Category Archives: Global

In the era of COVID-19, construction companies across America are trying to find the best way forward. Ten challenges every construction organization has to deal with are examined in this article.

While everyone wants their business to continue to operate and fulfill client needs, employee health and well-being are still at the heart of everything you do. With the ever-changing executive orders and inconsistent data, in addition to dealing with a risk that is new to the construction industry, we need to think differently about how we reduce the risk of COVID-19 to our construction teams. Consider these 10 tips for how best to manage a construction site for COVID-19 complications.

1. Determine your purpose and build a culture to support it

When we began this journey in January, it was clear that the pandemic would not only impact the health and well-being of our clients, subcontractors, and employees, but also the health of our industry and business. Our goal was to make sure everyone stayed healthy and employed—because the negative impact of losing a job is as real to our employees and their families as the virus itself.

So where do we start? With building a culture of trust.

Throughout the COVID-19 pandemic, trust has emerged as 1 of the most important elements for success. A professional environment that fosters unity and trust enables the response plans and processes that protect employees and clients.

If people trust each other, they will speak up when needed and share information that could save you some major headaches—or even lives. And when everyone on your project team is committed to the well-being of their associates, they are more likely to make safety-conscious decisions like:

  • Staying home if unwell,
  • Reporting possible exposures immediately, and
  • Practicing proper precautions because they do not want to risk exposing anyone else to the virus.

But the process of building that culture starts at the top. To be effective, leaders must engage the entire organization and support those in the field. Everyone needs to listen and also communicate their intentions, what they are open to, and what they think will or will not work.

With everyone on the same page, you can create a consistent culture and site response plan to reduce the risk of COVID-19 exposure for your employees, trade partners, clients, and community. It is the first step to keeping people safe and adhering
to regulations.

2. Establish clear lines of communication

Communication is key for any construction company, now more than ever. You have to keep lines of communication open between your project management, trade partners, and clients. Here are some standards we recommend:

  • Have every project site designate a primary communications representative to deliver all communications to the project team, trade partners, and client.
  • Have each project site identify a back-up communications representative in the event the main communications representative is unavailable.
  • Put up COVID-19 posters throughout the site.
  • Mandate that all information shared must be from credible and validated sources, such as the Centers for Disease Control and Prevention, OSHA, and the Department of Labor.
  • Develop and implement the proper communications vehicle to share updated policies, procedures, and changes.
  • Establish clear expectations on communication from subcontractors who were exposed to or tested positive for COVID-19.
  • Require over-communication between your team, subcontractors, and the client if any person stays home sick for any reason.
  • Mandate that site-wide communication is only sent by your primary or back-up communications representative.
  • Stipulate that subcontractors and sub-tier subcontractors must not send mass communications to anyone who is not a direct employee of the subcontractor.

3. Have employees work from home as much as possible

Given the contagious nature of the virus, construction companies should reduce the number of people at any 1 location. This will curb the spread of COVID-19. Each project manager should determine which on-site personnel have job functions that can be completed off site. Any person deemed not to be necessary on the site should work from home.

This protocol will allow all “site-necessary” workers the ability to practice social distancing and adhere to gathering limits.

4. Have a backup plan for all essential workers, materials, and equipment

Make sure that all project teams work with their organizations to identify backup personnel who could staff the project if a “site-necessary” person is not capable of coming to the site because of possible quarantine or because they were exposed to the virus outside of work.

You do not want progress to stall because someone vital has become ill and you do not have a plan B. What is the protocol for replacing staff, or a critical-path contractor, if they are impacted by the virus?

Work with your procurement organizations to stay in continuous communication with equipment and material suppliers. You want to ensure that delivery dates are not impacted; and, if they are, you know how to work around those challenges.

5. Abide by rules for social distancing and limited gatherings

Follow all government guidelines to help prevent and slow the spread of COVID-19. These include social distancing of at least 6 feet and limiting gatherings.

These regulations apply for:

  • Work areas,
  • Meetings,
  • Break areas, and
  • Offices and trailers.

Work areas

All work areas, inside and out, must follow the social distancing requirements and limit the number of people in a space. You might make this easier by:

  • Staggering shifts to reduce the number of workers,
  • Dividing areas into zones to limit workers in each zone,
  • Adding shifts to further separate work times, and
  • Segregating break times and locations to keep crews separated during breaks.


Even when employees are on site, use video or teleconferencing to conduct meetings. If meetings must be held in person, make sure they are in a building big enough to facilitate 6 feet of separation, or consider holding them outside.

Break areas

Break areas are subject to the same standards as any other location.

Offices and trailers

To mitigate the risk of exposure to or transfer of COVID-19, consider further safety measures, such as:

  • Not having more than 1 person in each office,
  • Not allowing people to congregate in the main area,
  • Putting posters up to remind everyone of the guidelines,
  • Having sufficient cleaning supplies and hand sanitizer available, and
  • Posting the contact list in an easily accessible location.

If possible, designate entrance and exit locations to segregate different populations (i.e., client, subcontract partners, etc.).

6. Establish rules for travel, visitors, and deliveries

Travel is one of the most common factors causing the spread of COVID-19. Here are some standards to consider to mitigate exposure.

Business travel

Only permit travel deemed critical to business continuity and require management approval.

If team members are working out of state and have to travel home, consider:

  • Can they reduce the frequency of their trips home?
  • Is it possible to have their spouse come to them and stay?
  • How can they limit their potential exposure when traveling to and from the site?

Personal travel

It is important that every construction company consider the effect that personal vacations could have on the safety of their personnel and community. Talk to your employees and trade partners about the impact travel can have on spreading the virus. We recommend that management review all employees’ personal travel plans.
Also, anyone who travels internationally or to a “hot zone” in the United States should not be allowed on a worksite within 14 days after their return.


Bringing visitors to a site introduces too many unknown factors, which is asking for trouble. Consider restricting all visitors from worksites without the prior approval of the site project manager. Only essential/critical visitors should be allowed on site (including client visitors, as well).

Create a health questionnaire for potential visitors to submit prior to coming on site and set clear standards of what is a deal-breaker for a site visit.


Review all deliveries prior to their arrival to determine where the items are coming from. Set a plan in place for deliveries coming from or passing through any country or U.S. city/state that is classified as a “hot zone.” Also, consider keeping all drivers and delivery activities segregated from the site workforce.

7. Know how to handle symptomatic employees

Any employee who is not feeling well or is showing any symptoms of an illness should stay home. The timeline before a worker should return to the site is dependent on several factors, but usually ranges from 3 to 14 days.

Consider excluding all employees from a project until they are symptom-free without the aid of medicine for 3 full days. You can make exceptions if:

  • They had a fever or cough and were positively diagnosed with anything other than COVID-19.
  • They received a COVID-19 test with a negative result.

Increase the time span to 14 days if they:

  • Had symptoms of COVID-19 but did NOT seek medical treatment or receive a COVID-19 test,
  • Sought medical treatment and tested positive for
    COVID-19, or
  • Refused to answer health declaration questions.

8. Be prepared for positive COVID-19 cases

There is a decent chance that an employee will test positive for COVID-19. If that happens, your team members should be prepared to:

  1. Have the infected employee leave the site immediately.
  2. Notify a supervisor and site management.

Then, management should:

  1. Suspend on-site work,
  2. Complete the COVID-19 contact tracing form,
  3. Quarantine anyone in contact with that employee,
  4. Arrange for thorough cleaning of all common areas to
    sterilize the site, and
  5. Communicate the situation to subcontractors and clients while protecting the identities of the impacted employees.

Do not wait until after it has already happened to put a plan
in place.

9. Train everyone on cleaning etiquette

By now, most people are aware of the personal hygiene needed to combat the spread of COVID-19. Nevertheless, it is worth providing further education to your employees, trade partners, and clients.


First, increase the number of handwashing stations on site. Then, make sure all personnel understand that they must:

  • Wash hands regularly with soap and water;
  • Wash hands for a minimum of 20 seconds;
  • Use hand sanitizer between washes; and
  • Always wash hands before and after breaks, and when arriving at or leaving a site.

Daily site cleaning

The COVID-19 virus can survive for extended periods on surfaces, so instruct project teams to:

  • Wipe down site common areas daily,
  • Wipe down commonly used tools and work platforms after each use and at the end of the day,
  • Wipe down each office/trailer before and after each shift every day, and
  • Wipe down all common surfaces in break rooms multiple times daily.

10. Work with the client to keep everyone informed and on the same page

Of course, there is no one-size-fits-all solution, especially when you factor in the needs and preferences of clients, trade partners, and others. Communication is everything.

Have site project managers talk to the client to develop answers to questions like:

  • What are the criteria for suspending work on a site?
  • How should the suspension be communicated to everyone involved?
  • What are the criteria for re-entering the site?
  • How will that be communicated to all involved?

Once you and the client have a common game plan in place, share it with everyone on the project and then stick to your standards.

You Do Not Have to Fly Blind

We are living through a confusing time right now, but that does not mean you have to wing it. There are concrete steps you can take to protect your company, your workers, your partners, and your clients. Follow these steps, and you will be on the right track to a safe, productive work environment.

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Ten years ago, a close friend of mine—let’s call him Paul—reached out to me. Paul worked as an executive at a local construction company. He was a gregarious and socially confident man who spent his free time with friends or at the gym. He volunteered as a mentor to younger men and worked to maintain a spiritual connection. From the outside, his life looked pretty good. We sat together over coffee as he told me his story.

“I don’t know what’s wrong with me,” Paul began. Beneath the despair, his voice reflected surprise.

This was the third time in his life that he had had thoughts of suicide, but this time was different. The first 2 times had occurred during Paul’s active alcoholism. Now, he had been sober for a dozen years and looked to be, by all accounts, quite successful. He was gainfully employed and had an active social life. Yes, he was a single parent with sole custody, but he had a great relationship with his teenage daughter. They lived in an affluent neighborhood. Paul admitted that his problems were “luxury problems”—he needed to replace their pool pump, for example.

But the darkness was closing in at an alarming rate. “And the scariest thing is, I don’t know why.” The night before, he spent 2 hours curled up on the living room
floor sobbing uncontrollably. Fortunately, his daughter had been at a friend’s house. “I need to pull it together,” Paul told me. “We just broke ground on 2 new projects totaling hundreds of millions of dollars. I can’t lose it now. People are counting on me.” He shook his head. “Men don’t get depressed. I mean, maybe small, weak men. But I have everything going for me. What the hell is wrong with me? Why can’t I just snap out of it?”

Paul felt comfortable confiding in me because he knew my story, my past experiences with alcoholism, depression, and suicidal ideation. In spite of this knowledge, I could see the shame and embarrassment on my friend’s face.

Depression is a serious mental disorder that affects millions and devastates tens of thousands of American lives every year. In 2017, for example, an estimated 11 million U.S. adults had at least 1 major depressive episode that included severe impairment.1 While I did not know it at the time, according to a report published by the Centers for Disease Control and Prevention (CDC), the construction and extraction industry has the highest suicide rate (for males) of any industry.2

An Industry-Wide Epidemic

Annually, more construction workers die from suicide than every other workplace-related fatality combined. In 2018, OSHA reported 1,028 construction deaths.3 The CDC reported that in 2015—the most recent statistics available—1,411 people in the construction and extraction industry committed suicide.4 The data cited by OSHA for those 2018 statistics reported 51 intentional deaths in the construction industry.5 The discrepancy is due to location: The 51 intentional deaths acknowledged by OSHA occurred at work. Suicide is an increasing concern in the construction industry as a whole, not focusing on any particular type of industry.

