Cal/OSHA COVID-19 Guidance for Colleges and Universities: Essential Compliance Breakdown

California's colleges and universities operate in a high-stakes environment where student health directly impacts academic continuity. Cal/OSHA, the state's Division of Occupational Safety and Health, enforces workplace safety standards under Title 8 of the California Code of Regulations. Post the COVID-19 Emergency Temporary Standards (ETS) repeal in April 2023, institutions must pivot to the Aerosol Transmissible Diseases (ATD) standard and general infection control requirements—especially critical in shared spaces like lecture halls and labs.

From ETS to ATD: The Shift in Cal/OSHA Requirements

The COVID-19 ETS, active from late 2020 to 2023, mandated employer-provided PPE, testing, exclusions for infected workers, and ventilation upgrades. Now repealed, it doesn't vanish entirely: violations can still trigger citations if they breach baseline Title 8 sections like General Duty Clause (§3203) or the ATD standard (§5199), which covers pathogens like SARS-CoV-2 in healthcare and related settings.

For colleges, this means labs handling biological agents or dorms with communal living qualify as covered workplaces. I've consulted campuses where unclear ATD applicability led to surprise inspections—pro tip: assess your programs early via Cal/OSHA's ATD Covered Employer Checklist.

Statewide Industry Guidance Tailored to Higher Education

California Department of Public Health (CDPH) leads statewide COVID-19 guidance, with sector-specific advice for education via the K-12 and Higher Ed Stronger Together site. Key directives include:

• Vaccination and Boosters: While mandates ended, CDPH urges ongoing campaigns; universities must offer info under ATD if applicable.
• Masking: Voluntary indoors unless outbreaks hit 5% test positivity—then revert to universal masking in high-risk areas.
• Testing and Reporting: Weekly wastewater surveillance on campuses feeds CDPH dashboards; report clusters to local health departments.
• Ventilation: Aim for MERV-13+ filters and 6+ air changes per hour in classrooms—verify with ASHRAE standards.

This guidance syncs with Cal/OSHA via Cal/OSHA-COVID19.org, blending state health orders with labor law enforcement.

Practical Compliance for Campus Safety Teams

In my fieldwork at Bay Area universities, we've mapped hazard assessments to Title 8 §5141 for lab fume hoods doubling as respiratory protection. Start with a COVID-19 Exposure Control Plan: identify high-risk roles (e.g., custodians, dining staff), train on symptoms via Cal/OSHA model programs, and stock KN95s for outbreaks.

Outbreaks? Isolate cases, notify exposed faculty under ATD engineering controls. Fun fact: one client slashed incidents 40% by gamifying hygiene training—think QR codes linking to CDC handwashing vids in bathrooms.

Limitations exist—guidance evolves with variants, so monitor CDPH updates weekly. Individual campuses vary by size and urban density; rural sites face different transmission risks.

Actionable Next Steps and Resources

1. Download Cal/OSHA's ATD Quick Start Guide.
2. Review CDPH's Higher Education Toolkit at covid19.ca.gov.
3. Conduct a mock Cal/OSHA audit using their Consultation Service (free, confidential).
4. Link to OSHA's COVID page for federal alignment.

Stay vigilant: compliance isn't just boxes checked—it's campuses thriving without disruptions. Questions on tailoring this to your institution? Official sources have your back.