by Greg Lathan

Wherever business managers lean politically, most concur that routine workplace testing of employees to identify COVID carriers is an effective measure to minimize occupational COVID transmission. The virulent nature of the Omicron variant (akin to measles in virulence) makes rapid antigen testing of the workforce a common sense choice to prevent them from spreading COVID to coworkers. What better concept to identify those employees who are infected with COVID and isolate them from their fellow workers to “Nip occupational COVID transmission in the bud!?” 

Although the pending OSHA mandate to test employees for COVID in businesses seems logical, actual implementation of rapid antigen testing of your workforce poses numerous challenges. Think about the magnitude of a nationwide endeavor which requires all employers exceeding 100 workers to begin COVID testing simultaneously, within a very brief, 30-day time frame!? Try to engage a third party, COVID testing operation with the personnel to perform your testing on-site, without using any of your own internal resources! Think you can google “on-site rapid antigen testing” and identify one? Not! And what about bulk test procurement to get your program started! GOOD LUCK!!

What do employers need to know about testing their workforce in the event the OSHA Emergency Standard for COVID testing is approved?

Since the emergence of the SARS CoV-2 Delta variant late last summer and following the release of the OSHA ETS draft rule in October, The EI Group (EI) has supported numerous “proactive” industrial clients who elected to perform occupational COVID testing, before a mandate from OSHA forced them to do so. Based on the experience from a contractor who has been in the “occupational COVID testing trenches,” EI would like to share our extensive learning curve with these companies during the past 5 months (yes, there is a significant learning curve involved in implementing an effective COVID testing program!) and provide some advice in complying with the OSHA ETS.  

Tried to buy a COVID test lately?
How will your company procure an adequate supply of COVID tests given the extraordinary demand during the recent spread of Omicron variant? First, you must have a CLIA waiver (Clinical Laboratory Improvement Amendment) to purchase and administer these tests. Most manufacturing firms will not qualify for a CLIA waiver. If your company can qualify, the application and certification process takes time. Also, simply obtaining a CLIA waiver certainly does not ensure that you can obtain COVID tests, as you must identify multiple distributors to purchase these tests to ensure a dependable supply chain. Most of EI’s proactive clients who launched COVID testing programs last Summer and Fall pre-purchased bulk quantity of these tests for the long haul. 

So I found some tests. Now who is going to administer them?
Where will you procure the labor to perform on-site testing? This is a central issue and rate limiting factor. There are approximately 200,000 businesses that will need to comply with the OSHA ETS, but many of these have multiple operations scattered geographically. There are simply not enough private contractors nationwide who can administer COVID tests on-site to cover the hundreds of thousands of business locations which will need to comply with the OSHA ETS if it is mandated. You must look within, possibly to your Human Resources Department or EHS Department to supply labor to implement an on-site COVID testing program. If this is not plausible, relationships with local temporary staffing operations must be tapped. COVID testing is a skill that can be easily taught to novices in less than 15 minutes.

Let’s begin by posing some key questions you should address before launching an on-site rapid antigen testing program and discuss them one by one:

1) What type of COVID tests should you purchase? Do you want nasopharyngeal, shallow anterior nasal or a saliva test? What are the pros and cons of using each?

Rapid antigen tests are cost effective and provide the most rapid results. The FDA has approved a number of various manufacturers, but these tests vary in sensitivity, accuracy, cost and availability. The percentage of false positives can be an issue. However, given the current supply chain issues with these tests, you should to identify several alternatives from a brand perspective to ensure an adequate supply are available.
Given the challenges with administering nasopharyngeal and saliva tests, the majority of EI’s clients have elected to use rapid antigen tests, which require only a shallow anterior nasal sample.
2) How many professionals will you need to administer rapid antigen tests to your entire employee population, given that the results are not available for 5-15 minutes? Are you going to test only those workers who are unvaccinated or test all employees, whether vaccinated or not? 

