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Impact of New OSHA Laws on Hands-On Training Curriculum in Higher Ed

8 February, 2021 | Sebastian Andreatta

Personally Identifiable Information Data secure digital contact tracing
States across the U.S. are implementing a variety of personnel protection programs to drive clearer guidelines on managing COVID-19 exposure throughout their facilities, campuses and buildings. Many states have begun implementing regulations to provide health and safety measures targeted at making sure schools have measures in place to rapidly alert those exposed and protocols to reduce further exposures.

Illinois, Kentucky, Massachusetts, Pennsylvania, Minnesota, Nevada, Washington, Virginia, Michigan, New York, New Jersey, Maryland, and Louisiana have enacted OSHA and Health and Safety measures that address these mandates. Other states are expected to follow and the Department of Labor in the Biden Administration is now looking to implement this at a national level.

California has been the most aggressive state in rolling out OSHA measures. Starting January 1st, California, with Assembly Bill 685 (AB685), jumped to the forefront of using OSHA regulations to extend pandemic safety regulations to all employees, staff, students, and regular visitors to all public and private sites/facilities.

In the California bill, the basic requirements are to notify within 24 hours anyone who has been exposed to a known COVID case, their union representative where there is one, and local and state boards of health. Penalties for non-compliance are substantial, ranging from $25,000 to $100,000 in addition to immediate site closure. This may be the most impactful of all, since an instance of exposure may subject your institution to an immediate 2 week closure. Although not all states are enacting such stringent measures, most have some version of this either in assembly or near enactment.

Throughout the pandemic, colleges, universities and schools in general have grappled with their own responses to maintaining educational objectives. In most cases, the focus has been to provide online instruction or some form of hybrid instruction with varying degrees of success.

For most of these institutions, the new OSHA requirement will have little impact since most staff and students are not onsite risking exposure to a COVID case. However, several disciplines require either onsite training, instruction or lab work. Typical of this are nursing programs, where some hands-on training is required, physical sciences requiring lab instruction, and for many community colleges, programs such as Culinary, Machinist, EMT and others need students to be onsite for some or all of the practical instruction required for certification. Similarly, schools with large foreign student populations have to continue maintaining housing for these groups.

As these new statewide measures begin to roll out in earnest this winter and spring, there is cause for administrators to provide compliance beyond some of the measures they are currently taking.

App-based approaches have mostly demonstrated to be inadequate in providing any measure of assurance of exposure, and their nature requires an all or nothing approach in use and regular reporting by App users. Low adoption rates and low user engagement have created situations of false positives (the app reports contact where there is none), and false negatives (people believe that no notification means they haven’t been in contact, thereby lowering their guard in maintaining safety measures). Current manual contact tracing methods are both lengthy, time consuming (outside of the obvious privacy flaws), with low response rates and don’t offer the immediacy of identifying, tracing, alerting and reporting to health departments and unions that digital tracing methods provide.

Successful implementations of these technologies have been functioning in place across the United States for several months, in the best cases, the investment is in the service, with little or no additional hardware needed. Best-of-breed solutions will also provide greater value for long-term campus use through additional capabilities that justify integration into an institution’s operations.

Kiana Analytics has been a leader in real-time location sensing services for personnel and asset management, operations, and safety through our Smart Facilities Management platform. Our extensive experience in privacy-centric people sensing and asset management has put us in a leadership role in real-time exposure notification services for infectious disease management such as COVID-19). Once an exposure is identified, our exposure notification feature helps you immediately identify and alert all affected individuals (preventing further viral exposures), locate the exact areas to be closed for surgical cleaning and provides facilities with long-term data to re-engineer public use areas to improve social distancing guidelines as they develop.

Our Software as a Service platform leverages a site’s existing Wi-Fi infrastructure and requires no software on any user’s device, while integrating into a site’s own health and safety framework. Our patented location sensing solution delivers operations management features such as asset tracking, a safety/security mobile app, rogue device identification and visitor management, delivering multiples of return on your investment beyond just contact tracing compliance with the law.

Kiana is under contract with E&I to deliver our unique digital contact tracing tool as part of our complete suite of Smart Facilities platform features. For more information, please visit us at our E&I microsite or at  If you have an immediate need or wish to see a live demo, contact Sebastian Andreatta at