Additional Considerations for Workers Who Reside in Communal Living Arrangements
This guidance is not a standard or regulation, and it creates no new legal obligations. It contains recommendations as well as descriptions of mandatory safety and health standards. The recommendations are advisory in nature, informational in content, and are intended to assist employers in providing a safe and healthful workplace. The Occupational Safety and Health Act requires employers to comply with safety and health standards and regulations promulgated by OSHA or by a state with an OSHA-approved state plan. In addition, the Act's General Duty Clause, Section 5(a)(1), requires employers to provide their employees with a workplace free from recognized hazards likely to cause death or serious physical harm.
In addition to the control measures and precautions used for employees working in close quarters and in temporary labor camps (see the Temporary Labor Camps standard, 29 CFR 1910.142), various combinations of workplace control measures may be appropriate for workers residing in communal living arrangements, including employer-furnished housing. Control measures will vary depending on the results of employers’ hazard and risk assessments for these environments. Where feasible, accommodations (i.e., flexibilities based on individual needs) should be considered for workers at higher risk of having severe illness from COVID-19. CDC’s COVID-19 Toolkit for Shared and Congregate Housing provides additional information for people living in close quarters environments, including what to do If You Are Sick or Caring for Someone who is sick.
Efforts to eliminate the hazard from shared living arrangements may include: assigning workers who have been tested for COVID-19 and do not have the virus to reside in designated employer-furnished housing, separate from those who have not yet been tested (i.e., cohorting workers); screening workers moving into employer-furnished housing for symptoms of COVID-19 before they enter (e.g., using mechanisms for worker self-reporting of symptoms); assigning workers who are ill or exhibiting signs and symptoms of COVID-19 to reside in designated employer-furnished housing away from healthy workers (quarantining workers); and using single unit housing (e.g., trailers/recreational vehicles, hotel or motel rooms) rather than dormitory/bunkhouse style housing. OSHA and CDC have provided information for implementing such testing and cohorting policies and procedures for specific industries, including in agriculture and seafood processing operations. Similar policies and procedures, as described here, may be adapted to other industries where testing and cohorting workers who reside in communal living arrangements, including employer-furnished housing, may be feasible.
Examples of engineering controls in shared living arrangements that may be useful for protecting workers from COVID-19 include:
- Configuring common living areas (e.g., kitchens, bathrooms, living rooms) to support social distancing of workers spaced at least six feet apart and to minimize the need for workers to be face-to-face and in close proximity to one another.
- Discouraging or preventing use of open toilet facilities (such as urinals and open bay showers) in larger shared housing facilities (such as labor camp restrooms) where alternative toilet facilities are available, or configuring such toilet facilities to maintain a distance of six feet between urinals and shower heads being used, with barriers between units where possible.
- Extending the minimum separation distances between beds and minimizing or avoiding the use of bunk beds so that a minimum of six feet is achieved between each bed, with workers sleeping in opposite directions (head to toe) to keep heads as far away from each other as possible. See Special considerations for shared housing in CDC/OSHA Interim Guidance for Agriculture Workers and Employers.
- Placing physical barriers or partitions between workers’ beds (e.g., curtains separating workers in semi-private areas).
- Working with building maintenance staff to determine if the building ventilation system can be modified to increase ventilation rates and/or the percentage of outdoor air (as close to 100% as possible) that circulates in the system.
- Providing lockers or other storage devices for soiled laundry to keep individual worker clothing separate.
Administrative Controls and Safe Work Practices
Examples of administrative controls and safe work practices in shared living arrangements that may be useful for protecting workers from COVID-19 include:
- Developing and implementing sanitation and protection measures in shared living facilities.
- Keeping up to date on guidance from state, territorial, local, and tribal public health departments, tailoring protection measures to community-specific information on COVID-19 transmission and policies.
- Limiting the number of workers living in shared housing to increase the ability to maintain social distancing.
- Implementing a group shelter policy (i.e., cohorting small groups of people) for long-term shared housing (e.g., wildland firefighters) with single unit housing for new residents for 14 days (during initial quarantine period) prior to a cohort living together.
- Modifying policies to limit visitors in the employer-furnished housing locations, while ensuring that workers maintain their rights as tenants to access healthcare workers, legal advocates, and other service providers. All visitors should follow applicable procedures and protocols when visiting shared living arrangements.
- Implementing practices to prevent or minimize spread between the surrounding community and congregant work settings (e.g., by establishing procedures for screening visitors to employer-furnished housing locations for signs and symptoms of COVID-19).
- Minimizing traffic in enclosed spaces, such as elevators and stairwells, and limiting the number of individuals in an elevator at one time. Designating one-directional stairwells, if possible.
- Minimizing the sharing of equipment, such as kitchen appliances, food preparation tools (e.g., knives), and eating utensils.
- Encouraging routine hand washing and personal hygiene.
- Avoiding sharing of dishes, drinking glasses, cups, or eating utensils. Handling used non-disposable food service items with gloves and washing with dish soap and hot water or in a dishwasher, or using disposable food service items where gloves and cleaners are not available.
- Enhancing sanitation of all high-traffic areas (e.g., laundry areas, toilet facilities) and frequently touched surfaces (e.g., door handles, paper towel dispensers, sinks, faucets, appliances), and sanitizing those surfaces frequently using EPA-registered disinfectants from List N.
- Encouraging use of cloth face coverings in shared spaces, especially when it is difficult to maintain social distancing; following CDC Considerations for Wearing Masks guidance that states some people (e.g., anyone who has trouble breathing) should not wear a cloth face covering or mask. Some people (e.g., those who rely on lipreading to communicate or who have sensory, cognitive, or behavioral issues) may not be able to wear a cloth face covering or mask. CDC recommends considering adaptations and alternatives whenever possible to increase the feasibility of wearing a cloth face covering or mask or to reduce the risk of COVID-19 spreading if it is not possible to wear one.
- Implementing practices to limit spread of infection from workers on rotational work to other workers or the general public. Examples of potentially risky practices that may require mitigation strategies include fly-in, fly-out practices (such as in oil and gas operations).
- Training workers on CDC guidance for How to Protect Yourself & Others.