Though we rarely openly discuss the topic of depression and suicide in our industry, the epidemic is so pervasive that OSHA has added a section to its website providing resources for suicide prevention in the construction industry.6 (In addition to hotlines and helplines for those in need, the page includes resources for coworkers, managers, and industry associations.)

Because most suicides do not happen at work, many employers do not consider depression and suicide an industry problem or an occupational hazard. As a result, suicide prevention generally is not included in a company’s safety program or policy. And the epidemic is global: In the United Kingdom, male construction workers take their lives at 3.7 times the national average; in Australia, construction workers are 70% more likely to
commit suicide.7

With few procedures in place to prevent these deaths, our industry is failing its employees. Armed with these facts, the mental health and well-being of our employees is as vital as any other fit-for-duty check. Unfit workers, whether mentally or physically distressed, are a danger to themselves and others.

Risk Factors: A Culture of Silence

Why do so many construction workers take their own lives? As it turns out, several factors contribute to the high number of suicides. Statistically, men between the ages of 45 and 54 are most likely to kill themselves, regardless of occupation,8 and our industry heavily employs this demographic. Construction encourages a tough-guy attitude; a stigma of weakness surrounds depression and suicide, so many who suffer do not seek help. Construction sites do not tend to encourage diversity; good-natured banter often escalates to bullying or harassment. The transient nature and irregular hours of construction work also contribute to stress—seasonal layoffs, inconsistent pay, and limited access to healthcare exacerbate any life challenges.9 As a country, we are also facing an opioid crisis. Legitimate treatment of pain management can turn into abuse and addiction. In fact, according to the CDC, 25% of people receiving long-term opioid pain management struggle
with addiction.10

Man up, Soldier on

White men11 between the ages of 25 to 54 account for the bulk of all suicides. Therefore, it is not surprising that male-dominated industries (like construction) report a higher rate of suicide than most. According to the U.S. Bureau of Labor Statistics (BLS), 90% of U.S. construction workers are men12 between the ages of 25 and 54.13 Among this particular demographic, a pervasive machismo exists. Pressure to “act like a man” pervades the industry and often discourages those entertaining suicidal thoughts to seek help.14 Furthermore, harassment and bullying are woven into the fabric of toxic masculinity. According to an international study, one-third of construction workers experience workplace bullying.15

A Feeling of Disconnectedness

According to the Construction Industry Alliance for Suicide Prevention (CIASP), the very nature of construction work predisposes workers to suicidal ideation. “Moving from jobsite to jobsite can create an environment in which workers are not as connected to their families, each other, or a workplace community. Coupled with working long or irregular hours, sleep patterns can be impacted, causing sleep deprivation and mental and physical exhaustion.”16 Lack of sleep, limited or no access to reliable healthcare, and feelings of isolation—moving from site to site, losing touch with family and a home-base community—all contribute to the risk of developing anxiety and depression. Add to that seasonal layoffs or an economic downturn, and construction work becomes even more unpredictable. Job loss leads to lack of income, but it also eliminates health benefits and access to Employee Assistance Programs (EAPs). This feeling of a lack of control can blossom into hopelessness, leaving a worker with the thought, “I only see one way out.”

The recent COVID-19 pandemic caused global distress. Many construction workers were laid off as jobsites closed, and those required to report to work often experienced anxiety about exposure to the virus. A survey by Construction Dive revealed that 78% of contractors reported their biggest COVID challenge—the aspect of the crisis that most affected their business—was dealing with anxious employees.17

Drug and Alcohol Abuse

Not surprisingly, Paul and I fit right into the construction-worker demographic. White, middle-aged ex-football players who were taught to tough out the pain. Years of substance abuse (in my case, alcohol) compounded our struggles with depression.

Though alcohol is a depressant, people prone to substance abuse typically feel an opposite reaction when they drink—alcohol serves as an energy source. For the average temperate drinker, an alcoholic beverage or 2 brings a feeling of relaxation and calm (because it is a depressant). But alcoholics feel stimulated by alcohol. After a few drinks, they see the world more clearly and can often execute simple motor skills (billiards, darts, bowling—even operating a vehicle) more efficiently than when no alcohol is in their system. But it is a depressant, and alcohol eventually depresses both the physical body and mental state.

For me, drinking started with fun. It moved to fun with problems, then problems with fun. Eventually, the fun vanished, and alcohol left nothing but problems. It is no secret that alcohol and illicit drug use are prevalent throughout the construction industry. The National Drug-Free Workplace Alliance (NDWA) cited the construction and mining industries as having the highest rate of heavy alcohol use for full-time adult workers.18 This same survey determined that construction workers also have one of the highest rates of illicit drug use. Recently, however, the correlation between substance abuse and suicide has become more pronounced.

America’s Opioid Addiction

Illicit drug use and alcohol consumption significantly impact our industry. Though different chemicals affect the body differently, any substance abuse eventually takes its toll, causing physical, mental, and emotional damage to the user. Our nation’s growing opioid addiction has infiltrated all industries, and construction workers—already prone to on-the-job injuries—are no exception.

The Center for Construction Research and Training (CPWR) published a report regarding opioid use and overdose fatalities at worksites. The foreword includes the following disclaimer: “Section 1 examines a small subset of construction workers who died of an overdose: those who died on a worksite. These are figures for which we have national data, but there is not equivalent national data yet about how many of the 130 Americans who die each day from an opioid overdose work in construction.”19 Just as OSHA does not report on suicides in the industry unless they occur on the job, opioid use and drug overdoses are similarly underreported. The report states unequivocally, however, that “risk of overdose fatality and opioid use was higher in construction than in
other industries.”20

Many of us know someone who has struggled with addiction. Some recover, but many do not. Take Leo, for instance.

Leo and I worked at the same company some years ago. As a prerequisite to getting hired, Leo passed a pre-employment drug screen. He had been on the job about a month when he suffered a significant lower leg injury after falling approximately 5 feet off a ladder. During the initial investigation, we determined he had met all applicable safety requirements and adhered to all regulations. While managing the subsequent injury treatment and insurance claim, however, we learned that he had methadone in his system at the time of the incident.

Methadone, part of the opioid drug family, is often prescribed as a treatment protocol for heroin and narcotic pain medication addiction. While generally considered safer and less addictive21 than many opioids, methadone treatment is not without risk. Common side effects of methadone include anxiety and nervousness, restlessness, and drowsiness. More serious side effects include fainting, lightheadedness, and dizziness; hallucinations or confusion; seizures; and severe drowsiness.22

Could any of these side effects have contributed to Leo’s fall from a ladder? Absolutely.

During the incident investigation, a witness reported that Leo had complained of being tired that day; he had not gotten enough sleep the night before. The witness understood the common machismo of his coworker and figured this was just another typical day working in the field. Maybe it was lack of sleep, or maybe it was a side effect of the methadone; we will never know.

Leo’s injury recovery progressed fairly quickly, and he returned to work before any lost-time took effect—good news for him and for our employer. He maintained his income, allowing him to support his wife and their toddler, while our employer saw the return-to-work program functioning as intended: maintaining employee productivity.

But Leo experienced a minor setback while recovering from his lower leg injury. We spoke during this time, and I learned that Leo also suffered from depression. He believed it stemmed from a previous sports-related injury that significantly impacted his physical, mental, and emotional health. According to Leo, that injury eventually led to a painkiller addiction, which intensified his depression.

Leo declined the offer to contact our employer’s EAP. I shared my own experience around alcohol dependence (and how I recovered), but Leo was not interested in pursuing rehabilitation. Our employer eventually fired Leo for repeated and unexpected absenteeism, and he and I lost touch.

A few months later, I received word that Leo had taken his own life.

The Financial Cost to Employers

Obviously, any loss of life is a horrific tragedy. But in addition to the human cost, suicide and depression take a significant financial toll on our industry.

Substance abuse, whether it leads to suicidal ideation or not, costs employers millions each year. Workers impaired by drugs or alcohol cause serious damage to businesses. According to the NDWA, these employees have increased absenteeism, lower productivity, higher healthcare costs, higher workers’ compensation claims, and more on-the-job injuries and incidents.23 In order to maintain a safe and productive work environment, employers must take action to stop substance abuse. A substance abuse testing program is often the cornerstone of this initiative. (For help implementing a substance abuse testing program, contact your insurance provider.)

A 2016 study published in Suicide and Life-Threatening Behavior, the official journal of the American Association of Suicidology, reported that the total national cost of suicides and
suicide attempts in the United States exceeded $93.5 billion.24 Lost productivity accounts for the majority of that number. As the construction industry accounts for 20% of the nation’s suicides, we, as a group, are losing approximately $18.7 billion a year to this epidemic in lost productivity alone.

Moving Forward: Solutions

Paying Attention

While an ounce of prevention may be worth a ton of cure, in the case of suicide, prevention is the only option. A company’s financial, organizational, hazard, and strategic risk are all impacted by the mental well-being of its workforce. As an industry, we must address mental health and wellness at a grassroots level.

New Hires

Our industry frequently performs background checks, pre-employment drug screening, and physical fitness reviews. Including a mental health questionnaire on employee risk assessments may shed light on potential problems before they claim the life of the employee. For example, an employee states that he can lift 25 pounds over his head repeatedly without difficulty, or that he can stand for extended periods in extreme climates. Why do we not ask if he has ever suffered from claustrophobia? If working in tight areas causes extreme distress or panic, we should know this before sending him into a confined space.

Should we eliminate prospective hires if we have concerns about their mental wellness? Absolutely not. This is not meant to serve as a discriminatory tool. But if a new hire reports a fear of heights, he should not be assigned to build scaffolds. Maybe he is better suited to forklift operation. The goal is that every new hire succeeds in the organization. With the culture of machismo that exists on construction sites, many men would rather tough it out than talk about their fears or anxieties.25 But stress and anxiety cause heightened cortisol levels, and chronically raised levels take their toll on both physical and mental health.26 And what helps us relax? Drugs and alcohol.

Ongoing Support and Wellness Programs

A strong correlation exists between physical health and mental fitness. Harvard Medical School reported a striking comorbidity between chronic pain and depression.27 According to the study, people suffering from chronic pain are 3 times more likely than the general population to develop psychiatric symptoms. Further, depressed patients are 3 times more likely to develop chronic pain. Leo recalled that his depression began only after his sports injury (which resulted in chronic pain).

Even employees without chronic pain will experience sore muscles and achiness from time to time; it is a byproduct of construction work. Employers can encourage healthy habits to treat and manage pain and stress by providing available resources. Many construction companies have pre-shift stretching sessions, but what about post shift? Most athletes know to stretch after a workout; the physical demands placed on a construction worker’s body warrant attention, as well.

What about diet and nutrition? A meta-analysis (including 21 studies across 10 countries) published in Psychiatry Research found a correlation between a Western diet and an increased risk of depression.28 Take a look at the food trucks around construction sites: burgers, burritos, pizza. Day after day, month after month, year after year, poor nutrition and the physical stresses of construction work add up. Rather than treating the stress with pain medication or a few beers after work, can your organization take proactive measures? Seek out healthier food truck options, or provide vending machines stocked with healthy snacks.

Executive buy-in is key when developing a successful mental and emotional wellness program within your organization. Encourage open and honest discussions about mental health and suicide. Be proactive in assisting your employees’ mental well-being. Top-down leadership is necessary; work with your human resources (HR) department and EAP provider. We can break the macho stereotyping of our workforce. One person can make a significant difference, and as those singularities unite, it creates a movement—a movement that may prevent the suicide of someone you love and value.

