220-10.E CDC guidelines can only be followed in lieu of DOLI requirements if they offer equivalent or greater protection

• During past revisions of the DOLI regulation this requirement has led to confusion as new information about the pandemic becomes available.  CDC guidelines are continuously evolving and a hierarchy of standards to follow would be more effective for long term implementation than a separate set of FAQ guidelines that don’t align with the original regulation.

220-40.E.4 Requires respiratory protection in shared vehicles. 

• It remains unclear whether medical clearance and fit testing is required for N95 use in this application.  This was previously clarified in a FAQ to not require medical clearance and fit testing if a N95 was selected.  Can this be included in the standard?

220-40.F.1.f Provides face covering exceptions. 

• How does this apply to contractors working at a facility that has different rules than their employer?

220-40.L.5.a Required frequencies for cleaning and disinfection of common spaces. 

• • Add provision for supplying cleaning and disinfection equipment in the area that can be used to clean and disinfect prior to accessing the common space

220-50 Need additional clarification under A.6.a around what is considered a licensed healthcare provider.

• It appears this section is not intended to apply to first aid provided by an employee.  Seeking to clarify that an employee licensed as an EMT would not be considered a licensed healthcare provider. 

220-20 The definition of “otherwise at-risk” includes an employee’s personal health conditions that the employer may not be aware of.  Sections 220-40.D and 220-40.G require the employer to require these employees to take certain actions. 

• Update sections that reference “otherwise at-risk employees” so that the employer is required to provide protective measures but not required to enforce the requirement since employers are not aware of what employees may be in this category.