Guidance for the Agriculture Industry

Guidance purpose and additional resources

Farm workers are part of our critical workforce and may face greater risk of exposure to COVID-19. It is imperative that employers implement safety measures and modifications to workflows and processes where possible to help prevent the spread of COVID-19 within their workplaces, consistent with state public health orders and the guidance contained in this document. The U.S. Centers for Disease Control and Prevention (CDC) and U.S. Department of Labor’s Interim Guidance for Agriculture Workers and Employers should be followed by workers and employers in this industry. The following guidelines provide additional best practices for the prevention and mitigation of COVID-19 among workers in the farm and agriculture industries and distill Colorado Public Health Order 20-28 as applied to the Colorado agricultural industry.

Employers should review CDPHE’s Guidance for Preventing, Reporting, and Mitigating Workplace and Non-Health Care, Non-Residential Facility Outbreaks as well as the CDC’s Coronavirus Disease 2019 (COVID-19) - Interim Guidance for Businesses and Employers, and ensure all provisions are followed. Additionally, the Occupational Safety and Health Administration (OSHA) and CDC’s joint Interim Guidance for Meat and Poultry Processing Workers and Employers provides recommendations for COVID-19 exposure risk reduction for meat/poultry processing facilities; several of the concepts and examples within can be translated to relevant processes in the agricultural industry as a whole.

Preventing the spread of COVID-19 at work sites

The following requirements derive from Public Health Orders 20-26 (Face Coverings for Critical Businesses) and 20-28 (Safer at Home and in the Vast, Great Outdoors), which apply to agricultural employers in Colorado. Best practices for complying with these orders, specific to the agricultural industry, are additionally provided. 

Per PHO 20-28(II)(I)(1)(a), and aligned with CDC’s agriculture worker guidance, employers should deputize a workplace coordinator(s) charged with addressing COVID-19 issues and being responsible for assessment and control plans.

LPHA Sources for Migrant and Seasonal Farmworker Outreach | Español 

  • Per PHO 20-26(I)(A), all employees working in critical businesses (which includes agricultural industry workers) are required to wear face coverings (medical or nonmedical-grade masks) that cover their nose and mouth while working if they routinely or consistently come within 6 feet of other workers or the public, except when doing so would inhibit the individual’s health. 
    • Employers must supply personal protective equipment, including face coverings, for the employees. See PHO 20-28(II)(I)(2)(g). It is appropriate for workers to wear their own masks if they prefer, given that those masks meet the requirements in PHO 20-26. 
    • The US Food and Drug Administration (FDA) factsheet Use of Face Coverings in the Food Sector During COVID-19, which describes respirators, disposable face masks, and cloth coverings appropriate for use in the agricultural industry, should be used as a reference to choose the appropriate face covering for workers. 
    • PPE worn for specific jobs that require it for non-COVID reasons should continue to be worn. PPE should be disposed of after each shift, or disinfected with an EPA-approved disinfectant and stored in a clean location between uses. 
    • Cloth face coverings may pose some work-related challenges. Cloth coverings may be uncomfortable to wear for extended periods in hot environments. When worn during physical labor, it may require touching of the face and repositioning of the coverings and could create hazardous situations if the face covering impedes proper operation of equipment. Workers and employers should be mindful of risk for heat stroke and physical injury that could occur as a result of performing certain tasks while wearing masks, and balance these risks with the benefit of mask-wearing on a case-by-case basis. Further physical distancing should be encouraged in situations where face masks are deemed not safe or practical.
  • Per PHO 20-28(II)(I)(2)(e), employers must encourage breaks to wash hands or use hand sanitizer. Employers should provide access to handwashing/hand sanitizing facilities, consistent with federal and state law (e.g., 29 C.F.R. § 1928.110(c) and 40 C.F.R. § 170.411, 170.509 and 170.605(h)-(j)). 
    • For transient work stations or field work, additional portable hand washing stations should be established to encourage additional hand hygiene. 
    • Adequate water sources, liquid soap, disposable paper towels, and trash cans should be made available throughout the workplace to provide additional, ready access to hand hygiene stations. 
  • Per PHO 20-28(II)(I)(1)(c) and (h), employers must clean and disinfect all high touch areas and must eliminate or regularly clean and disinfect any items in common spaces, such as break rooms, that are shared between individuals. 
    • High-touch areas include, but are not limited to, toilets, handwashing/sanitizing facilities, drinking water dispensers, and rest/break area tables and chairs.
    • CDC guidance for Cleaning and Disinfecting Your Facility and CDPHE’s Cleaning Guidance should be followed. EPA-approved disinfectants should be used. 
    • Employers should provide access to drinking water in a safe and sanitary manner. 
      • Communal water sources that require workers to touch spigots/spouts should be avoided unless adequate, frequent sanitation of the high-touch surface can be ensured.
        • Hand sanitizer should be placed alongside communal water supplies and workers should sanitize hands before touching the water supply’s spigot/spout. Alternatively, employers could provide disposable gloves to be used for accessing communal water sources. 
        • Employers should consider providing a communal access source for bottled water as an alternative to shared water jugs.
    • Employers should provide access to cleaning/sanitation supplies for all equipment used by workers. 
      • Workers should be assigned one set of equipment or tools per shift, that is not shared. Equipment or tools should be sanitized at the end of a shift. 
      • Equipment that is shared between workers on the same shift should be cleaned and disinfected between each user if possible. If disinfecting between users is not possible, the equipment should be cleaned at least once per shift and workers should be encouraged to wear gloves when handling the shared equipment.

