CAL/OSHA Revises Written COVID-19 Prevention Program

Last November, Cal/OSHA required nearly all employers to implement an effective written COVID-19 Prevention Program (Model CPP) pursuant to mandatory emergency temporary standards (ETS).

On June 29 2021, Cal/OSHA published its revised Model CPP to comport with the newest June 17, 2021 ETS revisions.

The revised Model CPP:

• Provides new instructions for documenting an employee’s fully vaccinated status;

• Eliminates physical distancing requirements except during certain outbreaks;

• Eliminates use of face coverings for fully-vaccinated workers;

• Requires employers to maximize workplace ventilation and air filtration;

• Eliminates requirement to disinfect workplace items between uses by others;

• Requires employers to provide respirators, such as N95 masks, for voluntary use to non-vaccinated employees upon request;

• Mandates additional training on face coverings, respirator use, and how to access testing and vaccination;

• Requires employers to inform employees that “vaccination is effective at preventing COVID-19, protecting against both transmission and serious illness or death”; and

• Redefines workplace exclusion after close contact, particularly for fully-vaccinated employees.

Employers must adopt these pandemic-related protocols as part of their state-mandated injury and illness prevention program through the use of the state model or their own programs. Thus, employers should carefully review the revised Model CPP and consult with an employment attorney for further assistance.

For more information, please contact Tim Bowles, Cindy Bamforth or Helena Kobrin.

See also:

• Easy Does it – Workplace COVID Standards Slowly Lessening (June 25, 2021)
• Workplaces Return, but not Home Yet – California’s COVID Restriction Cut-Backs from June 15, 2021 (June 18, 2021)
• Good Workplace Policy is Boss – Our Template Handbook & Forms for 2021 (May 28, 2021)
• Stay-Away “Exclusion” Pay – Require Pandemic Wages for Positive Test or Workplace Exposure (March 18, 2021)

Cindy Bamforth
July 15, 2021