By Dr. Michael Payne, UC Davis, School of Veterinary Medicine and Director, CDQAP

Some dairies received an unusual visit over the July Fourth weekend, one from the Division of Occupational Safety and Health, better known as Cal/OSHA. Rather than checking on familiar areas like heat stress and toilets, however, these visits focused on COVID-19 prevention.

Dairy producers shouldn’t feel singled out. A wide variety of commodities are receiving COVID-19 “compliance assistance” visits, including harvesting and processing operations for tomatoes, melons, walnuts, almonds, “Asian produce,” lumber, and nursery plants.

California’s dairy industry thus far has been spared from the catastrophic outbreaks experienced by Midwest packing plants. Coronavirus infections have, however, been detected on some California dairy farms and processing plants in other states. Closer to home, Coronavirus infections have become a serious issue in California’s produce workers.

Fortunately for time-strapped producers, Cal/OSHA—the agency with primary authority over employee respiratory health—has provided clear guidance on COVID-19 compliance.

This month, in collaboration with the California Department of Public Health (CDPH), Cal-OSHA released a comprehensive guidance for employers of livestock farms addressing COVID-19 worker safety. The main document is accompanied by an abbreviated checklist summarizing the high points.

What Does Cal/OSHA Require on Dairies?

A Written COVID-19 Plan – Cal/OSHA requires that a workplace-specific COVID-19 prevention plan be added to the dairy’s Illness and Injury Prevention Program (IIPP). The COVID-19 prevention plan must include a comprehensive risk assessment for all work areas and work tasks. A person responsible for implementing the plan must be designated. The COVID-19 training program should be described and employee training documented. The plan must incorporate California’s requirement for face coverings described below. The plan must be available to employees and their representatives.

Face Coverings – Agricultural operations fall under the state-wide mandate that face coverings be worn while in enclosed workspaces. Cal/OSHA currently interprets this to include breakrooms and milking parlors. Face masks need not be worn, either indoors or outdoors, when a physical distance of at least 6 feet can be consistently maintained. Employees witnessed in closer proximity than 6 feet and without face coverings may leave the producer open to a Cal/OSHA worker safety citation.

While face masks do not lead to dangerously low oxygen levels, they are uncomfortable and universally detested. Masks can, however, be remarkably effective at decreasing COVID-19 transmission. One Center for Disease Control (CDC) case history described how two Missouri hair stylists infected with coronavirus and having active symptoms, failed to transmit the disease to 139 clients. Both the stylists and all the clients wore masks.

Employers are required to provide some sort of face covering to employees. Producers may have to work with employees to determine which masks they find least objectionable. N95 masks offer the most virus protection. Masks fitted with exhalation valves may be perceived as feeling cooler and less humid, although they provide protection primarily to the wearer. Surgical masks, which are much looser and less durable, still decrease viral exposure by more than 6-fold. Workers are free to choose from a wide variety of commercial or homemade products. Some workers may only consistently wear a bandana or “gator” type of mask.

Worker Training – Producers are required to provide worker training addressing COVID-19. This is to include how to prevent its spread, the importance of home quarantine if symptoms develop, and information on paid sick-leave. Perhaps the easiest way to start employee training is by using Cal/OSHA’s farm worker video, available in both English and Spanish. The video does not address recent requirements on face coverings, which will have to be covered separately. To supplement the video, Cal/OSHA’s flyer for agricultural employees (available in English and Spanish) can be handed out. UC Davis offers an outline for “tailgate” coronavirus worker training. A third method of training is signage. CDC offers a wide selection of posters and infographics in a variety of languages. Initially producers might consider using CDC’s Stop the Spread of Germs poster available in English and Spanish. CDFA has also provided some tips on effective COVID-19 communication to farm workers.

Screening and Physical Distancing – Cal/OSHA requires temperature screening and/or symptom reporting. Such screening can be performed either at home by the employee or at the dairy. Employees may self-certify that they are symptom-free at the beginning of each shift. Employees must be encouraged to stay home when feeling ill, an action supported by a CDC poster in English and Spanish. Producers may consider staggering work meetings or meal breaks to help maintain worker distancing of at least 6 feet. Independent contractors, delivery personnel, and regulatory staff are subject to the same distancing and face covering requirements as employees. Employees may be at more risk of infection at home than they are at work. CDC offers guidance for extended, multi-generational families living in the same household in both English and Spanish.

Sanitation, Cleaning and Disinfection – Fortunately producers already comply with Cal/OSHA and CDFA requirements ensuring that bathrooms and hand- washing facilities are readily accessible, clean, and stocked with soap and single-use towels. Additional handwashing or hand-sanitizing stations can be located to encourage employee use when they arrive and leave work, and before and after eating. Posters in English or Spanish can be posted to remind employees to use the stations. Shared equipment should be sanitized between each use or disposable gloves should be provided. Common work areas, such as break areas should be cleaned and sanitized frequently.

Response to Disease – Employees with COVID-19 symptoms should be immediately sent home or to medical care. The dairy’s IIPP should describe how the local health department will be alerted. The dairy’s outbreak response should be consistent with CDPH guidance, Responding to COVID-19 in the Workplace. The local health department will assist dairy management through the necessary testing, trace-back, and quarantine efforts. It is essential that employees assist in these efforts to protect their families and others from contacting disease. CDC has provided a flyer for employees diagnosed with COVID-19 in English and Spanish. If a COVID-19 case results in hospitalization or death Cal/ OSHA must be notified.

Additional COVID-19 Guidance

There are a number of comprehensive COVID-19 websites available to producers. CDFA’s expansive COVID-19 homepage addresses everything from food safety to livestock markets, to meat and poultry processing plants. The UC Davis Western Center for Ag Health and Safety also has an extensive website with a wide offering of employee training tools, including videos, brochures, and posters in English and Spanish.

The dairy industry has similar online outreach. The NMPF website has an exhaustive menu of links and resources. This includes the frequently recommended COVID-19 Prevention and Management Dairy Farm Handbook. Other local organizations such as Western United Dairies, and Milk Producers Council also have excellent COVID-19 webpages.