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Safety – COVID-19 in the Workplace

Fibre Box Association (FBA) has been receiving inquiries about COVID-19 and box plants, including preparing workplaces, managing COVID-19 positive employees, recordable cases, etc. We thought it would be helpful to pass along info and practices we received from FBA Safety & Health Committee members.

The below information contains suggestions and resources. FBA recommends that readers conduct their own investigation and make their own judgments in addressing COVID-19 in the workplace, with professional assistance as needed.

Preparing Workplaces

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for the Occupational Safety and Health Administration’s (OSHA) Guidance on Preparing Workplaces for COVID-19. This planning guide, published in March of 2020, contains recommendations and descriptions of mandatory safety and health standards. It focuses on the need for employers to implement engineering, administrative, and work practice controls and personal protective equipment (PPE), [and] considerations for doing so.

Chain of Exposure Decision Matrix

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for an example of a Chain of Exposure Decision Matrix, put together by a Safety & Health Committee member’s company. This tool, built from CDC guidance, is an example to help manage employees who have been diagnosed with COVID-19 or have contact traced to positive cases. It is not a compliance tool but has been used to guide the company’s plants.

Please note: In Scenario 2, a strategy is addressed that allows quarantined workers to return to work. There are circumstances where such a practice would be allowed, but as the CDC notes, special controls need to be in place and even then, the risks are significantly greater than those encountered if the 14-day quarantine rule were followed.


COVID-19 can be a recordable illness if a worker is infected as a result of performing their work-related duties. However, employers are only responsible for recording cases of COVID-19 if all of the following are true:

  1. The case is a confirmed case of COVID-19 (see CDC information on persons under investigation and presumptive positive and laboratory-confirmed cases of COVID-19);
  2. The case is work-related (as defined by 29 CFR 1904.5); and
  3. The case involves one or more of the general recording criteria set forth in 29 CFR 1904.7 (e.g., medical treatment beyond first aid, days away from work).

We recommend that you complete extensive employee interviews and document everything if you find the COVID-19 case doesn’t need to be reported.

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for an article from JD Supra on COVID-19 Requirements for all Employers.