By Conn Maciel Carey’s COVID-19 Task Force

Today’s topic on the Fed OSHA COVID-19 ETS is health screening and medical management.

29 C.F.R. Section 1910.502(l) sets forth employee screening, employer/employee notification, medical removal, medical removal protection benefits, and return-to-work requirements.  This summary describes those requirements of the ETS.

A. Employee Screening

Employers have discretion in choosing whether to implement self-monitoring and/or in-person screening.  Employers who choose to have employees self-monitor for COVID-19 symptoms can assist employees in that effort by providing them with a short fact sheet to remind them of the symptoms of concern.  Employers may also consider posting a sign stating that any employee entering the workplace certifies that they do not have symptoms of COVID-19, to reinforce the obligation to self-screen before entering the workplace.

Employers who choose to conduct in-person employee screening for COVID-19 symptoms may use methods such as temperature checks and asking the employee if they are experiencing symptoms consistent with COVID-19.  Employers should conduct this screening before employees come into contact with others in the workplace, such as co-workers, patients, or visitors.

To the extent employers choose to conduct onsite screening, there are important safety considerations to take into account.  Continue reading →