COVID-19 State-Specific Training Requirements

This information is for customers using J. J. Keller's COVID-19 Prevention for Employers course.

View the chart below to learn more about state OSHA agencies who have adopted requirements specific to COVID-19.

State & Effective Date	Covered Employers	Summary of Requirements
California California has adopted an Emergency Temporary Standard for COVID-19 Prevention, as well as Assembly Bill 685, which is a notification requirement to help protect workers from COVID-19. Effective: The COVID-19 Emergency Standard became effective 11/30/20. The AB 685 notification requirements will be in effect from January 1, 2021, to January 1, 2023.	COVID-19 Prevention: Emergency Temporary Standard All employers. However, some classes of workers are excepted from the requirements (i.e., those covered by Cal/OSHA’s Aerosol Transmissible Diseases standard, or those working at home or having no contact with others). AB 685: Notification requirements for COVID-19 All employers	COVID-19 Prevention: Emergency Temporary Standard The regulations require that employers implement a site-specific written COVID-19 prevention program to address COVID-19 health hazards, correct unsafe or unhealthy conditions, and provide face coverings. When there are multiple COVID-19 infections or outbreaks at the worksite, employers must provide COVID-19 testing and notify public health departments. The regulations also require accurate recordkeeping and reporting of COVID-19 cases. AB 685: Notification requirements for COVID-19 Employers must notify all employees who were at a worksite of all potential exposures to COVID-19. In addition, employers must notify the local public health agency of all outbreaks. An outbreak in a non-healthcare setting is defined as three or more laboratory-confirmed cases of COVID-19 among employees who live in different households within a two-week period.
Michigan The Michigan Department of Labor and Economic Opportunity adopted Emergency Rules for Coronavirus Disease (2019). Effective: Oct. 14, 2020. The Emergency Rules will expire April 14, 2021. However, they may be replaced by an identical permanent standard.	All employers are covered by the rule. However, some requirements only apply to employers with employees involved in medium, high, or extremely high-risk job tasks, as defined below: • Low risk: Lower risk jobs are those that do not require contact inside six feet with persons known to be, suspected of being, or that may be infected with the SARS-CoV-2 virus. These individuals have minimal occupational contact with other employees or the general public, or could achieve minimal occupational contact through the implementation of work practice controls. • Medium risk: Medium risk jobs are those that require more than minimal occupational contact, contact inside six feet with other employees or other persons that may be, but are not known or suspected to be, infected with the SARS-CoV- 2 virus. These may include, but are not limited to, waiters, grocery store workers, agricultural workers, construction workers, domestic service workers, hairdressers, fitness instructors, workers in poultry and meat processing facilities, manufacturing workers, and healthcare workers in settings without known or suspected sources of SARS-CoV-2. • High risk: High risk jobs are those with a high potential for employee exposure inside six feet to known or suspected sources of SARS-CoV-2 virus. These include hospital workers, first responders, medical transport providers, mortuary services workers, medical and dental staff, non-medical support staff, long term care facility staff, home healthcare workers, etc. • Very high risk: Very high risk jobs are those with a high potential for employee exposure inside six feet to known or suspected sources of SARS-CoV-2 virus during the performance of specific medical (e.g., aerosol generating procedures), postmortem, or laboratory procedures with specimens from a known or suspected source of the SARS-CoV-2 virus. The rule also has specific requirements for individual industries.	• Classify job task based on risk. • Develop and implement a written COVID-19 preparedness and response plan consistent with CDC guidance. • Establish and implement a system for employee self-assessment and screening. • Implement controls to prevent transmission in the workplace. • Establish a system for notifying employees and other employers, as well as the local public health department, of suspected or confirmed cases. • Designate one more worksite COVID-19 safety coordinators. • Place posters that encourage safe practices. • Provide training. • Follow industry-specific requirements.
