Using the COVID-19 Workplace Guidelines, the Employer’s Guide for Workplace Health and Safety, follow the steps below to create the required exposure control plan:

1. Determine level of Exposure (refer to slides 10-11)
2. Detail measures to prevent employee exposure, including any:
   Engineering controls (refer to slide 14)
   Administrative controls (refer to slide 15)
   Hand hygiene and environmental surface disinfection (refer to slides 20-21, 25-26)
   Personal protective equipment (refer to slide 16)
   Health surveillance (refer to slides 24, 27-28)
   Training (refer to slides 28-32)
3. Use current CDC guidance and OSHA’s Infectious Disease Preparedness and Response Plan
4. Employer shall use preventive measures in line with the exposure risk category

A key component to prevent the spread of COVID-19 is the ability for employers to provide adequate training on potential risk to their employees. Under these guidelines, MIOSHA encourages training that includes steps the employee must take to notify the employer of signs and symptoms of COVID-19 and reporting suspected or confirmed diagnosis of COVID-19. Employers are to provide updated training to employees if changes are made to its exposure control plan or new information becomes available about the transmission of COVID-19.  Refer to the Employee Guidance from the State as a sample for training materials.

Additional Resources:

The State of Michigan’s Workplace Safety Guidelines can be found on the Labor and Opportunity (LEO) homepage.

To report health and safety concerns in the workplace visit the MIOSHA complaint page.

To learn more about MIOSHA and their efforts to protect Michigan’s workforce, visit their page.

Information regarding this outbreak is constantly changing. Refer to the official Michigan Coronavirus page and the CDC’s Coronavirus page.

Downloads to use for reference or modify for your own use:
SHRM Return to Work Guide
Workshop Guide for Reconstituting Operations
Infectious Disease Policy

If you need assistance putting together your organization’s Exposure Control Plan reach out to HRPro’s HR Consulting department at 248-543-2644 or email us.