Workplace safety has taken on a new dimension as California and other states attempt to move towards “reopening” the economy during the COVID-19 pandemic. Manufacturing and distribution centers face unique challenges as they attempt to balance meeting the demand for their products – including through online sales – while keeping their workers safe and healthy in the process. The U.S. Occupational Safety and Health Administration has established what it calls the Hierarchy of Hazard Controls. Manufacturing and distribution centers are well served considering the OSHA Hierarchy of Hazard Controls.

OSHA has established three elements in its Hierarchy of Hazard Controls:

  • Engineering controls
  • Administrative and work practices controls
  • Personal protective equipment

Each of these elements has direct application during the COVID-19 pandemic when it comes to worker safety in operations like manufacturing and distribution. 

Engineering Controls

Engineering controls are technologies that are built-in the overall operations of a business like a manufacturing plant or distribution center. These built-in technologies and equipment are designed to guard against, isolate, and redirect hazards away from employees and others that might enter a workspace.

The typical manufacturing plant or distribution center would have had different engineering controls in place prior to the COVID-19 pandemic. With that said, the vast majority of manufacturers and distribution centers needed to rework and enhance engineering controls in order to provide workers and others with necessary protections relevant to the hazards presented by the coronavirus.

An example of engineering controls that are being utilized with increasing frequency in manufacturing plants and distribution centers are plexiglass partitions or guards installed between workstations. Indeed, even more fundamentally, individual workstations are being created in many facilities of these types, replacing more communal structures that existed before the onset of the coronavirus pandemic.

Other types of engineering controls being added to manufacturing plants and distribution centers include:

  • Sanitization stations at different locations throughout a facility (often that provide touchless dispensing of hand sanitizer)
  • Enhance ventilation systems to better ensure a stable, consistent flow of fresh air throughout the premises
  • Increase in the use of touchless technologies when possible
  • Decrease in the use of shared equipment when possible

Administrative and Work Practices Controls

In addition to important engineering controls that are being adopted by manufacturing and distribution centers, the COVID-19 pandemic necessitates a reexamination of administrative and work safety practice controls. 

Each manufacturer and distributor has unique needs, goals, and objectives when it comes to administrative and work practice controls necessary to operate during the COVID-pandemic. With that said, there are some types of administrative and work practice controls that are applicable in manufacturing and distribution centers more generally:

  • Social distancing is a primary work practice control that needs to be implemented in manufacturing and distribution centers during the coronavirus pandemic to protect workers and others. At a minimum and wherever possible, workers should be positioned at least six feet from one another. Some argue that worker safety can be enhanced significantly if that distance is increased to 10 feet. 
  • Workers should wear masks when on the premises. Employers providing masks for employees is a strong recommendation from OSHA. 
  • Worker schedules need to be reconsidered. This may need to be done because state or local mandates require a reduction of onsite workforces. The bottom line is that worker safety and the ability to socially distance is best achieved with fewer people in a facility. Manufacturing and distribution centers face a challenge in the fact that the vast majority of these types of workforces cannot operate remotely. Some administrative staff may be able to work from home, but most workers in these industries cannot. 
  • Another strategy is to assign specific workers into defined cohorts. In other words, employees always are scheduled to work in shifts with the same group of workers. 
  • Administrative and work practice controls depend on employee and management compliance. Ideally, workers buy into the decisions a company makes in this regard. In addition, a manufacturer or distribution company is obliged to come up with some sort of effective, meaningful enforcement protocol to ensure that there is compliance with administrative and work practices controls. 
  • A crucial element of administrative and work practices controls for a manufacturing or distribution center during the COVID-19 pandemic is to have a comprehensive strategy for coronavirus contamination prevention and remediation. This strategy typically is implemented by a manufacturer or distributor in partnership with an experienced COVID-19 cleaning company.

Personal Protective Equipment

Personal protective equipment is considered the proverbial “last line of defense” when it comes to the OSHA Hierarchy of Hazard Controls. Personal protective equipment, or PPE, in the form of masks has already been discussed. In addition to masks, other types of COVID-related personal protective equipment include gloves, face shields or other protective eyewear, uniforms or smocks, and higher-grade facial protection like an N95 respirator. As is the case with administrative and work practice controls, companies need to develop strategies for enforcement when it comes to PPE.