Eliminating the Stigma

Leo, Paul, and I walked similar paths. For me, seeking a solution for my alcoholism and underlying depression saved my life. Leo chose not to treat either condition. My journey led to a 12-step recovery program and personal therapy. These worked for a while. But, like Paul, I experienced a recurrence of depression well into sobriety.

Depression, suicidal ideation, addiction, and other mental health conditions often present life-long challenges. I have never known anyone to recover from these conditions alone. Often, support must continue for years—or longer, depending on the condition. Talk therapy, 12-step programs, inpatient treatment, medication—every avenue must be made available to those suffering from suicidal ideation. For some, joining a church or civic group works as a mood-booster: helping others takes us out of ourselves. Immediate emergency medical care may be needed in certain cases, as well.

To regulate my mood, I continue to take an active role in my recovery from alcoholism. Paul’s doctor referred him to a psychiatrist. Paul needed medication to help regulate his brain chemistry, just as diabetics need insulin or cardiac patients require a statin. One of the goals of this article is to normalize the discussion around mental wellness. Let us eliminate the shame of seeing a therapist or needing psychotropic medication. Create an atmosphere of trust and openness in your organization.29 Arm your HR department with resources. Train your foremen to recognize signs of substance abuse, depression, and suicidal behavior. Teach them to take action. (Resources are listed at the end of this article.)

What Can I Do for My Employees Today?

Following the CDC’s alarming report regarding the high suicide rates in the construction industry, the Construction Industry Alliance for Suicide Prevention (CIASP)30 was formed. CIASP provides information, resources, and training to the construction industry, with the goals of eliminating the stigma associated with suicide and mental health issues, as well as offering relevant and implementable tools.

CIASP, a nonprofit organization, suggests that suicide awareness and mental health fitness be addressed on several levels. Raising awareness is not sufficient; as employers, we should offer resources for those in need, create a culture in which it is acceptable to discuss mental health concerns, and do what we can to decrease the inherent risks present in our industry. CIASP coined the phrase STAND up for suicide prevention.

S – creating safe cultures
T – providing training to identify and help those at risk
A – raising awareness about the suicide crisis in construction
N – normalizing conversations around suicide and mental health
D – decreasing the risks associated with suicide in construction31

CIASP offers (free of charge) a suite of integration tools to incorporate suicide prevention and mental health awareness into your company’s existing safety policy. Begin with the “Mental Health & Suicide Prevention for Construction Companies: Needs Analysis & Integration Checklist”32 to determine your current level of preparedness. This worksheet provides questions to assess your company’s mental health culture, as well as action steps to implement a more rigorous mental health and suicide prevention safety plan. Follow the checklist with CIASP’s “Three Levels of Integrating Suicide Prevention in Your Company”33 packet.

CIASP’s Integration Resources page34 also includes tools for prevention, intervention, and post-intervention; resources for veterans; and a link to extensive opioid-related issues and statistics.35 From this page, access, download, and immediately incorporate reproducible toolbox talks, wallet cards, posters, and more.

CIASP offers myriad resources, many of which are self-explanatory and easy to incorporate (like the toolbox talks). If you need assistance creating a more robust and dedicated initiative, contact CIASP directly. You can join the cause by standing up for suicide prevention today.

The author would like to thank CIASP for its input on this article.


Please seek help if you are suffering. You are not alone. The following services are free and confidential.

National Suicide Prevention Lifeline: 24 hours a day, 7 days a week, 365 days a year

Added July 2022: 988 has been designated as the new three-digit dialing code that will route callers to the National Suicide Prevention Lifeline. While some areas may be currently able to connect to the Lifeline by dialing 988, this dialing code will be available to everyone across the United States starting on July 16, 2022. 

Call: 1-800-273-8255
Para espanõl: 1-888-628-9454
Deaf and hard of hearing: 1-800-799-4889
Online chat:
Crisis Text Line: text HOME to 741741

Veterans Crisis Line: For Veterans, active duty members of the military, or those concerned about one; 24/7 services
Call: 1-800-273-8255 (press 1)
Text: 838255
Deaf and hard of hearing: 1-800-799-4889
Online chat:

Substance Abuse and Mental Health Hotline (SAMHSA’s National Helpline): 24/7 information service for individuals and family members facing mental and/or substance use disorders. English and Spanish.
Call: 1-800-662-4357
TTY: 1-800-487-4889

Alcoholics Anonymous (AA): AA is a fellowship of men and women who share their experience, strength, and hope to help others recover from alcoholism. Access multilingual online meetings or connect with someone who can help with your drinking problem.
Online meetings:
Find local A.A. resources:

Narcotics Anonymous (NA): If you think you have a problem with drugs, NA can help. Find meetings and helplines in your community.

Thank you to CIASP for their input on this article. To access additional resources or make a tax-deductible donation, please contact CIASP directly. Call (609) 799-7900, email, or visit


  1. “Major Depression,” National Institute of Mental Health (NIMH),
  2. Peterson C., et al., “Suicide Rates by Major Occupational Group – 17 States, 2012 and 2015,” Morbidity and Mortality Weekly Report (MMWR) 67,
  3. U.S. Department of Labor, “Commonly Used Statistics,” OSHA,
  4. Peterson C., et al., “Suicide Rates by Major Occupational Group – 17 States, 2012 and 2015,” MMWR 67,
  5. U.S. Department of Labor, “Injuries, Illnesses, and Fatalities,” U.S. BLS,
  6. U.S. Department of Labor, “Preventing Suicides,” OSHA,
  7. Chesterfield, Peter, “It’s Past Time to Build Better Mental Health in the Construction Industry,” BRINK,
  8. “Suicide Statistics,” American Foundation for Suicide Prevention (AFSP),
  9. “Suicide in the Construction Industry: Breaking the Stigma and Silence,” American Society of Safety Professionals,
  10. U.S. Department of Health and Human Services, “Promoting Safer and More Effective Pain Management,” CDC,
  11. “Suicide Statistics,” AFSP, It is worth noting that the study identifies the following racial groups: White, Black or African American, and Asians and Pacific Islanders. AFSP adds, “Note that the . . . CDC records Hispanic origin separately from the primary racial or ethnic groups of White, Black, American Indian or Alaskan Native, and Asian or Pacific Islander, since individuals in all groups may also be Hispanic. Overall, across groups, the rate of suicide for non-Hispanics was 16.42 and the rate for Hispanics was 7.20.”
  12. U.S. Department of Labor, “Labor Force Statistics from the Current Population Survey: Employed Persons by Industry, Sex, Race, and Occupation,” U.S. BLS,
  13. U.S. Department of Labor, “Labor Force Statistics from the Current Population Survey: Employed Persons by Detailed Industry and Age,” U.S. BLS,
  14. Chesterfield, Peter, “It’s Past Time to Build Better Mental Health in the Construction Industry,” BRINK,
  15. “Preventing Bullying in the Construction Industry,” GoContractor (blog),
  16. “Build Awareness,” CIASP,
  17. Goodman, Jenn, “How to Ease Workers’ Anxieties about Returning to the Jobsite,” Construction Dive,
  18. “Industry Statistics,” NDWA,
  19. Dong, Xiuwen Sue, Raina D. Brooks, and Chris Trahan Cain, “Overdose Fatalities at Worksites and Opioid Use in the Construction Industry,” CPWR: Quarterly Data Report (2019),, 1.
  20. Dong, Xiuwen Sue, Raina D. Brooks, and Chris Trahan Cain, “Overdose Fatalities at Worksites and Opioid Use in the Construction Industry,” CPWR: Quarterly Data Report (2019),, 2.
  21. U.S. Department of Health and Human Services, “Methadone,” Substance Abuse and Mental Health Services Administration
  22. Cunha, John P., “Methadone Hydrochloride,” RxList,
  23. “The Importance of Workplace Drug Prevention,” NDWA,
  24. Shepard, Donald S., et al., “Suicide and Suicidal Attempts in the United States: Costs and Policy Implications,” Suicide and Life-Threatening Behavior 46.3 (2016): 352-362,
  25. While this article refers to men in the construction industry, these same concerns surround women, though the rate of suicide among women in construction is around 1% (as opposed to the 20% of male suicide decedents in the industry). Source:
    Peterson C., et al., “Suicide Rates by Major Occupational Group – 17 States, 2012 and 2015,” MMWR 67,
  26. “Chronic Stress Puts Your Health at Risk,” Mayo Clinic,
  27. “Depression and Pain,” Harvard Health Publishing: Harvard Medical School,
  28. Li Y., et al., “Dietary Patterns and Depression Risk: A Meta-Analysis,” Psychiatry Research 253 (2017): 373-382,
  29. After an employee committed suicide, RK, a construction company, incorporated suicide prevention measures as part of its company culture. Noguchi, Yuki, “A Construction Company Embraces Frank Talk About Mental Health to Reduce Suicide,” NPR,
  30. CIASP,
  31. “STAND UP for Suicide Prevention,” CIASP,
  32. “Mental Health & Suicide Prevention for Construction Companies: Needs Analysis & Integration Checklist,” CIASP,
  33. “Three Levels of Integrating Suicide Prevention in Your Company,” CIASP,
  34. “Integration Resources: Implement a Suicide Prevention Program in the Workplace,” CIASP,
  35. “Opioid Resources: Resources to Prevent Opioid Deaths in Construction,” CPWR,

This manual includes statistics, risk factors, checklists, toolbox talks,and resources for next steps: “A Construction Industry Blueprint:Suicide Prevention in the Workplace.” National Action Alliance for Suicide Prevention.

Suicide Prevention Lifeline’s free, reproducible wallet cards (in English and Spanish) and 1‑pager on warning signs and what to do if you suspect someone is considering suicide: “Media Resources.” Suicide Prevention Lifeline.

Reproducible Opioid Deaths in Construction Hazard Alert.” CPWR.

Resources for the prevention of substance abuse and mental disorders, including workforce training and education: “Prevention of Substance Use and Mental Disorders.” SAMHSA.

A multi-pronged approach to addressing suicide in the workplace and community: Stone, Deb, Kristin Holland, Brad Bartholow, Alex Crosby, Shane Davis, Natalie Wilkins. “Preventing Suicide: A Technical Package of Policy, Programs, and Practices.” CDC.

Crisis line contact information, risk factors and warning signs,and industry-specific resources:“Preventing Suicides.” OSHA.

A comprehensive, actionable plan for construction companies implementing a suicide prevention plan: Spencer-Thomas, Sally. “Construction + Suicide Prevention: 10 Action Steps Companies Can Take to Save Lives.” Construction Financial Management Association (CFMA).

Find out where to get help, how to start a conversation, information on trainings and programs, statistics, international programs, and more: “Suicide Prevention Resources.” CPWR.

“Build Awareness.” CIASP.

Chesterfield, Peter. “It’s Past Time to Build Better Mental Health in the Construction Industry.” BRINK.

“Chronic Stress Puts Your Health at Risk.” Mayo Clinic.


Cunha, John P. “Methadone Hydrochloride.” RxList.

“Depression and Pain.” Harvard Health Publishing, Harvard Medical School.

Dong, Xiuwen Sue, Raina D. Brooks, and Chris Trahan Cain. “Overdose Fatalities at Worksites and Opioid Use in the Construction Industry.” CPWR: Quarterly Data Report (2019). Accessed May 13, 2020.