  • Per PHO 20-28(II)(B), employers must implement physical distancing to the extent possible in the workplace. 
    • Workflow and process modifications should be made to allow 6-foot distancing between coworkers during all tasks. See PHO 20-28(II)(I)(1)(b). This includes, but is not limited to, working in fields and packing sheds. 
      • For processing tasks where the spacing of workers is dictated by equipment or production lines, modifications may include:
        • Installation of plexiglass partitions between workstations.
        • Slowing the production line to allow fewer workers and greater spacing.
        • Reducing the size/weight of material being lifted or processes to accommodate one instead of two workers per task.
      • Proper ventilation is always required. See PHO 20-28(II)(I)(1)(e).
  • Employers who provide transportation to and from communal/employer-sponsored housing and or throughout worksites should do so in a manner that adheres to physical distancing guidance. 
    • Reduce capacity in transport vehicles to allow for physical distancing between occupants.  This can be achieved by providing additional vehicles and/or by making multiple trips. 
    • Face coverings should be worn by individuals while riding in shared transportation.
    • Transportation vehicles must be disinfected regularly per CDC guidance for Cleaning and Disinfection for Non-emergency Transport Vehicles
    • Employers should encourage face mask wearing and cleaning in shared vehicles among employees who carpool together, even when that is not an employer-sponsored transportation service.
  • Per PHO 20-28(II)(I)(2)(f), employers must phase shifts and breaks to reduce density. Employers must implement strategies such as staggered schedules or re-designing workplaces to create more distance between workers unless doing so would make it impossible to carry out critical functions. See PHO 20-28(II)(B).
    • Staggered work shifts and cohorting of workers (e.g., pairing individuals to the same shifts and not crossing shifts day-to-day or week-to-week) can reduce interactions among coworkers and limit workers to interactions in small groups. 
    • Staggered break times can reduce the number of individuals sharing break rooms. 
    • The space provided for breaks should have adequate room to allow physical distancing of at least 6 feet between individuals who are on their breaks at the same time. Reducing the number of chairs in break rooms or around tables can encourage less congregating.
    • Break spaces should include hand washing/sanitizing facilities; particularly if break times are used by workers for eating, smoking, and/or tobacco use where hand-to-mouth contact will occur more frequently. 
    • Additional clock-in/clock-out stations should be installed to reduce congregation at shift changes.

