Navigating the CDPH CAL/OSHA COVID-19 Industry Guidance for Private Venues and Events

What Venue and Event Planners Need to Know About COVID Testing Regulations for Events, Weddings and Gatherings

There is a lot to interpret in the new CDPH CAL/OSHA Guidelines for Private Venues and Events. Some of the rules are straight-forward while others will leave more unanswered questions and cause Venues to work to interpret their meaning, who is responsible, and how to implement them.

Rather than attempt to fill in those blanks I've offered my perspective on the guidelines and how you can best understand their intent.

I've also  inserted relevant links below (the first is the most comprehensive "Handbook") and I'll continue to post updates and associated links as they come available. Some of the guidance will cross industry lines. For example, private events and venues are under the April 15 rules. Those same venues may also be under the March 26 guidelines. I always suggest having counsel look at this per each venue/client.

What's important to bear in mind as we open up and new regulations come online is that there is an underlying point and methodology to what OSH and the CDC are implementing.

The rules and guidelines are put in place because removing the current Tier System comes with risk unless balanced by other targeted safety measures. We don't want to go backwards so we will instead go forward by implementing safety measures where people are perceived to be most at risk.

The onus of testing being put on gatherings and venues is therefore a method of enforced restraint and ballast to our finally opening up and ending stay at home orders.

In the end, what businesses of all stripes need to develop is a defensible policy that would indicate to an enforcement agency that great thought and effort has been expended to interpret and implement these standards. As a companion to that I believe OSHA and the CDPH want to see that a company/venue has invested materially in the safety of their patrons and in meeting the guidelines. Half measures may be interpreted as a company's being oppositional to these directives (in my opinion).

 

Our most successful clients have used the forced expenditure for things like testing and other safety measures with a mind towards ROI by touting their respect for people's safety and investment in measures to create a safe environment, and then stating (even "virtue" marketing) how they wish to be a place where people feel respected, safe and have real peace of mind- freeing them to enjoy the show/event. It can give a venue/business a leg up on the competition and something positive to talk about that resonates with their clientele and employees.

 

1 COVID-19 INDUSTRY GUIDANCE: Private Venues and Events April 14, 2021 Effective April 15, 2021 This guidance is designed to address sectors and activities opening statewide.

files.covid19.ca.gov

1 1 COVID-19 GUIDANCE: Outdoor Seated Live Events and Performances March 26, 2021 Effective April 1, 2021 . This guidance is designed to address

files.covid19.ca.gov

https://www.dir.ca.gov/dosh/coronavirus/COVID19FAQs.html#controls

EnforcementBack to top. Q: How will Cal/OSHA enforce the ETS as employers implement the rule? A: All employers are expected to comply with all provisions of the ETS, and Cal/OSHA will enforce the ETS, taking into consideration an employer's good faith efforts to comply. In addition to consideration of an employer's good faith effort to comply before issuing a citation, for the first two months ...

https://www.cdph.ca.gov/Programs/CID/DCDC/CDPH%20Document%20Library/COVID-19/Dimmer-Framework-September_2020.pdf

Blueprint for a Safer Economy Activity and Business Tiers April 19, 2021 . SECTORS Tier 1 Widespread Tier 2 Substantial Tier 3 Moderate Tier 4

 

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