Goodman, Jenn. “How to Ease Workers’ Anxieties about Returning to the Jobsite.” Construction Dive.

“Industry Statistics.” NDWA.

“Integration Resources: Implement a Suicide Prevention Program in the Workplace.” CIASP.

Li Y., Lv M., Wei Y., Sun L., Zhang J., Zhang H., Li B. “Dietary Patterns and Depression Risk: A Meta-Analysis.” Psychiatry Research 253 (2017): 373-382.

“Major Depression.” NIMH.

“Mental Health & Suicide Prevention for Construction Companies: Needs Analysis & Integration Checklist.” CIASP.

Noguchi, Yuki. “A Construction Company Embraces Frank Talk About Mental Health to Reduce Suicide.” NPR.

“Opioid Resources: Resources to Prevent Opioid Deaths in Construction.” CPWR.

Peterson C., Stone D.M., Marsh S.M., Schumacher P.K., Tiesman H.M., McIntosh W.L., Lokey C.N., Trudeau A.T., Bartholow B., Luo, F. “Suicide Rates by Major Occupational Group – 17 States, 2012 and 2015.” MMWR 67 (2018): 1253-1260.

“Preventing Bullying in the Construction Industry.” GoContractor (blog).

Shepard, Donald S., et al. “Suicide and Suicidal Attempts in the United States: Costs and Policy Implications.” Suicide and Life-Threatening Behavior 46.3 (2016): 352-362. Accessed May 13, 2020.

“STAND UP for Suicide Prevention.” CIASP.

“Suicide in the Construction Industry: Breaking the Stigma and Silence.” American Society of Safety Professionals.

“Suicide Statistics.” American Foundation for Suicide Prevention.

“The Importance of Workplace Drug Prevention.” NDWA.

“Three Levels of Integrating Suicide Prevention in Your Company.” CIASP.

U.S. Department of Health and Human Services. “Methadone.” SAMHSA.

U.S. Department of Health and Human Services. “Promoting Safer and More Effective Pain Management.” CDC.

U.S. Department of Labor. “Commonly Used Statistics.” OSHA.

U.S. Department of Labor. “Injuries, Illnesses, and Fatalities.” BLS.

U.S. Department of Labor. “Labor Force Statistics from the Current
Population Survey: Employed Persons by Detailed Industry and Age.” BLS.

U.S. Department of Labor. “Labor Force Statistics from the Current
Population Survey: Employed Persons by Industry, Sex, Race, and
Occupation.” BLS.

U.S. Department of Labor. “Preventing Suicides.” OSHA.


Copyright statement

This article was published in the August 2020 issue of Insulation Outlook magazine. Copyright © 2020 National Insulation Association. All rights reserved. The contents of this website and Insulation Outlook magazine may not be reproduced in any means, in whole or in part, without the prior written permission of the publisher and NIA. Any unauthorized  duplication is strictly prohibited and would violate NIA’s copyright and may violate other copyright agreements that NIA has with authors and partners. Contact to reprint or reproduce this content.

Disclaimer: Unless specifically noted at the beginning of the article, the content, calculations, and opinions expressed by the author(s) of any article in Insulation Outlook are those of the author(s) and do not necessarily reflect the views of NIA. The appearance of an article, advertisement, and/or product or service information in Insulation Outlook does not constitute an endorsement of such products or services by NIA. Every effort will be made to avoid the use or mention of specific product brand names in featured magazine articles.

Since states began easing up on stay-at-home orders and other pandemic restrictions, one of the most contentious issues has been the use of cloth face coverings. Conflicting early guidance from public health organizations and mixed messaging from leadership have only added to the debate. However, both the Centers for Disease Control and Prevention and the World Health Organization are now unequivocal that the use of cloth face coverings is one of the most important public health measures we can take to stop the spread of the severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2), the virus that causes COVID-19.

Many in the insulation industry are familiar with the rules and requirements for wearing respiratory protection. Employees in tight-fitting facepiece respirators must be fit-tested every year. Users must be clean shaven. Particulate filters must be certified as effective against particle sizes down to 0.3 microns. Users must do a seal check every time they put the respirator on. And the list of rules goes on. Understandably, some people who are used to these rules are now confused when we tell them that a face mask fashioned from an old bandanna is all they need to protect against something as small as an airborne virus.

Therein lies one of the biggest misconceptions about the use of cloth face coverings. A cloth face covering is not personal protective equipment like a half face respirator or an N95 mask. A cloth face covering is not meant to protect you; it is meant to protect others around you.

Most transmission of the coronavirus is from person to person, and in almost half of the cases, the person spreading the disease did not even know they were infected. Recent studies show that 40% to 45% of infections are spread by asymptomatic or pre-symptomatic individuals—that is, people who do not even know they are a risk to others.

How it Works

A cloth face covering is like a respirator in reverse. When you wear a respirator, you are filtering contaminants out of the air so they do not get into your lungs. When you wear a cloth face covering, you are filtering (or catching) the potentially infectious stuff in your lungs so it does not get into the air. When an infected person coughs, sneezes, talks, or even just breathes, they exhale respirable droplets containing the coronavirus. The droplets are many times larger than the virus particles themselves, and they are effectively blocked by a cloth face covering.

A cloth face covering is up to 99% effective at blocking potentially infectious respiratory droplets. Widespread use of cloth face coverings can significantly reduce infection rates, which is key to stopping the outbreak.

Respirators stop us from breathing bad stuff in; face coverings stop people from breathing bad stuff out. [Note that N95 masks and other respirators with an exhalation valve let out unfiltered breath and potentially infectious droplets, so they should not be used for “source control.”]

Wear a cloth face covering anytime you are in public and not able to maintain social distancing of at least 6 feet. This protects the people around you, including those that may be at higher risk of severe illness. Remember, you may be infectious and not even know it.

Also, do not be that person with the mask only around your mouth or down below your chin; wear it covering both your mouth and nose.

Here are a few face mask precautions:

  • Do not put masks on people who have trouble breathing or are incapacitated,
  • Do not put masks on children under 2 years old, and
  • Do not use face masks as a substitute for social distancing.

The Bottom Line

We in the construction industry, have always known that wearing a mask is about safety, and that has not changed. Wearing a mask is not infringing on anybody’s personal freedoms, and it is not a political statement; it is a safety concern and is for the public good. Do not think of mask wearing as government overreach; think of it as solidarity—we are all in this together. My mask protects you; your mask protects me. If we all band together, we can stop this pandemic in its tracks. Do your part and be a responsible citizen. A little inconvenience now will mean a quicker return to normal for all of us.

Copyright statement

This article was published in the August 2020 issue of Insulation Outlook magazine. Copyright © 2020 National Insulation Association. All rights reserved. The contents of this website and Insulation Outlook magazine may not be reproduced in any means, in whole or in part, without the prior written permission of the publisher and NIA. Any unauthorized  duplication is strictly prohibited and would violate NIA’s copyright and may violate other copyright agreements that NIA has with authors and partners. Contact to reprint or reproduce this content.

Disclaimer: Unless specifically noted at the beginning of the article, the content, calculations, and opinions expressed by the author(s) of any article in Insulation Outlook are those of the author(s) and do not necessarily reflect the views of NIA. The appearance of an article, advertisement, and/or product or service information in Insulation Outlook does not constitute an endorsement of such products or services by NIA. Every effort will be made to avoid the use or mention of specific product brand names in featured magazine articles.

Confidentiality of Injury and Illness Records

On June 4, 2020, Magistrate Donna M. Ryu ruled against the Department of Labor (DOL) in the case of the Center of Investigative Reporting v. DOL and held that employer injury and illness records filed with OSHA are not confidential and can be obtained by the media and/or just about anyone else under a Freedom of Information Act request. The decision seems to be based in some part on the 2016 rule proposed by OSHA (under then Assistant Secretary Dr. David Michaels) that was not adopted and that would have posted all such records filed with OSHA on the OSHA website. This was referred to in 2016 as the “shaming rule” for obvious reasons. The rule did not reach the final rule stage, but now Magistrate Ryu has brought back at least some of what Dr. Michaels was trying to accomplish at
that time.

In addition to the above, the D.C. Circuit Court of Appeals dismissed the attempt by the American Federation of Labor and Congress of Industrial Organizations (AFL-CIO) to force OSHA to promulgate an emergency temporary standard on the COVID-19 pandemic. This decision was made by a 3-judge panel of the court. The AFL-CIO has filed for an en banc hearing to have all of the judges of the D.C. Circuit hear and participate in a ruling on the case.

Working with Subcontractors

Be careful with how you treat the employees of subcontractors (subs) regarding safety compliance. Be sure you address this issue in your contract with your subs. Make sure you have a clear procedure for ensuring the safety compliance you require in your contract with your subs. In most cases, I suspect that you have procedures that maintain an arms-length relationship with your subs, so be sure any employee you have in charge of overseeing the work of your subs strictly and consistently follows those procedures. I recently became aware of a situation in which a company was cited for a fall protection violation where OSHA has taken the position that the contractor had a duty to ensure (i.e., guarantee) the safety of the sub’s employees. The OSHA compliance officer intercepted the principal’s employee while he was on his way to advise the site supervisor for the sub about the safety infraction. OSHA has taken the position that the contractor’s site supervisor should have dealt directly with the individual employees of the sub, rather than going to their supervisor.

Multistate Operations

If you are a contractor who works in multiple states, or a company covered by the general industry standards and have facilities in more than 1 state, you must be in compliance with the OSHA standards for all state-plan states in which you may work. For example, in Utah, a company with an employee who has a serious injury must report to Utah OSHA within 8 hours, even if the employee was not hospitalized. The state of Washington not only requires you to determine the integrity of walking/working surfaces (Federal OSHA standard at 1926.501(a)(2)), but also requires you to guarantee that the walking/working surface will support the weight of the employee who will work on it and his/her equipment. Regarding the pandemic, Nevada has promulgated an emergency temporary standard limiting the number of employees in an aerial lift, scissors lift, or JLG basket to 1 person.

In summary, remember that you are not just bound to the safety regulations in the state in which you are headquartered or in which you have your principal facility, but also to those in other states to which you send employees or in which you open new facilities.

COVID-19 Guidance

In the absence of a temporary emergency OSHA standard relating to COVID-19, OSHA continues to issue guidance and enforce safety and health practices under the general duty clause. OSHA issued more guidance for construction contractors in June, advising employers to perform a job hazard analysis (JHA) at the beginning of each work day to determine whether the work for the upcoming day will place them in the lower, medium, or high risk category, and then act appropriately with engineering and/or administrative controls. I recently heard comments from a New England federal OSHA compliance officer that he expects the construction company to reevaluate its work, as far as exposure potential, throughout the day, and adjust safeguards appropriately. The implication here is that whenever conditions on the site change in any way, a new JHA should be performed.

OSHA has defined lower risk for construction as work that allows workers to remain 6 feet apart with little contact with the public. Medium risk work requires workers to be within 6 feet of each other and with customers, visitors, and the public. High risk are those sites occupied by other workers, customers, or residents suspected or known to have COVID-19. In the guidance, OSHA lists engineering controls such as closing doors whenever possible or erecting barriers such as plastic sheeting. OSHA recommends that employers continually reassess these barriers. For administrative controls, employers should follow CDC guidance and train employees on the spread of the disease.

