VOSHA Outlines Top 10 Recommendations Relating to COVID-19

VOSHA posted earlier this week the following memo for Vermont employers with non-health care or institutional type worksites.  You can click here for the memo online, and click here for a related post on new OSHA guidelines, and if you have any questions or need additional information, please contact us at info@aivt.org.


To: Vermont Employers with Non-Health Care or Institutional Type Worksites
From: Vermont Occupational Safety and Health Administration
Date: June 8, 2021
Subject: Workplace Safety Top 10 Recommendations Relating to COVID-19

In accordance with the Center for Disease Control (CDC) guidance, the Vermont Occupational Safety and Health Administration (VOSHA) has updated guidance for non-health care or institutional employers in Vermont. This guidance applies to both private sector employers and public sector employers for both indoor and outdoor worksites.

This guidance does not apply to healthcare or institutional worksites. Examples of such sites or tasks include medical practitioner offices, hospitals, field healthcare services, correctional institutions, emergency services providers, homeless shelters, nursing homes, senior daycare facilities and other similar facilities or job duties.

The CDC updated guidance stating fully vaccinated individuals may conduct day-to-day activities without wearing a mask. The CDC defines an individual as “fully vaccinated” two weeks after receiving a second dose of a two-dose vaccine, or two weeks after the single-dose Johnson & Johnson vaccine.

Employers are not required to adopt CDC guidance and may choose to require masking for employees and/or customers should they choose. If the employers choose to implement the most current CDC guidance for vaccinated and unvaccinated employees, VOSHA recommends employers establish documented and well communicated policies for their workplaces which cover the following 10 items:

  1. Clearly communicating the CDC definition of “fully vaccinated.”
  2. Inform staff and/or customers that they are required to follow the masking and spacing guidelines based on their vaccination status, and that, by choosing not to wear a mask, employees are attesting that they meet the definition of fully vaccinated.
  3. Instruct all employees to monitor their symptoms daily, and to stay home if they are unwell or have a fever, regardless of vaccination status.
  4. Strongly encourage and provide necessary supplies for continued good hygiene practices.
  5. Remind employees that have not been fully vaccinated to continue to follow established masking and physical distancing procedures.
  6. Remind employees that are immunocompromised (or those who live with a family member of such condition) that they may voluntarily wear a mask and physically distance, even if they have been vaccinated.
  7. Allow for reasonable accommodations to assist staff who are either unvaccinated or immunocompromised maintain a safe and healthy workspace.
  8. Encourage respect and support in the work environment for all individuals, specifically those who choose to maintain more cautious practices.
  9. Any medically related work on the worksite (company medical offices, first aid applications, etc.) continue to be under the more restrictive masking and personal protective equipment (PPE) requirements as outlined through the OSHA Universal Precautions (click here).
  10. Frequently monitor the state’s COVID guidance at:   vermont.gov or healthvermont.gov.

Employers may choose to be more restrictive in their workplaces by maintaining current protective policies for employees, customers, and any other member of the public who is at the worksite.

The information outlined above are all recommendations in addition to the State of Vermont’s COVID-19 Universal Guidance. It should be noted, that when requirements are satisfactory to rescind universal guidance, COVID-19 remains a workplace injury if it is determined the worker contracted the virus at the workplace. To that end, employers may choose to, but are not required to, maintain some or all the recommendations identified above or components of the State’s Universal Guidance to mitigate the risk of employees contracting the virus

The most current CDC guidance can be accessed at the following link: Interim Public Health Recommendations for Fully Vaccinated People | CDC (click here).

More information about Vermont’s Occupation Safety and Health Administration and workplace safety can be found online at labor.vermont.gov.