Telecommuting Safely

While OSHA does not regulate home-based workplaces, it is important that a safety partnership be developed between employers and employees who work at home.

By 2010, it is estimated that more than half of the working population in America will be spending at least half of its time working from home. Working at home is an attractive alternative to working in a corporate office setting for more and more Americans.

Proponents of "telecommuting" (working at home) list numerous benefits, including increased productivity, increased job satisfaction, reduced absenteeism, reduced energy (gasoline) consumption and flexible work hours. Safety benefits associated with working at home include minimizing hazards associated with traffic accidents, reducing air pollution (fewer cars on the road) and minimizing the spread of communicable diseases.

There are no specific regulations regarding home-based workplace safety. The Occupational Safety and Health Administration (OSHA) created considerable controversy in November 1999 with a policy letter stating that employers were responsible for the safety of employees working out of their homes and, consequently, had an obligation to inspect the employees' homes for safety hazards.

The interpretation was rescinded and followed by an OSHA Instruction (Directive No. CPL 2-0.125, dated Feb. 25, 2000) on home-based worksites. The instruction states that OSHA will not inspect employees' home offices unless they receive a complaint or referral that indicates a hazard exists. OSHA will not hold employers liable for employees' home offices, nor are employers required to inspect home offices. Employers, however, are "responsible for hazards caused by materials, equipment or work processes that the employer provides or requires to be used in an employee's home."

For the majority of home-office workers, the employer provides, or should require employees to provide, ergonomically acceptable furniture and equipment. By providing or requiring ergonomic equipment, the employer assumes liability. The employee, however, is covered under workers' compensation laws whether working at home or at an office location. Therefore, employers are strongly advised to educate "telecommuters" in general office safety requirements, proper furniture and equipment selection and use, and ways of preventing repetitive motion disorders.

A method for conducting workplace hazard assessments should be developed. It is important that a safety partnership be developed between the employer and the employee. In most cases, the employer will have to rely on the employee to identify and correct home-office hazards. The following guidelines should help employers educate their employees in creating a safe and efficient at-home work environment.

Workplace Hazard Assessment

With approval and permission of the employee, the employer should conduct a workplace hazard assessment. At a minimum, the employee should be trained in recognition of workplace hazards and provided with a checklist inspection form to complete and return to the employer. Examples of a safety checklist for home offices can be found at www-act.ucsd.edu/policy/commute/check.html and at www.tasc.dot.gov/Hrm/telecommute.html

The tasks to be performed must be identified and hazards associated with the tasks evaluated in accordance with OSHA's standard on personal protective equipment, 29 CFR 1910.132. The OSHA standard requires evaluation of potential hazards such as impact, electrical, heat and cold, chemicals, and trips or falls. The level of risk associated with identified hazards must be assessed, and the means of eliminating or reducing the risks must be established. The employer must periodically re-evaluate the work area for hazards.

Furniture and Equipment

Employers may provide appropriate furniture such as desks, chair and lights. If employees are required to provide furniture, a written agreement should be obtained specifying that the employee will provide ergonomically acceptable furniture and equipment and that the workplace will have adequate lighting.

The work area must be of an adequate size to accommodate equipment and documents to be used. Cabinets, bookshelves and other furniture should not prevent safe and rapid egress from the work area in the event of an emergency and should be secured to prevent toppling during an earthquake.

Electrical

The home-based office must have an adequate number of outlets, and the capacity of the circuits should be adequate to accommodate the necessary office equipment. Outlets should be equipped with three-pronged ground configuration, and equipment should be plugged into surge protectors. A licensed electrician may be asked to inspect the home's electrical system and provide upgrades, if necessary.

Electrical cords and wires must be located in a manner to avoid tripping hazards. It may be necessary to install new outlets (and phone jacks) to avoid running cords across walkways. Adequate ventilation for electrical components must be provided to prevent overheating. All electrical equipment must have an Underwriter's Laboratory approval.

Fire

A fire extinguisher should be immediately available and the employee instructed in its proper use. The work area should also have an operable smoke detector. If space heaters, hotplates or coffee pots are used in the office, paper and flammable materials should be kept clear. Such appliances should be turned off when not in use or when the employee steps away for a few minutes.

Smoking should be discouraged. Smoking can cause fires and affect indoor air quality.

The office should be designed to allow rapid egress in the event of a fire or other emergency. A fire evacuation plan should be developed, particularly if the home office is in the basement or above the ground floor. A primary and secondary escape route should be provided, if possible.

Indoor Air Quality

As stated above, smoking should be discouraged to minimize the potential for fires and to avoid deterioration of indoor air quality. Other air-quality issues may include airborne asbestos (particularly in basement locations in older homes), molds, animal dander and other allergens, lead-based paint, carbon monoxide and radon. It is probably beyond the employer's ability to correct such air-quality issues in the home office. If such hazards exist, the employee should be advised to implement proper housekeeping measures and ensure adequate ventilation.

Slips, Trips and Falls

A variety of slip, trip and fall hazards can occur in the home and in the home-office. These include stairs, electrical and telephone cords, toys, pets, papers and other debris or obstacles. Such hazards should be noted during the workplace inspection and corrected.

Administrative Controls

A safety manager or point of contact should be identified for telecommuters to consult with or express workplace safety concerns. Third-party safety consultants may be used on a retainer basis to assist the employee and the employer as necessary. Follow-up actions should be implemented as soon as possible and corrective measures documented.

Workers' Compensation

As a general rule, workers' compensation coverage applies to employees working at home. Employers should verify that their worker's compensation insurance includes coverage for employees working at home and identifies any exclusions. Employees should specify one area in the home as the official work station. Employers would then only be liable for any work-related injuries or illnesses that occur in this area. Employers are responsible for maintaining records of all work-related injuries and illnesses, whether they occur in the main office or in the employee's home.

Timothy S. Mustard, CIH, is a health and safety manager for Parsons Engineering Science, 1700 Broadway, Suite 900, Denver, CO 80290. He serves as project manager or safety manager for hazardous waste operations nationwide.

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