Recommended training is extensive. It includes such things as training employees to recognize the signs and symptoms of COVID-19, and how the disease is spread. You should also train employees in all policies and procedures applicable to the employee’s duties, and provide information on social distancing and personal protective equipment. Remind employees to stay home if sick, how to properly wear face coverings, and how to use Environmental Protection Agency-approved cleaning chemicals. As with all other safety issues, you need to determine how to apply your progressive safety program to COVID-19 pandemic issues.

The above measures are what OSHA considers to be “feasible” recommendations or guidance. For OSHA to allege a violation of the general duty clause, it must prove that an employer did not implement feasible work practices, administrative controls, and engineering controls. So, if you determine that any of this guidance is not feasible or creates a greater hazard, you should document the analysis that led to your conclusion in case you are cited for a general duty clause violation. An example of greater hazard might be an increased risk of a heat-related illness created by requiring employees to wear face coverings in a high or extremely high heat index environment.

As you can see, even though we do not have an emergency temporary standard from federal OSHA, we can see that we are dealing with an ever-changing landscape.


Copyright statement

This article was published in the August 2020 issue of Insulation Outlook magazine. Copyright © 2020 National Insulation Association. All rights reserved. The contents of this website and Insulation Outlook magazine may not be reproduced in any means, in whole or in part, without the prior written permission of the publisher and NIA. Any unauthorized  duplication is strictly prohibited and would violate NIA’s copyright and may violate other copyright agreements that NIA has with authors and partners. Contact to reprint or reproduce this content.

Disclaimer: Unless specifically noted at the beginning of the article, the content, calculations, and opinions expressed by the author(s) of any article in Insulation Outlook are those of the author(s) and do not necessarily reflect the views of NIA. The appearance of an article, advertisement, and/or product or service information in Insulation Outlook does not constitute an endorsement of such products or services by NIA. Every effort will be made to avoid the use or mention of specific product brand names in featured magazine articles.

In the July issue of Insulation Outlook, Auman, Mahan and Furry attorneys Abbie White and Gary Auman addressed OSHA guidance concerning the recording of COVID-19 cases. As the pandemic continues, Abbie White addresses employers’ questions.

Do I need to record an employee’s case of COVID-19 on my OSHA log?

This section applies to all employers with 11 or more employees. OSHA has stated that COVID-19 is a recordable illness and must be recorded on an employer’s 300 log if the following 3 criteria are met:

  1. The employee has a confirmed case of COVID-19, as defined by the Centers for Diseases Control and Prevention (CDC)—meaning that the employee has had at least 1 respiratory specimen that tested positive for SARS-CoV-2;
  2. The case is work related as defined by 29 CFR 1904.5; and
  3. The illness results in death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, loss of consciousness, or is a significant injury or illness diagnosed by a physician or other licensed healthcare professional.

The first step simply requires that you determine whether your employee has tested positive for COVID-19. If the answer is “no,” you will not record the illness on your 300 log. An employee report of symptoms, without a confirmed positive test, is not sufficient to make an illness recordable. But now that COVID-19 tests are easier to come by in most locations, we should expect to see more employees with confirmed positive cases.

Assuming your employee has tested positive for COVID-19, you must move on to the second step and determine whether the illness is work related. This can be tricky, depending on whether there are other cases of COVID-19 in your workforce, and whether there is community spread of the virus in your area.

To comply with the recordkeeping requirements of 29 CFR 1904, employers must make a “reasonable determination” as to whether an employee’s COVID-19 case is work related. To make a “reasonable determination,” you must first ask your employee how he believes he contracted the illness. Your employee’s answer is likely to fall into 1 of 3 categories: (1) your employee believes he contracted the virus from someone outside of work; (2) your employee believes he contracted the virus at work; or (3) your employee will not know how he contracted the virus. If your employee reports that he contracted the virus outside of work (for example, he reports that he caught it from close contact with a friend or relative known to have COVID-19), your inquiry can probably stop with this information, unless you also have known COVID-19 spread within your workforce.

But, if your employee reports that he does not know where he contracted the virus, or that he believes he was exposed to the virus at work, you must proceed to ask follow-up questions about the employee’s in- and out-of-work activities. During this inquiry, you must be mindful of the employee’s privacy and avoid questions that could expose you to liability under the Americans with Disabilities Act, Title VII of the Civil Rights Act of 1964, Age Discrimination in Employment Act, etc. For example, you could ask your employee if anyone he lives with has tested positive for COVID-19, whether he has been in close contact (within 6 feet for more than 15 minutes) of a person known to have COVID-19, whether he has recently attended any large gatherings, and similar generic questions. You may find it helpful to prepare—in advance—a list of questions you will ask employees who report COVID-19 cases. You might also wish to have your questions reviewed by your employment counsel to ensure your questions will not violate one of the many other laws that employers are required to comply with concerning employee privacy, protected status, etc.

Last, you should review the employee’s work environment for potential sources of exposure. According to OSHA, cases are “likely work related” when there is no alternative explanation other than workplace exposure, and 1 of the following conditions is true: (1) several cases develop among workers who work closely together; (2) the virus is contracted shortly after a lengthy and close exposure to a customer or coworker who has the virus; or (3) the employee’s job duties involve frequent and close exposure to the general public in a locality with ongoing community transmission. On the other hand, an employee’s COVID-19 illness is likely not work related if the employee is the only worker in his work area to contract the virus; his job duties do not include frequent contact with the general public; or if the employee, outside of work, closely associates with someone who has COVID-19.

You should be prepared to undertake this inquiry for COVID-19 cases reported by your own employees, as well as workers (not employed by you) that you supervise and/or control. For example, if you have temporary workers on your jobsite, or if you exercise control over a subcontractor’s employees, you will be required to record their
work-related COVID-19 cases on your OSHA log unless the temporary employment agency agrees to log it on their 300 log. Remember, it must be recorded on 1 log or the other, so this is something you might want to deal with in your contract with the temporary employment agency—see 29 CFR 1904.31(b)(2) and 1904.31(b)(4). You will need to make a reasonable determination as to the work-relatedness of those cases as well.

You must only record the case of COVID-19 if it is “more likely than not” work related. If you have conducted a reasonable investigation into the work-relatedness of the illness and cannot determine whether a workplace exposure played a causal role, the illness is not recordable. If it is a close call, and you decide not to record the illness, you would be well served to document the reasons you decided not to record the illness on your log.

You will have 7 days to record a case on your OSHA log. Thus, you will have about a week to investigate the source of the employee’s illness and make your “reasonable determination” as to work-relatedness. If you initially determine that a case is not work related, but later learn that it is, you must record the illness at that time. To avoid a potential OSHA citation for untimely recording, you should document the reason you initially determined the illness was not work related in addition to the date you learned information suggesting otherwise. Further, if you initially determine that the illness is work related, but later learn that it is not, you should line through the entry on your OSHA log. (Do not erase it!)

Assuming that your employee tested positive for COVID-19 and you have determined the illness is work related, you will need to determine whether the illness meets 1 of the other recording criteria (i.e., resulting in death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, loss of consciousness, or the illness is a significant injury or illness diagnosed by a physician or other licensed health-care professional). Cases of COVID-19 will virtually always result in days away from work; thus, there will be few, if any, situations where the third recording criterion is not met.

As always, the obligation to record work-related cases of COVID-19, along with other illnesses and injuries, only applies to employers with more than 10 employees in a calendar year.

Do I need to report a case of COVID-19 to OSHA?

This section applies to employers of any size. Only serious illnesses and injuries must be reported to OSHA—i.e., injuries and illnesses resulting in death, in-patient hospitalization, amputation, and/or loss of an eye. Although work-related COVID-19 infections may result in hospitalization or even death, they are only reportable to OSHA under certain circumstances. A hospitalization must only be reported if the employee is admitted to the in-patient unit of the hospital for treatment within 24 hours of the work-related incident (i.e., exposure). It will likely be difficult to determine when an employee’s work-related exposure occurred, and thus, difficult to determine whether the hospitalization occurred within 24 hours for purposes of reporting. If an employee dies from a work-related case of COVID-19, the death is reportable if it occurs within 30 days of the work-related exposure.

Editor’s note: For more on this topic, see “OSHA Raises the Bar for Investigating the Work-Relatedness of COVID-19 Cases” in the July 2020 issue of Insulation Outlook.

Copyright statement

This article was published in the August 2020 issue of Insulation Outlook magazine. Copyright © 2020 National Insulation Association. All rights reserved. The contents of this website and Insulation Outlook magazine may not be reproduced in any means, in whole or in part, without the prior written permission of the publisher and NIA. Any unauthorized  duplication is strictly prohibited and would violate NIA’s copyright and may violate other copyright agreements that NIA has with authors and partners. Contact to reprint or reproduce this content.

Disclaimer: Unless specifically noted at the beginning of the article, the content, calculations, and opinions expressed by the author(s) of any article in Insulation Outlook are those of the author(s) and do not necessarily reflect the views of NIA. The appearance of an article, advertisement, and/or product or service information in Insulation Outlook does not constitute an endorsement of such products or services by NIA. Every effort will be made to avoid the use or mention of specific product brand names in featured magazine articles.

On May 19, 2020, OSHA again revised its guidance to employers concerning enforcement of the record-keeping requirements found in 29 CFR 1904 as they pertain to the recording of COVID-19 cases.

From the start of the COVID-19 outbreak in the United States, OSHA has stated that COVID-19 is a recordable illness and must be recorded on an employer’s 300 log if the following 3 criteria are met:

  1. The employee has a confirmed case of COVID-19, as defined by the Centers for Disease Control and Prevention (CDC)—meaning that the employee has had at least 1 respiratory specimen that tested positive for SARS-CoV-2;
  2. The case is work-related as defined by 29 CFR 1904.5; and
  3. The illness results in death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, or loss of consciousness, or is a significant injury or illness diagnosed by a physician or other licensed healthcare professional.

While the first and third criteria are relatively easy to verify, determining the work-relatedness of COVID-19 is particularly difficult for employers when there is known community spread of the virus. In previous guidance, OSHA recognized this difficulty and stated that it would not require employers to determine the work-relatedness of a COVID-19 case (and would not enforce 29 CFR 1904) unless1:

  1. There was objective evidence that a case of COVID-19 may be work related (for example, a number of cases developed among workers who work closely together without an alternative explanation); and
  2. This objective evidence was reasonably available to the employer (including information given to the employer by employees, as well as information an employer learned regarding its employees’ health and safety in the ordinary course of managing its business and employees).

In practice, this meant that an employer was not required to undertake an extensive inquiry into the potential work-relatedness of an employee’s COVID-19 and could rely upon objective information that was reasonably available to it. Unless the causal link between COVID-19 and the workplace became known to the employer through the normal course of operating the business, the employer was not expected to record the case.

However, OSHA has announced that it will now enforce 29 CFR 904 with respect to employers across all industries2 and has issued new guidance that raises the bar for employers investigating the work-relatedness of COVID-19 cases.

Effective May 26, 2020, employers must make a “reasonable determination” as to the work-relatedness of employee COVID-19 cases. Now, employers must take affirmative steps to question employees with confirmed cases of COVID-19, rather than simply relying upon information that the employer could learn through the regular course of managing the business. To make a “reasonable determination,” employers should “(1) [A]sk the employee how he believes he contracted the COVID-19 illness; (2) while respecting the employee’s privacy, discuss with the employee his work and out-of-work activities that may have led to the COVID-19 illness; and (3) review the employee’s work environment for potential SARS-CoV-2 exposure,” keeping in mind any other workers in the same environment who have contracted COVID-19. OSHA cautions that employers, and particularly smaller employers, “should not be expected to undertake extensive medical inquiries, given employee privacy concerns and most employers’ lack of expertise in this area.” So the “reasonable determination” is modified by the ability of the employer to obtain information while pursuing the steps enumerated in this paragraph, in light of the caution regarding employee privacy concerns and the recognition that most employers do not have expertise in these areas.

