Some building owners or employers hire disinfection companies to perform COVID related disinfection services to provide the illusion that the building is "safe" to enter. Honestly, having COVID certified professionals clean and disinfect buildings seems like a good idea, although we are seeing untrained, unvetted technologies, uninsured contractors not utilizing protocols to apply chemicals that are ineffective and in many cases providing a false sense of security. Ultimately, this one-time cleaning and disinfection is nothing more than a psychological play to appease employees and/or the public to feel safe while inside that building.
•COVID Training and Certification - Most contractors do not have any form COVID training as required by OSHA and in some cases insurance carriers. According to Federal OSHA Employers must "train all workers with reasonably anticipated occupational exposure to SARS-CoV-2 about the sources of exposure to the virus, the hazards associated with that exposure, and appropriate workplace protocols in place to prevent or reduce the likelihood of exposure." Reasonable exposure to SARS-CoV-2 includes virtually every industry on earth.
•Disinfection Protocols - According to OSHA, employer protocols must be developed to prevent or reduce the likelihood of exposure to SARS-CoV-2. Protocols should include control and prevention measures, response procedures on what to do if an employee tests positive for COVID-19, the use of PPE, engineering controls and administrative controls (work practices). (PPE (29 CFR 1910.132), Eye and Face Protection (29 CFR 1910.133), Hand Protection (29 CFR 1910.138), and Respiratory Protection (29 CFR 1910.134) standards). Protocols will also be the document used to assist with the clean up procedures and determine the level of risk associated with that particular facility/building.
•Contractors performing COVID services should be properly insured with a "Communicable Disease Coverage Endorsement" added to their Pollution Liability section of their Environmental Liability Policy. Most policies have a communicable disease or virus exclusion in their policy.
•Contractors should also use a COVID service legal contract prepared by an experienced attorney to ensure the highest liability protection with clear expectations on the services to be performed. Many contracts are not properly designed for COVID related services and could lead to increased liability to the contractor.
•Employers should ensure that employees have obtained COVID specific training and implement routine increased cleaning & hygiene for the building. COVID specific Health and Safety requirements should be performed and documented as required by OSHA. In addition, a company that is insured/rated as janitorial services would want to notify their insurer of the change in exposure to avoid potential claims. They should notify their broker/insurer that they will be taking on biohazard work.
•Compliance with these items will result in the building owner or employer acquiring a COVID Compliant placard that can be displayed on the front of the window of the building. This placard will visually demonstrate that best available practices and procedures are being implemented to control and prevent exposure to COVID-19.