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Advice to Contractors: COVID-19 Prevention & Control Plan

This advice for contractors was originally posted by the Plumbing Contractors Association of Greater Chicago. Our thanks to Executive Director S.J. Peters for permission to repost.

 

Background & Purpose

A. Coronavirus Disease 2019 (COVID-19) is a respiratory disease caused by the SARS-CoV-2 virus. It has spread from China to many other countries around the world, including the United States. Depending on the severity of COVID-19’s international impacts, outbreak conditions — including those rising to the level of a pandemic — can affect all aspects of daily life, including travel, trade, tourism, food supplies, and financial markets.

B. The purpose of this plan is to reduce the impact of COVID-19 outbreak conditions to contractor employees, customers, visitors, and the public.

C. This COVID-19 guidance plan is based on traditional infection prevention and industrial hygiene practices. It focuses on the need for employers to implement engineering, administrative, and work practice controls and personal protective equipment (PPE), as well as considerations for doing so.

D. Employers and workers should use this planning guidance to help identify risk levels in workplace settings and to determine any appropriate control measures to implement. Additional guidance may be needed as COVID-19 outbreak conditions change, including as new information about the virus, its transmission, and impacts, becomes available.

 

About COVID-19

A. Symptoms

1- Infection with SARS-CoV-2, the virus that causes COVID-19, can cause illness ranging from mild to severe and, in some cases, can be fatal. Symptoms typically include fever, cough, and shortness of breath. Some people infected with the virus have reported experiencing other non-respiratory symptoms. Other people, referred to as asymptomatic cases, have experienced no symptoms at all.

2- According to the CDC, symptoms of COVID-19 may appear in as few as two days or as long as 14 days after exposure.

B. How COVID-19 Spreads

1- Although the first human cases of COVID-19 likely resulted from exposure to infected animals, infected people can spread SARS-CoV-2 to other people.

2- The virus is thought to spread mainly from person-to-person, including:

a. Between people who are in close contact with one another (within about 6-ft.).

b. Through respiratory droplets produced when an infected person coughs or sneezes. These droplets can land in the mouths or noses of people who are nearby or possibly be inhaled into the lungs.

3- It may be possible that a person can get COVID-19 by touching a surface or object that has SARS-CoV-2 on it and then touching their own mouth, nose, or possibly their eyes, but this is not thought to be the primary way the virus spreads.

4- People are thought to be most contagious when they are most symptomatic (i.e., experiencing fever, cough, and/or shortness of breath). Some spread might be possible before people show symptoms; there have been reports of this type of asymptomatic transmission with this new coronavirus, but this is also not thought to be the main way the virus spreads.

5- The CDC website provides the latest information about COVID-19 transmission:

a. www.cdc.gov/coronavirus/2019-ncov/about/transmission.html

Prevention & Control Practices

A. For most employers, protecting workers will depend on emphasizing basic infection prevention measures. As appropriate, all employers should implement good hygiene and infection control practices, including:

1- Promote frequent and thorough hand washing, including by providing workers, customers, and worksite visitors with a place to wash their hands. If soap and running water are not immediately available, provide alcohol-based hand rubs containing at least 60% alcohol.

2- Encourage workers to stay home if they are sick.

3- Encourage respiratory etiquette, including covering coughs and sneezes.

4- Provide customers and the public with tissues and trash receptacles.

5- Employers should explore whether they can establish policies and practices, such as flexible worksites (e.g., telecommuting) and flexible work hours (e.g., staggered shifts), to increase the physical distance among employees and between employees and others if state and local health authorities recommend the use of social distancing strategies.

6- Discourage workers from using other workers’ phones, desks, offices, or other work tools and equipment, when possible.

7- Maintain regular housekeeping practices, including routine cleaning and disinfecting of surfaces, equipment, and other elements of the work environment.

a. When choosing cleaning chemicals, employers should consult information on Environmental Protection Agency (EPA)-approved disinfectant labels with claims against emerging viral pathogens.

b. Products with EPA-approved emerging viral pathogens claims are expected to be effective against SARS-CoV-2 based on data for harder to kill viruses.

c. Follow the manufacturer’s instructions for use of all cleaning and disinfection products (e.g., concentration, application method and contact time, PPE).

B. Prompt Identification and Isolation of Sick People, if Appropriate

1- Prompt identification and isolation of potentially infectious individuals is a critical step in protecting workers, customers, visitors, and others at a worksite.

2- The contractor should inform and encourage employees to self-monitor for signs and symptoms of COVID-19 if they suspect possible exposure.

3- All contractor employees shall follow all standard practices for reporting illnesses, when they are sick, and/or experiencing symptoms of COVID-19.