In addition to questioning employees, OSHA will continue to look at information that was reasonably available to the employer at the time the work-relatedness determination was made, but OSHA announced that it will also look at information that the employer learned later (after the work-relatedness determination was made) to assess whether the employer’s determination was reasonable. Such Monday-morning quarterbacking by OSHA places a burden on employers to revisit the “work-relatedness” determination of COVID-19 cases that were not recorded if subsequent information suggests that the case should have been recorded.

OSHA outlined the types of evidence that would weigh in favor of a COVID-19 case being work related, stating that cases are “likely work related” when several cases develop among workers who work closely together; if contracted shortly after a lengthy and close exposure to a customer or coworker who has the virus; or if the employee’s job duties involve frequent and close exposure to the general public in a locality with ongoing community transmission, and there is no alternative explanation other than workplace exposure. OSHA stated that it would also “[G]ive due weight to any evidence of causation,
pertaining to the employee illness, (sic) at issue provided by medical providers, public health authorities, or the employee herself.”
On the other hand, OSHA acknowledges that an employee’s COVID-19 illness is likely not work-related if the employee is the only worker in his work area to contract the virus; his job duties do not include frequent contact with the general public; or if the employee, outside of work, closely associates with someone who has COVID-19.
Last, OSHA clarified that employers must evaluate the work-relatedness of each case using a “more likely than not” standard. OSHA stated, “If, after the reasonable and good faith inquiry described above, the employer cannot determine whether it is more likely than not that exposure in the workplace played a causal role with respect to the particular case of COVID-19, the illness is not recordable.” In other words, a mere possibility that the exposure occurred in the workplace does not make a case recordable.
It remains to be seen whether this new guidance ends up being a distinction without a difference, as many employers are already investigating employee COVID-19 cases to protect their other employees and comply with various state government directives. But, in the event OSHA pays a visit, employers should be prepared to prove they have made a “reasonable determination” as to the work-relatedness of employee COVID-19 cases. When an employer questions an employee with a known case of COVID-19, the questions and responses should be documented by the employer, dated, and stored in a location where the employee’s health information will be protected. If an employer decides that a particular case is not work related, it should document any and all reasons supporting that determination. In addition, employers who typically rely upon their workers’ compensation insurance carriers to investigate worker claims should not strictly rely on the insurance company’s investigation to determine the work-relatedness of the virus. To comply with OSHA’s directive, employers should undertake an independent investigation (which may have to be more extensive than their workers’ compensation insurance carrier’s investigation) of each claim and arrive at their own conclusions about the work-relatedness of COVID-19 cases. If the employer is in 1 of the few states that prohibit private workers’ compensation insurance, the bulk of the investigation on work relatedness will fall on the employer’s shoulders. OSHA has made it clear that it is the responsibility
of the employer to make the reasonable determination; and,
therefore, the employer will have to defend itself in the case of recordability by demonstrating that it did act reasonably in making its determination.

1. This “hands off” policy did not apply to employers of workers in the healthcare industry, emergency response, or correctional institutions. Employers in those industries were required to continue making work-relatedness determinations on a case-by-case basis.
2. As always, employers with 10 or fewer employees are not subject to the injury/illness recording requirements in 29 CFR 1904 and need only report cases of COVID-19 that result in death, hospitalization, amputation, or loss of an eye.


Copyright statement

This article was published in the July 2020 issue of Insulation Outlook magazine. Copyright © 2020 National Insulation Association. All rights reserved. The contents of this website and Insulation Outlook magazine may not be reproduced in any means, in whole or in part, without the prior written permission of the publisher and NIA. Any unauthorized  duplication is strictly prohibited and would violate NIA’s copyright and may violate other copyright agreements that NIA has with authors and partners. Contact to reprint or reproduce this content.

In the span of 2 months, the coronavirus crisis has demanded sweeping changes from the U.S. construction industry, and experts say many of them will remain in place even after the outbreak recedes.

As contractors return to work on sites that were shut down by shelter-in-place initiatives, they face an industry that has been drastically changed by the both public health and economic effects of the pandemic.

“There are new factors coming into play now that you or I never thought about,” said Joe Natarelli, leader of Marcum LLP’s national Construction Industry Group. “And people need to plan now to be prepared for the long term.”

From a renewed emphasis on jobsite safety to longer project delivery times and the increased influence of organized labor, the virus has upended many facets of the industry. Companies that try to return to a business-as-usual mentality will face a harsh new reality, Mr. Natarelli said.

“There’s been a paradigm shift in many areas of construction that is leading contractors to do many things differently than they did in the past,” he said.

Here are 8 ways that COVID-19 has altered the construction industry for the near future and beyond.

1. Jobsites Will Be Cleaner and Safer

The virus put a spotlight on the importance of worker health and safety, and U.S. contractors responded by implementing new jobsite policies such as staggered shifts, employee temperature checks, and top-to-bottom disinfections of jobsites, tools, and machinery.

Superintendents at Bridgewater, Massachusetts-based Callahan Construction Managers have implemented a variety of protocols to promote social distancing and employee health, including a ban on carpooling, a 100% mask-and-glove policy, and well-stocked handwashing stations, according to President Pat Callahan. In addition, the company’s safety team made 200 gallons of sanitizing soap that has been distributed across jobsites.

This emphasis on cleaner, less crowded work areas is one that will not recede after the virus does, Mr. Natarelli said.

“Contractors can’t be thinking that they can bring workers back after all this dies down and it will be the same as always,” he said. “They’ll have to include a lot more health and safety measures so that employees are comfortable returning to work.”

Medical experts’ belief that outbreaks across the world will come in waves for months or even years to come make safety plans important now and into the future.

“Employers can no longer conduct business the same way as they did in the past,” Attorney Michael Rubin, Chair of Goldberg Segalla’s national OSHA and Worksite Safety Practice Group said. “Especially now, they need to be flexible and, in many instances, creative, as they think of new ways to perform certain tasks that they have performed in the same way for many years in the past.”

2. Distancing Will Be the Norm, Via Technology

The current emphasis on social distancing on jobsites will likely continue even after the current health threat passes, Mr. Rubin said. “We can expect to see less group activities and more clearly defined procedures and protocols for even some of the most routine work tasks,” he added.

Even as the current outbreak subsides in many areas, state and local officials are putting measures in place to mitigate risk on construction sites going forward.

The need for social distancing has also changed how contractors interact with project teams and with customers, and companies have developed unique solutions to stay in touch. California-based AECOM has launched an interactive web-based tool that allows clients to hold virtual public meetings, a crucial component in the process of creating public projects such as town halls, stadiums, and concert venues. The platform allows AECOM employees and customers to engage with the public about the impact and benefits of proposed projects without leaving their homes.

“It’s exactly like a real public meeting, but without the in-person element,” Kevin Carlson, AECOM’s Global Lead for Digital Transformation, noted.

In addition, in some areas of the country, building departments are implementing remote technology for inspections, a trend that will continue after the health crisis is over, according to Stephen Poposki, a building official in Cape Coral, Florida.

For instance, when faced with a recent inspection delay on a project in Nashville, Tennessee, general contractor DPR submitted 360-degree photos and videos to the local fire marshal for a virtual inspection, allowing it to turn the project over on time.

“I think we’re going to come up with some really efficient ways of doing business,” said Mr. Poposki. “And because people are also very aware of what’s going on in the news, they’re really more willing to accept change right now, and this is the perfect time to do it.”

3. Projects Will Take Longer

Many of the major safety changes on construction sites will add to the time it takes to complete projects. While crucial to keeping workers healthy, techniques such as suiting up with PPE, only allowing 1 trade on a site at a time, and staggering work shifts will slow down progress, and the days of fast-tracking a project may be over—at least for now, experts say.

“Construction schedules will not be the same as they used to be,” said Mike Benike, Executive Vice President at Rochester, Minnesota-based Benike Construction, during a COVID-19 webinar sponsored by Destination Medical Center, a public-private economic initiative in Rochester, Minnesota. ​​“Things will take a little longer because we won’t be able to have lots of people in the same place at the same time.”

Mr. Natarelli advises contractors to consider time constraints when bidding out new jobs, to make sure the contract reflects a reasonable construction schedule. The entire project team, including owners, architects, subs, and other partners, needs to understand that at least in the near term, projects will take longer than before.

“We’ll be planning jobs differently going forward,” he said. “These longer completion times aren’t going to go away anytime soon, and we need to be prepared going forward that if another wave of the virus does come back, we’re in much better shape and we’re much better prepared.”

4. Telework Will Become More Common

The coronavirus has also brought major changes to construction’s back offices. Forced to stay at home, many office employees have kept business operations running via remote work, relying on technology like videoconferencing, emailing, and texting to stay in touch.

This nationwide experiment in telework will likely cause many leaders to think about making the practice permanent. A recent Gartner study found that 74% of American companies will move at least 5% of their office workforce to permanently remote sites, and nearly a quarter of respondents said they will move at least 20% to permanently remote positions, according to a survey of the company’s chief financial officers (CFOs).

“CFOs, already under pressure to tightly manage costs, clearly sense an opportunity to realize the cost benefits of a remote workforce,” said Alexander Bant, Practice Vice President, Research for the Gartner Finance Practice.

While the trend toward remote work will lead to a dramatic reduction in the need for office space for many companies, others may think about expanding, noted Ross Forman, Managing Director of Business Advisory firm BDO.

These firms may seek to take advantage of lower rents to expand their office space to allow for greater social distancing in the workplace. This could mean a move away from the popular open office space layouts to allow for additional private space “to reassure skittish staff long after the worst of COVID-19 infections have passed,” he said.

5. Union influence will grow

Since World War II, the percentage of the U.S. construction industry involved in union memberships has steadily declined, from about 87% of the workforce in 1947 to 12.8% in 2018. Nevertheless, since the pandemic began, trade unions have taken on renewed influence in many areas of the country by advocating for members’ best interests in keeping sites operational and safe.

Recently trade unions in New York state were instrumental in persuading government officials to shut down projects that were previously allowed to continue, and in Massachusetts, 2 unions staged walkouts earlier this month in protest of what they deemed to be unsanitary working conditions.

At the same time, other unions have wielded their influence to keep members on the job. North America’s Building Trade Unions recently teamed up with the Associated General Contractors of America [and NIA] to ask government officials at all levels to make construction an essential service and exempt it from regional, state, and local shutdowns.

During the crisis, unions have provided a voice for workers who are struggling to decide whether they should stay home or go to work, said Mark Erlich, a Fellow at Harvard University’s Labor and Worklife Program. Unions also help laborers find new work after a layoff.

The appeal of unions will be stronger than ever going forward, Mr. Erlich said, a trend that “will likely come into conflict with cost-cutting measures that construction employers will inevitably be considering once they reckon with the financial losses from the crisis.”

“It’s going to cost more money and not going to be as efficient as in the past, but the market is going to force those types of changes,” Mr. Natarelli said.

6. Demand for Project Types Will Change

The coronavirus outbreak has reshaped the types of projects that will be built this year and
for many years to come. Hospitality, retail, and entertainment projects are likely to be in less demand, while healthcare construction and healthcare-related manufacturing projects could see more activity, according to Charles Hewlett​, RCLCO Real Estate Advisors’ Director of Strategic Planning.