  • Per PHO 20-28(II)(I)(1)(g), employers must implement symptom monitoring protocols, conduct daily temperature checks, and monitor symptoms in employees at the worksite to the greatest extent possible, or if not practicable, through employee self-assessment at home prior to coming to the worksite. Employers should conduct screening of workers for COVID-19 symptoms at the start of each shift.
    • If employees use shared transportation to travel to worksites, screening should occur prior to boarding shared transportation.
    • Recommended screening protocols are described in the CDPHE Workplace Outbreak Guidance. Sample screening forms can be found here: Employee Health Screening Form and Employee Health Self-Screening Log.
    • If an employee reports any symptoms, refer symptomatic employees to the Colorado COVID Symptom Support tool and take all of the following steps.
      1. Send employee home immediately (see Quarantine Housing Accommodations, below);
        • Employers must require employees to stay home when showing any symptoms or signs of sickness, and connect employees to company or state benefits providers. See PHO 20-28(II)(I)(2)(a).
      2. Increase cleaning in your facility and require physical distancing of staff at least 6 feet apart from one another;
      3. Exclude employee until they are fever-free, without medication, for 72 hours and 10 days have passed since their first symptom; and
      4. If multiple employees have these symptoms, contact your local health department.
  • Employers must permit workers who experience any COVID-19 like symptoms to stay home and seek medical attention. Employers must not penalize employees for taking sick leave. 
  • Employers should implement policies such as access to paid time off to encourage individuals who are sick to stay out of the workplace (see Access to Medical Attention, Sick Leave, and Wage Loss Benefits section below).
  • Employers should post materials on good hygiene (see PHO 20-28(II)(I)(1)(d)) and describing COVID-19 signs and symptoms, in English, Spanish, and any other common language of their workers, in prominent locations throughout their workplace.

Employer-provided housing, especially when use is a requirement of the job, must comply with physical distancing and cleaning/sanitation requirements expected for workplaces. Employers who sponsor housing for workers, including accommodations in houses, motels, dormitories, and mobile homes, should abide by the CDC’s COVID-19 Guidance for Shared or Congregate Housing. The following are additional recommendations on specific practices that will, in most cases, ensure housing complies with the PHO requirements and CDC guidance. Employers are encouraged to reach out to their local public health agency for proactive support in ensuring the housing they provide adheres to best practices. 

  • Shared sleeping quarters should be arranged to allow a minimum of six feet between beds and increased total square footage per person (recommended to at least double the OSHA standard minimum, to 100 square feet per person). 
    • Arrange beds with alternating head-to-toe alignment to further space breathing zones while sleeping. 
    • Assign a single bed to each worker; shared units (e.g., bunk beds) are not advisable as they may not provide 6 feet of distancing and additionally create surfaces that are touched by multiple individuals, presenting a challenge for adequate sanitation/cleaning. 
    • Ensure adequate ventilation provided in sleeping quarters (e.g., screened windows that open, or fans). 
  • Routine cleaning and disinfection of the employer-provided housing is to be ensured by the employer without cost to the employee(s). Common use spaces (e.g., kitchens, bathrooms, living rooms, dining rooms, laundry services) are to be cleaned with EPA-approved disinfectants more than once per day.
    • Common use spaces should be consistently stocked with handwashing and hand sanitizing supplies.
    • Face masks should be worn in common use spaces within employer-provided housing at all times.
    • Common use spaces should be adequately sized for the number of individuals in the shared housing unit to allow 6-foot physical distancing at all times. Adequate numbers of tables, seating, etc. should be provided to allow distancing.
  • Shared dining facilities should have adequate dishware and cutlery so that sharing is not necessary. Consider providing single-use food service items.
  • In light of COVID-19 risks, it is recommended that employers increase the number of housing units to accommodate more distance between residents. 
    • Additional housing accommodations are to be provided for any worker who becomes sick and/or has been in close contact with a confirmed COVID-19 case, to allow adequate isolation/quarantine from coworkers in shared housing. Individuals who experience symptoms of COVID-19 are to have access to facilities that allow them to isolate from asymptomatic individuals, including separate sleeping quarters, bathrooms, and kitchens. 
      • Per OSHA regulation 29 C.F.R. § 1910.142, individuals who have contracted COVID-19 are not permitted to use communal kitchen/dining facilities, and employers are required to report instances of illness occurring in employer-provided housing to public health authorities. 
      • Hotel/motel rooms (with kitchen facilities) in the area could be considered as an option for acquiring additional housing. Contact the Colorado Department of Labor and Employment (CDLE) for help identifying appropriate housing options. 
  • If an employee who lives in shared housing becomes sick, they should be isolated away from other workers. Alternative housing arrangements should be provided if needed to appropriately isolate and quarantine sick or exposed workers from others. 
  • For H-2A temporary housing considerations, review the Department of Labor’s explanation of alternative housing arrangements in response to COVID-19.

