On November 25, 2020, Liebert Cassidy Whitmore issued a special bulletin concerning an emergency regulation (8 C.C.R. 3205) that the California Occupational Safety and Health Standards Board (“OSHSB”) adopted concerning the adoption and implementation of a COVID-19 Prevention Program (“CPP”). The emergency regulation requires that, effective November 30, 2020, all public agencies adopt and implement a CPP in order to reduce transmission of the virus that causes COVID-19 at agency worksites and facilities.
As a result, public agencies that have not already adopted and implemented a CPP, must take immediate action to do so. Subsequent to the adoption of a regulatory-compliant CPP, agencies must review and, as necessary, modify existing agency policies and practices also comply with the requirements set forth in the emergency regulation.
In order to assist public agencies with this burdensome and time-consuming undertaking, Liebert Cassidy Whitmore drafted a template CPP that agencies may adopt in order to establish compliance with the requirements in the emergency regulation. To accompany the template, Liebert Cassidy Whitmore also drafted a guide that identifies specific obligations under the regulation so that public agencies may more easily identify existing agency policies and practices that require modification.
Liebert Cassidy Whitmore attorneys are available to assist public agencies that have any questions or concerns about the CPP or other aspects of the emergency regulation.