4- Where appropriate, the contractor shall take precautions for immediately isolating people who have signs and/or symptoms of COVID-19.

a. Move potentially infectious people to a location away from workers, customers, and other visitors. Although most worksites do not have specific isolation rooms, designated areas with closable doors may serve as isolation rooms until potentially sick people can be removed from the worksite.

5- Take steps to limit spread of the respiratory secretions of a person who may have COVID-19.

a. Provide a face mask, if feasible and available, and ask the person to wear it, if tolerated. Note: A face mask (also called a surgical mask, procedure mask, or other similar terms) on a patient or other sick person should not be confused with PPE for a worker; the mask acts to contain potentially infectious respiratory secretions at the source (i.e., the person’s nose and mouth).

6- If possible, isolate people suspected of having COVID-19 separately from those with confirmed cases of the virus to prevent further transmission — particularly in worksites where medical screening, triage, or healthcare activities occur, using either permanent (e.g., wall/different room) or temporary barrier (e.g., plastic sheeting).

7- Restrict the number of personnel entering isolation areas.

8- Protect workers in close contact with (i.e. within 6-ft. of) a sick person or who have prolonged/repeated contact with such persons by using additional engineering and administrative controls, safe work practices, and PPE. Workers whose activities involve close or prolonged/ repeated contact with sick people are addressed further in later sections covering workplaces classified at medium and very high or high exposure risk.

C. Communicate Workplace Flexibilities and Protections

1- Actively encourage sick employees to stay home.

2- Ensure that sick leave policies are flexible and consistent with public health guidance and that employees are aware of these policies.

3- Talk with companies that provide your business with contract or temporary employees about the importance of sick employees staying home and encourage them to develop non-punitive leave policies.

4- Do not require a healthcare provider’s note for employees who are sick with acute respiratory illness to validate their illness or to return to work, as healthcare provider offices and medical facilities may be extremely busy and not able to provide such documentation in a timely way.

5- Maintain flexible policies that permit employees to stay home to care for a sick family member. Employers should be aware that more employees may need to stay at home to care for sick children or other sick family members than is usual.

6- Recognize that workers with ill family members may need to stay home to care for them.

a. See CDC’s Interim Guidance for Preventing the Spread of COVID-19 in Homes and Residential Communities: www.cdc.gov/coronavirus/2019-ncov/hcp/guidance-prevent-spread.html.

7- Be aware of workers’ concerns about pay, leave, safety, health, and other issues that may arise during infectious disease outbreaks.

8- Provide adequate, usable, and appropriate training, education, and informational material about business essential job functions and worker health and safety, including proper hygiene practices and the use of any workplace controls (including PPE). Informed workers who feel safe at work are less likely to be unnecessarily absent.

D. Personal Protective Equipment

1- While correctly using PPE can help prevent some exposures, it should not take the place of other prevention strategies. Examples of PPE include gloves, goggles, face shields, face masks, and respiratory protection, when appropriate. During an outbreak of an infectious disease, such as COVID-19, recommendations for PPE specific to occupations or job tasks may change depending on geographic location, updated risk assessments for workers, and information on PPE effectiveness in preventing the spread of COVID-19. Employers should check the OSHA and CDC websites regularly for updates about recommended PPE. All types of PPE must be:

a. Selected based upon the hazard to the worker.

b. Properly fitted and periodically refitted, as applicable (e.g., respirators)

c. Consistently and properly worn when required.

d. Regularly inspected, maintained, and replaced, as necessary.

e. Properly removed, cleaned, and stored or disposed of, as applicable, to avoid contamination of self, others, or the environment.

2- Employers are obligated to provide their workers with PPE needed to keep them safe while performing their jobs. The types of PPE required during a COVID-19 outbreak will be based on the risk of being infected with SARS-CoV-2 while working and job tasks that may lead to exposure.

3- Workers, including those who work within 6-ft. of patients known to be, or suspected of being, infected with SARS-CoV-2 and those performing aerosol-generating procedures, need to use respirators:

4- National Institute for Occupational Safety and Health (NIOSH)-approved, N95 filtering facepiece respirators or better must be used in the context of a comprehensive, written respiratory protection program that includes fit-testing, training, and medical exams.

a. See OSHA’s Respiratory Protection standard, 29 CFR 1910.134 at www.osha.gov/lawsregs/

regulations/standardnumber/1910/1910.134.

b. When disposable N95 filtering facepiece respirators are not available, consider using other respirators that provide greater protection and improve worker comfort. Other types of acceptable respirators include: a R/P95, N/R/P99, or N/R/P100 filtering facepiece respirator; an air-purifying elastomeric (e.g., half-face or full-face) respirator with appropriate filters or cartridges; powered air purifying respirator (PAPR) with high efficiency particulate arrestance (HEPA) filter; or supplied air respirator (SAR). See CDC/ NIOSH guidance for optimizing respirator supplies at: www.cdc.gov/coronavirus/2019-ncov/hcp/respirators-strategy.

