Seyfarth Synopsis: OSHA has issued a COVID-19 guidance for package delivery employers. OSHA offers recommendations to help reduce employees’ risk of exposure to the coronavirus, including administrative controls, hygiene measures, face coverings, and social distancing.

OSHA had previously released a Guidance on Preparing Workplaces for COVID-19, with recommendations for protecting employees during the COVID-19 pandemic. The new COVID-19 Guidance for Package Delivery Workforce is another industry-specific guidance released by OSHA. While the Agency’s guidance is advisory and non-mandatory, it provides useful tools for the package delivery industry in protecting employees and customers during the pandemic.  To that end, OSHA’s recommendations include:

• Encourage workers to stay home if they are sick;
• Establishing flexible work hours (e.g., staggered shifts) where feasible;
• Practice sensible social distancing and maintain six feet between co-workers where possible;
• Minimizing interaction between drivers and customers by leaving deliveries at loading docks, doorsteps or other locations that do not require person-to-person exposures;
• Encourage respiratory etiquette, including covering coughs and sneezes;
• Promoting personal hygiene. If workers do not have access to soap and water for handwashing, provide alcohol-based hand rubs containing at least 60 percent alcohol. Provide disinfectants and disposable towels workers can use to clean work surfaces, including vehicle interiors;
• Allowing workers to wear masks over their nose and mouth to prevent them from spreading the virus;
• Discourage workers from using other workers’ tools and equipment;
• Using Environmental Protection Agency-approved cleaning chemicals from List N or that have label claims against the coronavirus; and
• Encouraging workers to report any safety and health concerns.

These recommendations largely track the prior recommendations from OSHA and the CDC including the CDC’s recent recommendation for all individuals to wear cloth face coverings in public, to prevent the risk of disease transmission. As we discussed in a previous article, the CDC’s face covering recommendations raise important safety and legal challenges for employers. It is also important to note that several state and local emergency orders have more stringent requirements and recommendations for essential package delivery services on issues such as the use of cloth face coverings, social distancing, and pre-shift employee health screening.