All employees, including U.S. citizens and H-2A visa workers, who are exhibiting COVID-19 symptoms are eligible to receive medical treatment and, if necessary, testing, via the Emergency Paid Sick Leave Act and Emergency Family and Medical Leave Expansion Act (both part of the Families First Coronavirus Response Act [FFCRA]) which became effective April 1, 2020. The FFCRA ensures access to medical testing and treatment for COVID-19 for all individuals living and working in Colorado, regardless of immigration status and health insurance status. 

CDC’s Guidance for Agriculture Workers and Employers contains detailed information regarding workers’ rights. The Occupational Safety and Health Act of 1970, 29 USC 660(c), Section 11(c), prohibits employers from retaliating against workers for raising concerns about safety and health conditions. Additionally, OSHA’s Whistleblower Protection Program enforces the provisions of more than 20 industry-specific federal laws protecting employees from retaliation for raising or reporting concerns about hazards or violations. 

CO-HELP operators can provide support in several languages, including English, Spanish, and Mandarin. 

Reporting suspected or known cases will allow employers to receive support for implementing workplace infectious disease control and assessing/managing any workplace-related outbreak. 

The employer should report suspected or known cases to the local public health agency (see below) or to CDPHE. Workers with concerns that their employer is not adequately responding to known or suspected COVID-19 cases among employees can also call the COVID hotline to report. Reports can be made anonymously, via English or Spanish.

The local public health agency of each county is available to respond to questions and concerns and to support the local community in COVID-related issues. The local public health agency can also communicate concerns to CDPHE. Contact information for each county’s local public health agency can be found at colorado.gov/pacific/cdphe/find-your-local-public-health-agency.

Consulate General of Mexico in Denver: Through the Department of Protection, the Consulate provides assistance to Mexican farmworkers who reside in Colorado and to those working temporarily under the H2A visa prpgram

(303) 667-8657 (available 24/7) | infodenver@sre.gob.mx

The Guatemala Consulate in Denver has been updating its Facebook page with information about COVID-19, testing sites, and emergency numbers.

Employers should post this guidance in key areas throughout the worksite. The postings should be located in multiple highly-trafficked areas, such as common areas of housing, workplace entry/exit doors, workplace common areas, bathroom stall doors, and above water fountains/receptacles. Posting must be in a language understood by the workers.  

Employers are also encouraged to post additional information regarding best health practices including hand washing frequency and personal hygiene practices, a description of COVID-19 signs and symptoms, as well as additional resources available to workers in Colorado. CDC’s Communication Resources (also available in Spanish) and CDPHE’s Communication resources pages contain links to a variety of print resources, videos, and public service announcements. CDPHE’s Resources in other languages webpage contains links to a variety of COVID-19 materials in languages other than English, including communication resources and translated press releases and public health orders. 

Compliance with the public health orders cited throughout this guidance document is mandatory and enforceable by the state and local public health agencies. The additional recommendations and examples provided are enforceable to the extent that they illustrate compliance required by the public health orders or other state and federal law.