The number of testing professionals will vary based on a number of factors. If your facility has 3 standard shifts in 24 hours, you may be forced to position the testing professionals between two shifts and capture employees as they finish work and as they arrive to work (as opposed to staffing them in the early morning to capture the first shift employee population, mid-afternoon for second shift and late night for third shift). Although not ideal, it will definitely lower the labor required to perform COVID testing. We have found clients who desire to staff COVID testing professionals between 2 shifts (one exiting and one arriving) typically have chosen the early morning between the third and first shift change, because third shift typically has only a skeleton crew.
Given the challenge of getting employees to reveal their vaccination status, it is probably easier to test both vaccinated and unvaccinated employees.
3) Do your facilities have a suitable testing area with separate points of ingress and egress?If not, there is the possibility of viral transmission from employees arriving to work who have not been tested with employees who leaving work at the end of their shift. Minimizing the points of ingress is also key to preventing employees from circumventing the testing procedure.
4) How do you test employees upon arrival to the workplace and minimize the potential transmission of COVID from employees who test positive, while maximizing their productive time on the factory floor? Ideally, employees should be tested upon arrival to work, therefore a strategy should be developed to keep arriving employees socially distanced, while they are waiting on test results. Given the test results are not available for 5-15 minutes, this can become problematic. If more than 100 employees are arriving for a given shift, consider establishing multiple testing stations or stagger the arrival of employees over an hour before the shift begins. 

5) How will you physically track employees who are administered a COVID test within your facility? EI has used several alternative employee tracking methods. These include distributing punch cards to tested workers designating the date and time of tests were administered, or colored armbands similar to those issued at concert events, changing the band color every week.
6) What is your discharge protocol if a worker tests positive for COVID? For those who test positive, should they be subjected to a PCR confirmation test? If so, who will administer the PCR test and how will your company be notified of the PCR confirmation results?Remember, any positive rapid antigen test should be verified by a PCR test for COVID and most of these must be submitted to a lab with results available in 1 to 3 days. If the employee is referred to a third party, you must develop a protocol to be notified of the test results. This could be as simple as using the current procedure you have previously used to track employee test results during COVID infections in the past. Although on-site PCR tests for COVID are now available on the market, they are costly ($80-$125) and require 30 minutes for test results.

7) What about State reporting for COVID test results?BOTH negative AND positive test results are required to be reported to the State in which they were conducted on a daily basis. Paperwork abounds. State reporting requirements can also vary between States. Have you researched the specific requirements for your State?
8) How long should employees who test positive for COVID safely be isolated? Will you require a post quarantine COVID test?Will you utilize the newest CDC recommendation of 5 days or the WHO recommended isolation of 10 days? In any respect, ideally employees emerging from COVID quarantine should be subjected to testing. 

9) What follow-up measures should be performed on COVID carriers who are denied access to the workplace?  How will you communicate return-to work guidance?Try to build on your existing system previously established for reporting positive COVID cases at work.

First and foremost, begin planning for your facility COVID testing operation ASAP! Do not assume that you will have the opportunity to engage a third party to provide turnkey COVID rapid antigen testing for your business at the last minute! Attempt to address each of the issues posed above and do your best to identify support for actual test administration from your internal Human Resources or Occupational Health and Safety Department. Administration of COVID testing is not complicated and requires no special certification – novices can easily be taught this protocol! Most of EI’s clients with multiple geographic operations elected to begin with a single pilot test site to confirm the testing procedures developed and the staff they internally trained to perform COVID testing operated smoothly first, before rolling out to multiple testing operations.

How Can We Help?
Since the outbreak of the SARS-Cov-2 Delta variant late last summer, The EI Group has garnered significant experience while performing rapid antigen testing of employees as they arrived to work at numerous manufacturing operations. In addition, EI’s previous experience in performing COVID screening of similar operations for body temperature and administration of COVID questionnaire following the original outbreak of COVID in early 2020 outbreak established a foundation for the protocol. EI has successfully utilized during the administration of rapid antigen testing during the explosion of the Delta variant last year. You’ve got questions – we’ve got answers. Call EI today at (800) 717-3472.