The Tech Box

The Tech Box – February 2021

COVID-19 Emergency Temporary Standard and COVID-19 Prevention Plans

This month, I’m sharing information from the Fibre Box Association (FBA) Safety & Health Committee. This committee works to identify safety and health issues and concerns within the corrugated industry and creates collaborative positions on current matters to help and inform the industry.

President Biden issued an Executive Order (EO) directing the Occupational Safety & Health Administration (OSHA) to issue updated employer guidance on protecting workers from COVID-19 within two weeks. The EO also instructed the agency to consider establishing a COVID-19 emergency temporary standard (ETS) by March 15.


issued stronger workplace guidance

on January 29.

“Protecting Workers: Guidance on Mitigating and Preventing the Spread of COVID-19 in the Workplace”

provides updated guidance and recommendations. The guidance is not a standard or regulation, but that may still come in the form of an ETS. Below is some information on ETS and COVID-19 prevention plans that could be helpful for box manufacturers.

Emergency Temporary Standard - ETS

Under certain limited conditions, OSHA is authorized to set emergency temporary standards that take effect immediately and are in effect until superseded by a permanent standard. Unlike regular rulemaking, there is no time period to ensure compliance and instead compliance is mandatory immediately.

COVID-19 Prevention Plans

OSHA guidance strongly recommends the development and implementation of a written COVID-19 prevention plan, or the addition of a COVID-19 – epidemic/pandemic section to existing injury and illness prevention programs (IIPP).

Implementation of the following actions are advised with respect to your company’s written plan:

  • Communicate the company COVID-19 prevention policies and procedures to employees.
  • Perform a Hazard Analysis Critical Control Points (HACCP) to identify, evaluate and correct COVID-19 hazards.
  • Provide physical distancing of at least six feet unless it is not possible.
  • Mandate the use of face coverings.
  • To reduce transmission risk, practice hazard prevention and control using

    OSHA Hierarchy of Controls



    - engineering solutions (including elimination or substitution),

    followed by

    safe work practices, administrative controls, and


    personal protective equipment (PPE). Avoid selecting controls that may directly or indirectly introduce new hazards.
  • Document and implement procedures to investigate and respond to COVID-19 cases in the workplace. If any employees contract COVID-19, ensure that any cases that are determined not reportable are thoroughly documented, supporting the decision.
  • Provide employees with COVID-19 training that is customized per company policies and considers their work situations.
  • Exclude COVID-19 cases and exposed employees from the workplace until they are no longer an infection risk.
  • Establish recordkeeping of COVID-19 cases and reporting of serious illnesses and multiple cases as locality dictates, such as Cal/OSHA and the local health department.

Sample COVID-19 Prevention Plans

The links below are some sample COVID-19 prevention plans that you can customize for your company or plants. While these are good resources, we encourage you to craft your plan specifically to your plant/company.


Mary Alice

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Mary Alice Drain is the Director of Technical Services at Fibre Box Association (FBA). If you have technical questions about the corrugated industry, you can reach her direct at