c. Consider using PAPRs or SARs, which are more protective than filtering facepiece respirators, for any work operations or procedures likely to generate aerosols (e.g., cough induction procedures, some dental procedures, invasive specimen collection, blowing out pipettes, shaking or vortexing tubes, filling a syringe, centrifugation).

d. Face shields may also be worn on top of a respirator to prevent bulk contamination of the respirator. Certain respirator designs with forward protrusions (duckbill style) may be difficult to properly wear under a face shield. Ensure that the face shield does not prevent airflow through the respirator.

e. Consider factors such as function, fit, ability to decontaminate, disposal, and cost. OSHA’s Respiratory Protection eTool provides basic information on respirators such as medical requirements, maintenance and care, fit testing, written respiratory protection programs, and voluntary use of respirators, which employers may also find beneficial in training workers at: www.osha.gov/SLTC/etools/respiratory. Also see NIOSH respirator guidance at: www.cdc.gov/niosh/topics/respirators.

f. Respirator training should address selection, use (including donning and doffing), proper disposal or disinfection, inspection for damage, maintenance, and the limitations of respiratory protection equipment. Learn more at: www.osha.gov/SLTC/respiratoryprotection.

g. The appropriate form of respirator will depend on the type of exposure and on the transmission pattern of COVID-19. See the NIOSH “Respirator Selection Logic” at: www.cdc.gov/niosh/docs/2005-100/default.html or the OSHA “Respiratory Protection eTool” at www.osha.gov/SLTC/etools/respiratory.

OSHA Standards

A. While there is no specific OSHA standard covering SARS-CoV-2 exposure, some OSHA requirements may apply to preventing occupational exposure to SARS-CoV-2. Among the most relevant are:

1- OSHA’s Personal Protective Equipment (PPE) standards (in general industry, 29 CFR 1910 Subpart I), which require using gloves, eye and face protection, and respiratory protection.

a. When respirators are necessary to protect workers or where employers require respirator use, employers must implement a comprehensive respiratory protection program in accordance with the Respiratory Protection standard (29 CFR 1910.134).

2- The General Duty Clause, Section 5(a)(1) of the Occupational Safety and Health (OSH) Act of 1970, 29 USC 654(a)(1), which requires employers to furnish to each worker “employment and a place of employment, which are free from recognized hazards that are causing or are likely to cause death or serious physical harm.”

3- OSHA’s Bloodborne Pathogens standard (29 CFR 1910.1030) applies to occupational exposure to human blood and other potentially infectious materials that typically do not include respiratory secretions that may transmit SARS-CoV-2. However, the provisions of the standard offer a framework that may help control some sources of the virus, including exposures to body fluids (e.g., respiratory secretions) not covered by the standard.

Workers Living Abroad or Travelling Internationally

A. Employers with workers living abroad or traveling on international business should consult the “Business Travelers” section of the OSHA COVID-19 webpage (www.osha.gov/covid-19), which also provides links to the latest:

1- CDC travel warnings: www.cdc.gov/coronavirus/2019-ncov/travelers

2- U.S. Department of State (DOS) travel advisories: travel.state.gov

B. Employers should communicate to workers that the DOS cannot provide Americans traveling or living abroad with medications or supplies, even in the event of a COVID-19 outbreak.

C. As COVID-19 outbreak conditions change, travel into or out of a country may not be possible, safe, or medically advisable. It is also likely that governments will respond to a COVID-19 outbreak by imposing public health measures that restrict domestic and international movement, further limiting the U.S. government’s ability to assist Americans in these countries. It is important that employers and workers plan appropriately, as it is possible that these measures will be implemented very quickly in the event of worsening outbreak conditions in certain areas.

D. More information on COVID-19 planning for workers living and traveling abroad can be found at: www.cdc.gov/travel.

Training

A. Provide workers with up-to-date education and training on COVID-19 including, but not limited to:

1- Background

2- Signs/Symptoms

3- Risk Factors & Control

4- Control & Protection Techniques (e.g. proper hygiene practices, cough etiquette, and care of PPE).

B. Documentation of all training is required.

 

Any information and/or recommendations contained herein have been compiled from sources believed to be reliable and represent the best current opinion on the subject. No warranty, guarantee, or representation is made by Vista Safety Consulting LLC as to the absolute correctness or sufficiency of any information contained herein. Recommendations and information are advisory and designed to assist clients with the implementation, management and control of their own safety program and activities. Vista Safety Consulting LLC assumes no responsibility for implementation, correction, or control of any conditions or recommendations identified herein. This document does not contain legal advice. For legal advice, contact your own attorney.

 

 
 
 
 
 
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