Workplace Cleaning and Disinfection Recommendations

Among the issues employers need to be considering is what steps need to be taken in advance of learning that an infected employee has been in the workplace, and also what its protocols will be if an infected employee has been in the workplace for a period of time prior to discovery.

The most current guidance on how to clean and disinfect the workplace issued by the Center for Disease Control and Prevention (CDC) was issued April 1, 2020.  All employers are strongly encouraged to check this website periodically to make sure that you are following the most current guidance. The CDC has also posted a quick reference document: Cleaning And Disinfecting Your Facility.

As has been widely noted, there is still much to be learned about the causes for and how the coronavirus disease 2019 (COVID-19) spreads.  Transmission of the virus may well occur from surfaces contaminated with the virus.  It is unclear how long the virus may remain viable on various surfaces.

The CDC Guidance lays out in detail the steps that should be taken to properly clean and then disinfect potentially contaminated surfaces.  There are, however, other considerations for employers as noted:

  • Employers need to make sure that they are complying with all federal, state and local health protocols and guidelines, including those involving the identification of new potential cases of COVID-19.
  • Employers should educate those employees whose duties include cleaning, laundry and trash pickup to recognize the symptoms of COVID-19 and to provide instructions on what to do if they develop symptoms.  At a minimum, staff should notify their supervisor and ensure that the local health department is notified if they develop symptoms of COVID-19.  The Health Department will then provide guidance on what actions need to be taken.
  • Employers should also develop policies and guidelines for worker protection and provide on-site training to all cleaning crews prior to providing cleaning tasks.  Training should include when to use Personal Protective Equipment (PPE), what PPE is necessary, how to properly put on, use and take off PPE, and how to properly dispose of the PPE.
  • The CDC has said that the PPE required for cleaning staff in this context are disposable gloves and gowns, which should be worn for all tasks in the cleaning process, including handling trash.
    1. Gloves and gowns should be compatible with the disinfecting products being used.
    2. Additional PPE may be required based on the cleaning/disinfecting products being used whether there is a risk of splash.
    3. Gloves and gowns should be removed carefully to avoid contamination of the wearer and surrounding area.
    4. Upon removal of the gloves the cleaning crew should be sure to thoroughly wash and clean their hands carefully.
  • Employers must ensure that employees are trained on the hazards of the cleaning chemicals used in accordance with OSHA’s Hazardous Communication standards (29 CFR 1910.1200).
  • Additionally, certain employers will need to ensure compliance with OSHA standards for handling Bloodborne Pathogens (29 CFR 1910.1030, including the proper disposal of regulated waste and PPE) (29 CFR 1910.132).

For further questions regarding steps to be taken, be sure to consult the most current guidance from the CDC, and state and local health departments.

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These articles are provided for general informational purposes only and are marketing publications of Gentry Locke. They do not constitute legal advice or a legal opinion on any specific facts or circumstances. You are urged to consult your own lawyer concerning your situation and specific legal questions you may have.