New Jersey New Jersey has adopted a requirement that all employers must implement COVID-19 safety and health protocols, which will be enforced by the state’s Department of Health (DOH). Effective: Nov. 5, 2020	All private and public employers in New Jersey.	• All individuals on the worksite maintain at least six feet of distance from one another to the maximum extent possible. • Employees, customers, visitors, and other individuals entering the worksite wear a face mask on the premises. • Provide hand sanitizer or sanitizing wipes to employees, customers, and visitors at no cost to them. • Ensure employees practice regular hand hygiene. • Routinely clean and disinfect all high-touch areas in accordance with New Jersey Department of Health (DOH) and Centers for Disease Control and Prevention (CDC) guidelines. • Conduct daily health checks before each shift. • Immediately separate and send home employees who appear to have COVID-19 symptoms, as defined by the CDC, upon arrival at work or who become sick during the day. • Promptly notify all employees of any known exposure to COVID-19 at the worksite. • Clean and disinfect the worksite in accordance with CDC guidelines when an employee at the site has been diagnosed with COVID-19. • Continue to follow guidelines and directives issued by the New Jersey DOH, the CDC, and OSHA, as applicable, for maintaining a clean, safe, and healthy work environment. Employers who do not follow the safety standards can be subject to fines and penalties, and potential worksite closure by the New Jersey DOH.
Oregon Oregon OSHA has adopted OAR 437-001-0744 an emergency temporary standard (ETS) for COVID-19 risks in the workplace. Effective: Nov. 16, 2020, with staggered dates for training (12/21/20), Infection Control Plan, (12/21/20), and ventilation optimization (1/6/21). The ETS will expire May 4, 2021. However, it is expected to be replaced by a permanent standard, likely to be expanded to all “airborne infectious diseases”.	All employers are covered by the rule.	• Ensure physical distancing. • Provide face masks, face coverings, or face shields at no cost to worker. • Establish a cleaning and sanitation schedule consistent with the rule. • Post the “COVID-19 Hazards Poster” and electronically send to remote employees. • Optimize ventilation requirements, as specified in the rule (by Jan. 6, 2021). • Establish an infection control plan. • Train employees by Dec. 21, 2020. Note: Employers must ensure that the training provides an opportunity for feedback from employees about the topics covered in the training. • Establish a system for notifying employees and other employers of suspected or confirmed cases. • Follow industry-specific requirements.
Virginia The Virginia Safety and Health Codes Board has adopted an Emergency Temporary Standard (ETS), Infectious Disease Prevention: SARS-CoV-2 Virus That Causes COVID-19, 16VAC25-220. Effective: July 27, 2020. The ETS will expire January 27, 2021. However, it is expected to be replaced by an identical permanent standard.	All employers are covered by the rule. However, some requirements only apply to employers with employees involved in medium, high, or extremely high-risk job tasks, as defined below: • Low risk: Lower risk jobs are those that do not require contact inside six feet with persons known to be, suspected of being, or that may be infected with the SARS-CoV-2 virus. These individuals have minimal occupational contact with other employees or the general public, or could achieve minimal occupational contact through the implementation of work practice controls. • Medium risk: Medium risk jobs are those that require more than minimal occupational contact, contact inside six feet with other employees or other persons that may be, but are not known or suspected to be, infected with the SARS-CoV- 2 virus. These may include, but are not limited to, waiters, grocery store workers, agricultural workers, construction workers, domestic service workers, hairdressers, fitness instructors, workers in poultry and meat processing facilities, manufacturing workers, and healthcare workers in settings without known or suspected sources of SARS-CoV-2. • High risk: High risk jobs are those with a high potential for employee exposure inside six feet to known or suspected sources of SARS-CoV-2 virus. These include hospital workers, first responders, medical transport providers, mortuary services workers, medical and dental staff, non-medical support staff, long term care facility staff, home healthcare workers, etc. • Very high risk: Very high risk jobs are those with a high potential for employee exposure inside six feet to known or suspected sources of SARS-CoV-2 virus during the performance of specific medical (e.g., aerosol generating procedures), postmortem, or laboratory procedures with specimens from a known or suspected source of the SARS-CoV-2 virus. The rule also has specific requirements for individual industries.	• Classify job task based on risk. • Establish and implement a system for employee self-assessment and screening. • Provide flexible sick leave policies, telework, staggered shifts, etc. • Implement controls to prevent transmission in the workplace. • Establish a system for notifying employees and other employers of suspected or confirmed cases. • Prepare an Infectious Disease Preparedness and Response Plan (if 11+ employees in jobs classified as medium risk; or any employer with high-risk jobs). • Provide training (if medium, high, or very high risk).