Best Practices for Construction Sites in the Age of COVID-19

On By sdcountybar

By Jackson W. Isaacs
Isaacs Law Firm, APC

On March 19, 2020, in response to the novel COVID-19 pandemic, the State of California ordered all individuals to stay home and shelter in place, subject to certain “critical industry” exceptions.[1] Amongst those 16 critical industries[2] excepted from the stay at home order was the construction industry including residential construction. Thus, despite many sectors of the economy grinding to an abrupt halt, the construction industry could continue operations. However, due to the serious health risk posed by COVID-19, the construction industry was forced to adapt to the new environment. What follows is a compilation of recommendations and guidelines that contractors, trades, and others have developed to allow California to continue to build during COVID-19.[3]

  1. Plan. Construction industry employers, including contractors, tradespeople, design professionals, and inspectors should develop a COVID-19 exposure control plan which includes measures to reduce the risk of onsite worker or job site visitors of contracting COVID-19.
  2. COVID-19 Supervisor. Owners, contractors or construction managers should designate a site-specific COVID-19 supervisor to enforce COVID‐19 response practices on each job site and perform regular job site inspections. The designated COVID-19 supervisor should be present on the construction site during construction activities. The supervisor can be an onsite worker designated to carry out this role, such as the site foreman or the Project Manager.
  3. Maintain Distance. Job site workers and visitors should maintain minimum 6-foot separation from other individuals during all activities including work breaks, and material or equipment deliveries.  
  4. Stagger Schedules. Under normal conditions, trades such as plumbers and electricians work in close quarters – conditions conducive to viral transmission. To reduce this risk, project managers or schedulers should stagger trades and work schedules as necessary to reduce density of workers, minimize the number of overlapping trade teams and maintain social distancing.
  5. Plan Personnel Flow. To the extent possible, areas where workers would be forced to come within six feet of each other such as hallways, hoists, elevators, break areas, and buses should be eliminated or modified. If possible, designate one entrance for entry and another exit only and post appropriate signage.
  6. Prohibit Gatherings. Prohibit indoor gatherings or meetings of 10 or more people at any time on the job site, including during lunch and other breaks. Job site safety meetings should be held in smaller groups while maintaining six-foot distancing. If it is necessary to gather more than 10 people together, ensure such meetings are held outdoors with appropriate distancing.
  7. Tool Sharing. Workers should not share equipment or tools. If tool-sharing is required, each tool should be sanitized before and after each use. When cleaning or disinfecting areas or tools, do not use pressurized air or water spray to avoid generating bio‐aerosols.
  8. Hand-Washing. Job sites should have a clean and sanitary restroom with a hand washing station or hand sanitizer for employees and visitors. Allow workers to wash hands regularly and thoroughly with soap and water or use alcohol‐based hand sanitizers while on job sites at least every 30 minutes. Hand sanitizer should contain a minimum 60% ethanol or 70% isopropanol. Job site bathrooms should be regularly cleaned and/or sanitized. The recommended ratio of job site toilets to employees during the emergency declaration is 1:10 (to match size of groups allowable). If this is not feasible, job site toilets should be cleaned at a higher than standard frequency.
  9. Eliminate Shared Water Sources. Do not provide communal drinking water coolers and prohibit workers from sharing food or personal items. Contractors should provide bottled water for employees.
  10. Carpooling. Discontinue car pool or ride‐sharing of workers before, during and after work.
  11. Keep Count. Maintain a daily attendance log of all workers and visitors. Job site deliveries should be managed to limit contact between workers and minimize the overall headcount on the job site.

PPE. Job site employers must provide personal protective equipment (PPE) for their employees as appropriate for the activity being performed. If possible, the contractor should maintain a cache of additional PPE in the event a worker runs out of or misplaces his personal PPE.

  1. Face Coverings. All job site workers and visitors should wear face coverings over their noses and mouths while performing their work. Face coverings include fabric coverings, such as scarves and bandana coverings.
  2. Wash Coverings Daily. All reusable face coverings must be frequently washed, at minimum once a day, for the health and safety of users and others. Single-use masks must be discarded appropriately.
  3. Gloves. Workers should use supplemental PPE, such as nitrile or latex gloves, when necessary.
  4. No Sharing. Workers shall not share PPE with coworkers unless they are cleaned and disinfected before and after use.

COVID-19 Job Site Signage. Contractors or Construction Managers must post the latest CDC guidelines for required hygienic practices in English, Spanish, and any other necessary language, together with any locally required signage, in conspicuous locations visible to all workers. These guidelines must include, at a minimum:

  1. Not touching face with unwashed hands or with gloves.
  2. Washing hands often with soap and water for at least 20 seconds.
  3. Use of hand sanitizer with at least 60% ethanol or 70% isopropanol alcohol.
  4. Covering the mouth and nose when coughing or sneezing.
  5. Cleaning and disinfecting frequently-touched objects and surfaces – including but not limited to – workstations, keyboards, telephones, handrails, machines, shared tools, elevator control buttons, and doorknobs.

Job Site Worker Wellness Checks. Finally, the COVID Supervisor should interact with each worker as they enter the job site to perform a wellness interview. The Supervisor should:

  1. Ensure that all workers have performed a daily health assessment before arriving to the job site and advise workers that they should self-monitor for symptoms throughout the day.
  2. Advise workers to notify their manager/employer if they:
    1. Have a fever, or are exhibiting any COVID‐19 symptom, or other symptoms of sickness,
    2. Have been diagnosed with COVID-19 or exposed to someone diagnosed with COVID‐19, have been advised by a medical professional to quarantine or have immediate or close family members who are sick with COVID-19, or
    3. Are in a high-risk category.
  3. Advise all workers that any worker displaying COVID-19 symptoms or other illnesses must leave the job site immediately, with notification given to the worker’s appropriate management team and the COVID-19 Supervisor.
  4. Contractors are encouraged to conduct temperature checks for workers coming onto job sites.

COVID-19 is a very serious illness which at the time of this article has already taken over 110,000 American lives. For this reason, these guidelines should be followed closely despite any impact on productivity or profitability. Contractors should also know that failure to implement or adhere to a comprehensive COVID-19 which results in the infection of an employee could expose that employer to potential liability.

Be Safe. Stay Well.

[1] https://covid19.ca.gov/img/Executive-Order-N-33-20.pdf

[2] https://www.cisa.gov/identifying-critical-infrastructure-during-covid-19.

[3] This list is closely based on the guidelines publised by the County of San Diego Development Services Department. These guidelines can be accessed