October 25, 2021
Training for Higher-Risk Employers
Plus: See below for mask signage, as masks are still required for employees and optional for vaccinated customers
The VOSH Standard for Infectious Disease Prevention requires employees in “higher-risk workplaces” to be trained on the standard by November 7, 2021. Higher-Risk Employers means a workplace:
- Where employees who are not fully-vaccinated or otherwise at-risk employees are working close to one another.
- Where employees who are not fully-vaccinated or otherwise at-risk workers often have prolonged closeness to coworkers or potential frequent contact with members of the public who may not be fully vaccinated.
- Where employees who are not fully-vaccinated or otherwise at-risk employees work in enclosed indoor spaces with inadequate ventilation where other coworkers or members of the public are present.
- Where employees who are not fully-vaccinated or otherwise at-risk employees may be exposed to the infectious virus through respiratory droplets or aerosols in the air. It is also possible that exposure could occur from contact with contaminated surfaces or objects, such as tools, workstations, or break room tables. Shared spaces such as break rooms, locker rooms, entrances, and exits to the facility may contribute to their risk.
- Other distinctive factors that may increase risk among these employees who are not fully vaccinated or otherwise at-risk employees include the common practice of sharing employer-provided transportation in ride-share vans or shuttle vehicles.
VADA believes many dealerships in Virginia will not need to classify themselves as higher risk after an evaluation of the relevant factors. Even though there are similarities between the previous ETS and the current VOSH Standard for Infectious Disease Prevention, employees who received training under the previous standard must receive training on the new standard.
- For vaccinated employees, the training required by the Standard may be provided in written form. Here is the attached presentation from VOSH.
- Employees who are not vaccinated can access a recording of the presentation by VADA’s Anne Gambardella, Esq. here. It can be used in conjunction with the dealership’s training of employees on their Infectious Disease Preparedness and Response Plan where applicable.
Once the 15-minute training is complete, a written certification of the training is required to be kept on file. Access the "Training Documentation Form" under "Training Materials," here.
Please note that the VOSH Standard for Infectious Disease Prevention does not require a physical or electronic signature if other documentation of training completion can be provided (e.g., electronic certification through a training system, security precautions that enable the employer to demonstrate that training was accessed by passwords and usernames unique to each employee, etc.).
For additional information, please see the DOLI website page for the VOSH standard.
The Standard still requires all employees wear masks in areas of high or substantial transmission. Amid the spread of COVID-19, those high and substantial transmission areas now encompass all of Virginia. Vaccinated employees can stop wearing masks when transmission levels fall to moderate or low. Most localities in Virginia are considered high or substantial transmission (see the latest map here).
The signage here is for displaying at entrances and elsewhere in your dealership and applies to customers. Click it for a downloadable and printable 8.5x11 PDF.