Home Based Work Safety Considerations

By Jeremy Wherren, CSP, CHMM, CMQ/OE, Corporate Health and Safety Officer
As we all adjust our business operations to this crisis, there are a litany of things for us to consider, and each day priorities change as we pivot to an everchanging situation. Worker safety and health are one of, if not our greatest, priorities confronting us today. In the coming weeks, I will be providing some practical guidance on worker safety and health and other workplace compliance practices to help you and your workplace get through these unprecedented times.

This week’s topic includes compliance considerations with Home-Based Worker safety.

It is important for all employers who have employees working from home to consider work practices to prevent accidents in the home. As of the writing of this blog post, according to NBC News approximately 272 million American’s are subject to “stay-at-home” or shelter-in-place” orders due to the Corona Virus Pandemic. This has required most employees to work remotely from home, thereby transforming their study, garage, or dining room table to a home office.

What’s OSHA’s Take on Home-Based Work?
The U.S. Occupational Safety and Health Administration currently does not have any regulatory standards concerning employee work from home or telecommuting. However, on February 25 2000, OSHA did issue Directive CPL 2-0.125 for Home-Based Worksites. Within this Directive, OSHA defines Home Offices and Home-Based Worksites. A Home-Based Worksite includes any areas of an employee’s personal residence where the employee performs work, whereas a Home Office includes only office work activities in a home-based worksite such as typing or using equipment – computer or file cabinet etc.

OSHA also maintains specific policies for Home Offices compared to Home-Based Worksites. OSHA will not conduct inspections of Home Offices, nor will it hold employers liable for employees’ home offices and does not expect employers to inspect the home offices of their employees. For Home-Based Worksites, OSHA will only conduct inspections when OSHA receives a complaint or referral that indicates that a violation of a safety or health standard exists that threatens physical harm, or that an imminent danger exists, including reports of a work-related fatality.

So, are employers off the hook from OSHA regulations and Home-Based Work?
Not completely, employers are responsible for in-home worksites for hazards caused by materials, equipment, or work processes which the employer provides or requires to be used in an employee’s home. Also, employers who are required to keep records of work-related injuries and illnesses will continue to be responsible for keeping such records, regardless of whether the injuries occur in the factory, in a home office, or elsewhere, as long as they are work-related and meet the recordability criteria of 29 CFR Part 1904. Work related injuries could include musculoskeletal disorders (MSDs) related to poor office design or electric shock from company provided equipment etc. requiring to be recorded on the OSHA 300 log.

What are some key things we can do to prevent Home-Based work injuries?

  • Employees should maintain an ergonomically friendly home office space, there are many resources available such as the OSHA e-Tool checklist to help employees self-assess good ergonomics.
  • Take micro-breaks to minimize the chance of incurring an MSD from static postures.
  • Follow common safe practices with electric cords and use of outlets (e.g. do not overload outlets, avoid using extension cords as much as possible, do not run electrical cords through walking areas, etc.).
  • Practice good housekeeping keeping clutter to a minimum and keep sharps like scissors, letter openers, or razor blades safely secure from inadvertent contact.
  • Stay active at home, try to exercise, and maintain wellness.
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