Cal/OSHA and CDPH Guidance: What California Auto Dealers Need to Know

1. You need to have a work-specific plan.

A work-specific plan is your go-to document for implementing and overseeing COVID-19 prevention efforts across your facilities. Cal/OSHA and CDPH lay out these basic steps for establishing and following through on your plan:

1. Establish a written, worksite-specific COVID-19 prevention plan at every facility, perform a comprehensive risk assessment of all work areas, and designate a person at each facility to implement the plan.
   
2. Identify contact information for the local health department where the facility is located for communicating information about COVID-19 outbreaks among employees.
   
3. Train and communicate with employees and employee representatives on the plan.
   
4. Regularly evaluate the workplace for compliance with the plan and document and correct deficiencies identified.
   
5. Investigate any COVID-19 illness and determine if any work-related factors could have contributed to risk of infection. Update the plan as needed to prevent further cases.
   
6. Identify close contacts (within 6 feet for 10 minutes or more) of an infected employee and take steps to isolate COVID-19 positive employee(s) and close contacts.

Be sure to adhere to all detailed guidelines from Cal/OSHA and CDPH. Failure to do so could result in workplace illnesses that may cause operations to be temporarily closed or limited.

2. You’ll need to thoroughly train employees on specific safety topics.

Cal/OSHA and CDPH require you to educate your workforce on COVID-19 prevention. Employees should be trained on the following topics:

• Information on COVID-19, how to prevent it from spreading, and which underlying health conditions may make individuals more susceptible to contracting the virus.
• Self-screening at home, including temperature and/or symptom checks using CDC guidelines.
• The importance of not coming to work if employees have symptoms such as frequent cough, fever, difficulty breathing, chills, muscle pain, headache, sore throat, recent loss of taste or smell, or if they or someone they live with have been diagnosed with COVID-19.
• To seek medical attention if their symptoms become severe, including persistent pain or pressure in the chest, confusion, or bluish lips or face. Updates and further details are available on the CDC’s webpage.
• The importance of frequent hand washing with soap and water, including scrubbing with soap for 20 seconds (or using hand sanitizer with at least 60% ethanol or 70% isopropanol when employees cannot get to a sink or hand washing station, per CDC guidelines).
• The importance of physical distancing, both at work and off work time (see section #5 below).
• Proper use of face coverings, including: Face coverings do not protect the wearer and are not personal protective equipment (PPE).
  • Face coverings can help protect people near the wearer, but do not replace the need for physical distancing and frequent hand washing.
  • Employees should wash or sanitize hands before and after using or adjusting face coverings.
  • Avoid touching eyes, nose, and mouth.
  • Face coverings should be washed after each shift.

3. You’ll need to implement individual control measures and screening.

You won’t be going back to business as usual. Dealerships are required to implement rigorous COVID-19 prevention measures through a mix of practices and technologies. Be sure to do the following:

• Provide temperature and/or symptom screenings for all workers at the beginning of their shift and any personnel entering the facility. Make sure the temperature/symptom screener avoids close contact with workers to the extent possible. Both screeners and employees should wear face coverings for the screening.
• Encourage workers who are sick or exhibiting symptoms of COVID-19 to stay home.
• Provide workers with all required protective equipment and ensure they use it. Consider where disposable glove use may be helpful to supplement frequent hand washing or use of hand sanitizer—for instance, for workers who are screening others for symptoms or handling commonly touched items.
• Use face coverings when necessary. Face coverings are strongly recommended when employees are in the vicinity of others. Workers should have face coverings available and wear them when at work, in dealership facilities and showrooms, in offices, or in a vehicle for work-related travel with others. Face coverings must not be shared.
• Take reasonable measures to remind the public that they should use face coverings.

4. You’ll need to clean and disinfect objects and surfaces properly and frequently.

Get ready to clean a lot and clean often. Here are Cal/OSHA and CDPH’s cleaning and disinfecting protocols:

• Perform thorough cleaning in high traffic areas such as showrooms, waiting areas, break rooms, and areas of ingress and egress including stairways and elevator controls. Frequently disinfect commonly used surfaces, including counters, credit card machines, touchscreens, doorknobs, armrests, toilets, handwashing facilities, door handles, vehicle keys, and vehicles displayed in the showroom (door handles, seat adjustment controls, radio).
• Clean touchable surfaces between shifts or between users, whichever is more frequent, including but not limited to working surfaces, keys, and stationary and mobile equipment controls.
• Avoid sharing phones, tablets, office equipment, or tools wherever possible. Never share PPE.
• Regularly clean and sanitize shared equipment, such as time clocks, payment portals, pens, and styluses between each use.
• Equip terminals, desks, and help counters with proper sanitation products, including hand sanitizer and sanitizing wipes, and provide personal hand sanitizers to all staff directly assisting customers.
• Ensure that sanitary facilities stay operational and stocked at all times and provide additional hand sanitizer when needed.
• When choosing cleaning chemicals, use products approved for use against COVID-19 on the Environmental Protection Agency (EPA)-approved list and follow product instructions. Use disinfectants labeled to be effective against emerging viral pathogens, diluted household bleach solutions (5 tablespoons per gallon of water), or alcohol solutions with at least 70% alcohol that are appropriate for the surface. Provide employees training on manufacturer’s directions and Cal/OSHA requirements for safe use. Workers using cleaners or disinfectants should wear gloves as required by the product instructions.
• Provide hand sanitizer dispensers throughout showrooms, lobbies, and service areas, for use by customers and employees.
  