In addition, demand for distribution and warehouse space may likely increase as U.S. companies favor higher inventory levels and emphasize supply chain resiliency over efficiency, Mr. Hewlett said.

“In the long run, expect more manufacturing facilities to locate in North America to ensure supply and access to markets during episodes like this one, a boon to economic growth and industrial and logistics facilities in the U.S. and Mexico,” he said.

Keith Prather, Market Intelligence Expert for Olathe, Kansas-based business management consulting firm Pioneer IQ, agreed, saying that less reliance on Chinese-made building products will create a surge of new manufacturing- and supply chain-related construction projects, such as factories and warehouses.

Experts are divided on how infrastructure initiatives will fare in the near future, with some noting that projects like road and bridge construction could suffer as state Department of Transportation revenue declines because of decreased fuel tax revenues, and federal infrastructure funding may be waylaid as Congress turns its attention to COVID-19 mitigation measures for business and unemployed Americans.

Nevertheless, some public works projects have received a shot in the arm because of the pandemic. The Airport Improvement Program will invest $3.2 billion in the development and modernization of aviation facilities across the country, and the governors of some states, including Florida and Minnesota, have accelerated billions of dollars of transportation projects in an effort to lessen the economic fallout from the coronavirus pandemic and to take advantage of fewer vehicles on the road.

7. Supply Chains Will Recalibrate

Even before the outbreak hit the United States, the coronavirus created major global supply chain disruptions, especially of goods from China, the source of about 30% of U.S. building materials last year. Government containment efforts and quarantines in China slowed or shut down factories in dozens of cities and provinces, leading to a falloff in production of everything from cars to smartphones. U.S. builders have noted delays and shortages in items like steel, surfacing, and case goods.

Wendy Cohen, Vice President of Operations for Sacramento, California, construction management firm Kitchell CEM, said she has experienced some delays in material availability since the crisis began. Kitchell project teams are working with clients, architects, contractors, and trade partners to identify shortages and develop creative solutions for the projects that the company continues to build for essential clients such as schools, colleges, and the Los Angeles Department of Public Works.

With so many sourcing challenges on the horizon, many American construction firms will be hesitant to resume orders from Chinese suppliers, according to Mr. Prather.

“How we source projects has a lot of weaknesses,” he said. “We believe that going forward there will be a lot of reshoring back in the U.S., where we’ll see an increase in our manufacturing ability here as well as heading into Mexico.”

Mr. Natarelli said many of his large contractor clients that are bidding out jobs include clauses in their contracts that call for as many as 5 backup sources for materials. Many are willing to pay higher prices for supplies coming from less risky locations.

“Alternative suppliers are very big right now, and contractors are weighing the risks with the rewards,” he said.

8. Modular Adoption Will Increase

An enhanced focus on worker safety will help accelerate the industry’s move to offsite construction methods. While contractors like PCL, Clark, and Mortenson have relied on prefabrication for many years, Mr. Natarelli said the coronavirus pandemic will motivate more firms to investigate the benefits of offsite building.

The assembly-line efficiency and climate-controlled environment of factory production can save on labor costs and shorten project schedules, but other advantages will take center stage in post-pandemic construction, according to Mr. Natarelli, including increased site safety and reduced congestion.

“It reduces the amount of time you’re in the field, and keeping the labor force in a controlled environment is good from a health standpoint, too,” he said. “So maybe now you have a job that went from 6 months to 9 months and maybe this can shave that to 8 months while you’re also promoting social distancing, too.”


Copyright statement

This article was published in the July 2020 issue of Insulation Outlook magazine. Copyright © 2020 National Insulation Association. All rights reserved. The contents of this website and Insulation Outlook magazine may not be reproduced in any means, in whole or in part, without the prior written permission of the publisher and NIA. Any unauthorized  duplication is strictly prohibited and would violate NIA’s copyright and may violate other copyright agreements that NIA has with authors and partners. Contact to reprint or reproduce this content.

Power plant owners and operators have experienced degradation of their boiler insulation. Damage can be caused by storms impacting exterior boilers, tube leak repairs, other modifications, or the pull of gravity over an extended time period. Degraded insulation creates a boiler performance problem in addition to hazards for personnel and nearby equipment.

Restoring lost insulation can be a difficult and expensive proposition due to limited access and large surface areas involved. The typical steam-generating boiler efficiency penalty caused by heat lost to the atmosphere is in the range of 0.25% to 0.4% when the insulation is in perfect condition. On the plus side, a proper insulation design and installation can save as much as 5% to 7% in fuel cost (oil, gas, coal, or refuse), paying for approximately 5% of the initial boiler construction cost.

The power generation industry needs cost-effective and thermally efficient insulation systems on its steam-generating boilers to maintain efficiency and ensure personnel and equipment safety. This key component can fail due to improper installation or design of the insulation (and lagging) systems. Experienced and qualified contractors—and, in some cases, plant maintenance personnel—are key to correct installation. Insulation systems fail because the power industries—including designers—often fail to understand how far the industry has regressed. For many reasons, the power industry has gone through major reorganization, mergers, and plant shutdowns. This, in conjunction with an aging workforce, has led to a change in how the industry looks at insulation of its steam-generating boilers. Fewer than 20 years ago, most power boiler companies and original equipment manufacturers (OEMs) understood the importance of insulation for energy efficiency. These same companies also had training and continuing education programs to help keep their boilers operating efficiently while keeping their installation costs reasonable. Unfortunately, much of the expertise and knowledge in today’s boiler industry has been lost or forgotten.

That loss of knowledge has, in turn, led to the end of keeping historical records for the insulation systems used on steam-generating boilers. Once keeping historical information stopped, the continuing education programs also began to dwindle. The industry has suffered as a result because reviewing historical data helps improve boiler design; correct design flaws; document labor variances; improve labor productivity; and establish better costs, budgets, and bids.

Loss of Historical Data

Without historical data, it inevitably costs more to repair or replace existing insulation systems and equipment. With the technology and tools available today, it is easier than ever to record and track data, but this must be an ongoing process, and the data recorded needs to be kept for historic records to give companies an overall view of their system’s performance and successes. Here are 3 examples of the effects of a lack of historical data.

Example 1. Many boiler manufacturers design (and supply) their flues, ducts, and emission control equipment systems without taking into consideration the cost or effect their stiffener designs will have on the insulation and lagging that will be required later in the project. Historical data would support and confirm that using large stiffeners (greater than 7 inches high) is detrimental to the longevity and integrity of the insulation and lagging systems being designed and installed today.

Example 2. Many OEMs and power generation companies have changed their standards to mandate double-layer applications on their boiler walls. The thinking is that double-layer application is better than single layer because it eliminates gaps between the individual insulation pieces and reduces the chances for hot spots on the outer lagging or
casing surface. However, there is no documentation to support that this is universally true. Historical data could confirm or disprove whether using double-layer instead of single-layer insulation provides a better insulation system. Going to double layer does not ensure the elimination of gaps or prevent improper insulation applications, but proper installation does.

Figure 1 through Figure 3 illustrate some examples of how installing a double-layer system does not prevent costly mistakes. Each of these photos represents violation of most OEM installation specification requirements.

Example 3. Some companies increase the insulation on existing boiler walls or soon-to-be-built boilers from the original design of 4” thick to 5” thick, based on the theory that more insulation is better for energy savings. While insulation provides energy savings, the buckstay design should not be neglected when making this change. Historical data would show that increasing the boiler wall insulation without also changing the distance of the buckstays to the tube wall can create other problems (see Figure 4 and Figure 5) that may outweigh the desired savings.

Lack of Continuing Education and the Need for a Boiler Standard

The lack of a continuing education programs for the power industry is also costing the industry money. A typical power plant may have 2 or 3 different types of boilers, with different tube wall designs. Such a scenario requires personnel with specialized understanding of all the different types of boilers, their unique operation requirements, the large multidirectional expansion that can occur, and the potential need to install the materials while the boiler is in operation. Adding to this is the impact that changing fuels, adding gas turbines, or going to a co-generating system has on the power and insulation industries. We must begin to take note of these changes, especially when converting to alternative fuels in existing boilers. We also must anticipate and adjust to new outage requirements when adding gas turbines to replace existing coal- or oil-fired units. And we must change how we view the importance of both insulation and refractory when adding a co-generation system.

Understandably, working in the power industry has changed over time. No longer do the power plants and OEMs have the expertise or personnel to monitor proper installation of their insulation systems; and most of the workforce used to install insulation has limited or no experience working at power plants. Each boiler may have its own set of standards and applications, depending upon who manufactured the boiler. There can be confusion as to what insulation system is to be used and how to install the system. Consider the following examples:

  • Example 1. 1 boiler may require insulation behind the buckstays, whereas another may require a poured insulation.
  • Example 2. 1 boiler may require the penthouse enclosure to be internally insulated, while the boiler next to it has an externally insulated and lagged penthouse enclosure.
  • Example 3. 1 boiler may be top supported, while the boiler next to it is a bottom-supported unit. The expansion is different and must be accounted for.
  • Example 4. 1 boiler may require a 1-rib overlap on the outer lagging, whereas another does not.
  • Example 5. 1 boiler may have insulation attachments on 12” centers, compared to another boiler requiring a different spacing (e.g., 18” x 21”).
  • Example 6. 1 boiler may require buckstay covers even as another right next to it does not.

Not listed above but equally important are the different ways to insulate pipe, valves, and fittings. When a power plant changes from coal fired to gas turbines it will no longer be necessary to inspect the air heater baskets as often or remove and replace large areas of boiler wall insulation. In lieu of this typical type of work during outages, there will be more emphasis on efficiency and heat loss. Piping standards, like boiler wall insulation standards, differ from 1 boiler manufacture to another and will need to be consolidated
or revised.

Here is an example: When doing frequent inspections of large steam valves, removable insulated valve covers will be needed. In years past, the valves may only have been inspected every 2 years, and they were wrapped with an insulated blanket and covered with jacketing. Now, the frequency will be once or twice a year. Labor will need to know how to fabricate a removable valve cover. (Please see Figures 6, 7, and 8.)

The examples described are not all inclusive, which is why many in the industry are calling for unification or the development of agreed-upon insulation application standards that may be applied to all membrane or inner-cased boilers, and on gas turbines and co-generation systems. The need for such standards is demonstrated by all of the examples and issues described in this article; and it would address the fact that working at a power plant requires a special understanding of the different types of boilers; their unique operation requirements; and the large, multidirectional expansion that can occur.

Power and Insulation Industries Expanding

The power and insulation industries are going through a growth and change not seen since the late seventies and early eighties. Power companies will be spending billions of dollars on new power plants, retrofitting to accommodate new fuels, adding a co-generation system, or moth-balling their existing coal-fired boilers and replacing them with gas turbines. The power industry must educate all its workers on the importance of maintaining good historical data, and it must keep up with training for working at a steam-generating plant. To improve the power industry, we need to develop and maintain a well-educated workforce. This should apply not just at the power plants but also include boiler inspectors dealing with insulation applications and OEM companies and suppliers. To accomplish this, everyone—including labor associations—must work together to improve the power generation industry.

With the increase in today’s new boiler construction, including heat recovery steam generators, now is the time to increase the level of understanding of insulation and of the value of keeping historical data, increase the availability of continuing education programs, and agree upon an insulation application standard that makes sense for saving energy and is easy for installers to understand and follow.