• Dedicate employees to sanitize vehicles returning from rental and test drives as well as other high-touch surfaces in lobbies, showrooms, and offices.
  
• Use protective barriers such as disposable mats and seat covers when applicable, such as during test drives and moving returned vehicles.
  
• Adjust or modify store hours to provide adequate time for regular deep cleaning.
  
• Install and encourage the use of credit cards and hands-free devices, if possible, including motion sensor lights, contactless payment systems, automatic soap and paper towel dispensers, and timecard systems.
• Inspect deliveries and take all necessary and feasible disinfection measures when receiving goods.
  
• Consider installing portable high-efficiency air cleaners, upgrading the building’s air filters to the highest efficiency possible, and making other modifications to increase the quantity of outside air and ventilation in offices and other spaces.

5. You’ll need to follow physical distancing guidelines at all times.

Again, your dealership will need to establish rigorous new practices and procedures to protect the health and safety of your workers and customers. Here’s what Cal/OSHA and CDPH recommend you do:

• Implement measures to ensure physical distancing of at least 6 feet between workers and customers. This can include use of physical partitions or visual cues (e.g., floor markings, colored tape, or signs to indicate where workers and/or employees should stand).

• Take measures in areas where physical distancing cannot be maintained to minimize exposure between employees and customers, such as Plexiglas or other appropriate barriers, if feasible. Where barriers are not feasible, employees are strongly recommended to wear face coverings. Some jurisdictions already require face coverings outside the home.
• Adjust meetings to ensure physical distance and use smaller individual meetings at facilities to maintain physical distancing guidelines. Decrease the capacity for conference and meeting rooms in order to maintain at least 6 feet of physical distance between employees.
• Close or restrict common areas where personnel are likely to congregate and interact, such as kitchenettes and break rooms. Close self-service coffee, water, and snack areas, unless they are capable of dispensing without physical touching. Where possible, create outdoor break areas with shade covers and seating that ensures physical distancing.
• Redesign office spaces, cubicles, etc. to ensure workspaces allow for 6 feet between employees. Provide a single, clearly designated entrance and separate exit to help maintain physical distancing, wherever possible.

• Place additional limitations on the number of workers in enclosed areas like supply closets, to ensure at least 6 feet of separation to limit transmission of the virus.
• Stagger employee breaks, in compliance with wage and hour regulations, to maintain physical distancing protocols.
  
• Adjust maximum occupancy rules based on the size of your facility to limit the number of people in a store, office, or showroom at one time. Capacity limits should be low enough to ensure physical distancing but in no case more than 50% maximum occupancy.
• Ask vendors who are required to enter the location to have their employees follow the guidance of local, state and federal governments regarding wearing face coverings and PPE.
  
• Limit passengers in the vehicle during test drives to only a single customer with the employee sitting in the opposite back seat, when applicable. Both the customer and the employee are strongly encouraged to wear face coverings.
• Encourage customer appointments and have customers practice physical distancing while waiting for service using visual cues or ask customers to wait in their vehicles.
  
• Offer curbside delivery or pickup and move sales and agreements to remote/digital platforms as feasible.
  
• Discontinue shuttle services.
  
• Require employees to not use handshakes and similar greetings that break physical distance.

EHS Services and Software Can Make It Easier

If that all seems like a lot of work, well, that’s because it is. These new guidelines are not simple, and they’ll likely be in place for some time to come. But you need to follow all of them if you want to stay in business and keep your employees safe.

Whether you’ve read through the pages of detailed guidance about COVID-19 prevention plans, employee training, and disinfecting protocols, please know KPA is here to help you during your reopening and afterward.

We’ve developed a comprehensive Return to Work Safely Program to help guide your return to normal operations, and ensure your dealership stays compliant with OSHA.

There are two options for the program: Return to Work Safely Fundamentals or Return to Work Safely Plus. Both programs give you access to:

• An online toolset of assets and training, including time-saving templates, readiness assessments and checklists for reopening procedures, facility hygiene, and daily wellness
• EPA-approved COVID-19 disinfectant and Safety Data Sheet (SDS) guidance
• Automotive-specific handbook and policy guides for returning to work
• A new return to work online training module
• Nearly 30 additional fact sheets, signs, and posters

Return to Work Safely Plus provides additional access to KPA consultants to help you customize handbooks, policies, and inspections specific to your business and California state guidance. 

If this is something you might be interested in, download the KPA Return to Work Safely Datasheet for more details or request a live demonstration here.

You’re not alone here. KPA’s environment, health, and safety software and services can make following the new guidelines as easy as possible.