Lower fuel costs coincide with lower equipment and maintenance costs. Energy savings can be achieved by properly designing and installing insulation (and lagging), and it begins with a better educated workforce and recording and maintaining historical data both at the plant level and at the OEMs. Implementing these recommendations will help establish industry standards for proper insulation applications and provide the industry with the information needed to improve boiler and plant reliability.

Copyright statement

This article was published in the June 2020 issue of Insulation Outlook magazine. Copyright © 2020 National Insulation Association. All rights reserved. The contents of this website and Insulation Outlook magazine may not be reproduced in any means, in whole or in part, without the prior written permission of the publisher and NIA. Any unauthorized  duplication is strictly prohibited and would violate NIA’s copyright and may violate other copyright agreements that NIA has with authors and partners. Contact to reprint or reproduce this content.

By Auman, Mahan & Furry

Please contact Amy Mitchell (, Matt Bakota (, or Steve Watring ( for questions specific to your business and as additional questions and circumstances arise.

March 17, 2020

We know you are receiving numerous emails providing guidance on how to handle the impact of COVID-19 on your workforce. We also have received such emails, and unfortunately, not all guidance being issued is accurate or based on the law. Instead, it appears some of the guidance is based on news reports, tweets, and summaries of proposed laws as opposed to the actual laws in place. Please know that we at Auman, Mahan & Furry believe it is more important to be accurate than to be first at sending out information. At the same time, we know you are being forced to make quick decisions on these issues. As such, we are providing the information below as a supplement to the March 11, 2020 article  posted on our website in response to additional questions we have received. The information below discusses specifics for Ohio employers relating to unemployment compensation but also addresses issues applicable to all employers throughout the United States.

If an employer reduces the work hours of employees due to the impact on its business, do the employees have to be paid their full wages?

Absent a union contract or other agreement or understanding, wage-hour laws only require you to pay hourly employees for hours actually worked.

Importantly, if you reduce the hours of exempt salaried employees because of business conditions, you normally must pay them their full salary unless they do no work during the entire week. You normally can require them to use paid leave for the time missed, as long as they receive their full pay. Other options include converting them to hourly or reducing their salary, provided that you provide notice and it is not done retroactively.

An employer can take a proportionate deduction from the salary of an exempt employee if they take intermittent Family and Medical Leave Act (FMLA) leave. See below for additional information on FMLA.

Are employers required to allow employees to work from home?

In most situations, no. An employer is not required to allow an employee to work from home unless it is determined to be a reasonable accommodation under the Americans with Disabilities Act or state law for medical conditions that qualify as a disability. COVID-19 normally will not qualify as a disability.

Are there any long-term consequences to allowing employees to work from home during the pandemic?

If an employer permits an employee to work at home during the pandemic, the employee may assert that physical presence at work is not an essential function of the position and try to continue to work at home after the pandemic has subsided. In order to limit the effectiveness of this argument, employers should provide written notification to any employee working at home that telework is being permitted on a temporary basis only because of the extraordinary situation in the workplace caused by the coronavirus and that it is being permitted even though the employee may not be able to perform all of the employee’s essential job functions during this temporary period.

Will employees be eligible for unemployment benefits in Ohio if an employer closes or lays off employees because of a coronavirus-related reason?

Yes. Governor Mike DeWine issued an executive order to expand unemployment benefits for individuals otherwise eligible who are requested by a medical professional, local health authority, or employer to be isolated or quarantined as a consequence of COVID-19, even if the employee is not diagnosed with COVID-19. In addition, the normal 1-week waiting period for unemployment benefits will be waived.

If an employer sends an employee home because the employee is exhibiting symptoms or has been exposed to someone who tested positive for COVID-19, will the employee be eligible for unemployment benefits in Ohio?

Yes. If the employee is not otherwise receiving pay, the employee will be eligible for unemployment benefits pursuant to Governor DeWine’s executive order as explained above.

Are employees entitled to unemployment benefits in Ohio if they stay home from work to self-quarantine or due to lack of childcare available?

In most cases, no. If an employee stays home at the individual’s own choosing, not based on the employer or medical professional’s advice, the employee would not be eligible for unemployment benefits.

Does an employer have to excuse an employee who calls off of work to self-quarantine or to practice social distancing even if the employee does not have symptoms or previous known exposure to COVID-19?

At this time, no. An employer’s normal attendance policy can apply to any such absences. However, if the employee has an unrelated medical condition that qualifies as a disability under the Americans with Disabilities Act or state law and has been advised by a physician to not attend work, it may, depending on the circumstances, be a reasonable accommodation to allow the employee to take a leave of absence. In addition, OSHA provides protections for employees who refuse to work if they believe they are in imminent danger, and the National Labor Relations Act provides protections to employees, union and non-union, who engage in protected concerted activity for mutual aid or protection. As such, we recommend caution and contacting legal counsel before disciplining or terminating an employee for such absences.

The amendments to the FMLA being considered by the U.S. Senate at this time may permit employees to use FMLA leave for this purpose. However, until such amendments become law, FMLA does not apply to absences solely to self-quarantine or practice social distancing.

Are employees eligible for short-term disability benefits?

Medical professionals currently indicate that most individuals who test positive for COVID-19 will not require medical treatment or experience serious or long-term symptoms. An employee will be eligible for short-term disability benefits only if their symptoms and medical condition meet the requirements of the policy. Employees who are off work for self-quarantine purposes only will not normally qualify for short-term disability benefits.

If an employer decides or is required to close or lay off employees for COVID-related reasons in Ohio, is the employer required to give advance notice?

The federal Worker Adjustment and Retraining Notification (WARN) Act applies to business with 100 or more full-time workers and requires advance notice for mass layoffs and plant closures affecting at least 50 employees. However, WARN Act requirements are not triggered if the layoff is for 6 months or less. If the employer determines that the layoff will be extended for more than 6 months, written notice will be required at the time that the need for the extension becomes known. We are hopeful, based on the information currently available, that the COVID-19 pandemic and closures will not extend to the 6-month mark.

What will be required if the Families First Coronavirus Response Act, H.R. 6201, passed by the House becomes law?

Significant changes are anticipated when the Senate considers H.R. 6201 this week. At this point, it is too early to anticipate the extent of unpaid and paid leave that may be required and the specifics as to the size of employer it will cover. Under the current FMLA, eligible employees are entitled to up to 12 weeks of unpaid leave for a serious health condition or to care for a family member with a serious health condition. An employee with COVID-19 may, if they experience severe symptoms or complications, qualify for unpaid FMLA leave but not all employees with COVID-19 will be eligible under the FMLA. The Department of Labor has previously issued guidance confirming that employers cannot apply FMLA leave to absences that do not qualify under the law. Once the law is finalized, we will be issuing additional guidance based upon the actual provisions of the new law. We have draft guidance waiting for final revision based upon any changes that are made to the current draft bill.

What else can I do?

  • Understand and comply with the law. Try to keep up with changes. If in doubt, get good legal advice before acting. Check back often on the Auman, Mahan & Furry website for updates.
  • Look for opportunity in adversity. While nobody knows the future, there is a good chance that this will be short-lived. Keeping good employees through bad times often builds loyalty and pays long-term dividends. There also may be a temporary opportunity to pick up some workers that were not available less than a month ago.


Please contact Amy Mitchell (, Matt Bakota (, or Steve Watring ( for questions specific to your business and as additional questions and circumstances arise.

From NIA Legal Counsel Gary Auman, Auman, Mahan & Furry

Coronavirus disease (COVID-19) is on many employers’ minds, creating questions and fears as to how to plan for the future and what their obligations to their employees may be. False information is also rampant as people teeter between panic and apathy. As such, now is a good time for employers to take action in preparing both their employees and their worksites for possible implications of the virus.

OSHA has released a guidance document for employers on their website at It is essential for employers to remember that both this OSHA guidance publication and this Safety News Alert are only RECOMMENDATIONS; they are not additional rules that employers must comply with under OSHA. With that said, it would be prudent for employers to consider the advice both in the publication and in this alert.

In its publication OSHA has provided exposure risks in 4 categories: very high, high, medium, and low. The very high risk is for those medical, laboratory, or postmortem staff who are involved with known or suspected cases of COVID-19 and use aerosol generating procedures or specimen handling. The high category includes those medical, postmortem, or laboratory staff who do not use aerosol generating procedures or potential COVID-19 specimens. Most employers do not fall into the top 2 categories.

The medium risk category is where many more employers will have concerns. According to OSHA, jobs having a medium risk “include those that require frequent and/or close contact (i.e., within 6 feet of) other people who may be infected.” This would include potential exposure through community transmission, the general public, travel, retail, etc. This also includes contact with those who may not know they are sick.

Jobs that require no contact with possibly infected people (or within 6 feet of the general public) fall into the lowest risk category. OSHA has provided this pyramid visual, showing that most employers are in the lower risk and medium risk groups.

Based on these 4 categories, OSHA has SUGGESTED, not required, procedures for employers. Those in the lowest risk category have 1 primary suggestion: monitor public health information both in your state and with the Centers for Disease Control and Prevention (CDC) and make sure your workers are aware of their recommendations. No additional protections are currently recommended— no face masks or engineering controls. This suggestion, if implemented, will result in communicating those recommendations to employees.

Those employers in the medium risk category should consider making some changes. OSHA recommends that these employers consider restricting public access, potentially using face masks, limiting face-to-face contact, and even making medical screening available. Each employer should assess the kind of contacts they have with people when implementing these suggestions. For instance, grocery businesses will likely have more contact with the general public than roofing operations. It is up to each employer to determine the risks at each worksite and how to protect their employees. It would be rare for employers in this category to require respirators, but if they are used, remember a written respiratory protection program as well as other requirements under OSHA MUST then be followed.

Those employers in the high and very high risk categories have several more considerations according to OSHA, including engineering controls such as isolation rooms; administrative controls such as signs, monitoring of both medical and stress induced conditions, and education; and personal protective equipment such as respirators.

It is important to remember that these are OSHA recommendations and not additional rules. However, with the spread of the coronavirus and the fears associated with it, it may be wise for employers to at least consider implementing some of OSHA’s recommendations to all employers. OSHA advises all employers to develop an Infectious Disease Preparedness and Response Plan to include the following: how to implement governmental guidance; assessing the level of exposure risk to employees; non-occupational risk factors; worker specific risk factors (i.e., age and health); potential controls for those risks; and contingency plans for outbreaks such as absence, distancing, remote work, reduced or staggered workforce, and supply chain interruptions.

Employers should also consider implementing policies such as encouraging frequent handwashing, staying home if sick, housekeeping, and not sharing equipment where possible. OSHA recommends employers develop policies and procedures and train employees on them should an employee become infected with COVID-19, including identification, reporting of symptoms, and potential isolation at the jobsite. Employers should consider addressing employees’ concerns regarding sick policies, absenteeism, and pay issues. Employers should not require a sick note for an absence as this would expose more people to the virus.

There are more recommendations available on the OSHA, CDC, and state websites. Although these are not required rules, it would be prudent for employers to take action in preparing for possible implications of the virus. This is not a time to panic, but it is a time to prepare. Having a plan, educating employees on that plan, and implementing precautionary measures is vital to securing a non-panicked, prepared workforce. Employers should be aware that OSHA is receiving complaints from workers regarding allegations of a lack of concern and effort by some employers to take proactive steps to protect their workforce in light of COVID-19. In such cases OSHA, if it were to investigate, would do so under the General Duty Clause.