COVID-19 WORKSITE HEALTH & SAFETY PROGRAM
At Company Name we are committed to ensuring the safety and health of our workforce, including taking the appropriate steps to limit the spread of the novel coronavirus known as SARs-CoV-2 and the disease it causes, COVID-19. The health and safety of our employees, customers, vendors, subcontractors and their families is our top priority. This plan will be communicated clearly to all employees, in their preferred languages, with opportunities for them to give feedback. Because the future of the COVID-19 pandemic is uncertain and circumstances change frequently, we will continue to update this program to follow construction industry best practices to prevent infection and protect our employees. All employees have the right to refuse unsafe work and the obligation to report it to their supervisor.
While we are experiencing this pandemic, Company Name will develop, implement, communicate and review workplace flexibilities and protections. We are actively encouraging sick employees to stay home. Employees who have symptoms are expected to notify their supervisor and stay home. Employees who are well but who have a family member at home with COVID-19 should notify their supervisor and follow CDC recommended precautions at a minimum. Sick employees should follow CDC recommended precautions and not return to work until the criteria to discontinue home isolation are met, in consultation with healthcare providers and state and local health departments.
Note: All policies herein may not be applicable to all employees, depending on their job task; some may apply only to field staff or supervisors in temporary office spaces (e.g., construction trailers).
COVID-19 Compliance Officer
Name of the Person is designated as the COVID-19 Compliance Officer to ensure that Company Name and all subcontractors are in full compliance with these guidelines. The COVID-19 Compliance Officer will perform risk assessments, make company policy recommendations and implement guidelines. It is expected that the COVID-19 Compliance Officer will use an array of public health guidance, including but limited to OSHA, NIOSH, the CDC and the industrial hygiene hierarchy of controls to eliminate, isolate and mitigate COVID-19 hazards on the worksite. The COVID-19 Compliance Officer will work with management to ensure an adequate level of cleaning supplies, tissues and paper towels, hand sanitizer, first-aid supplies, face coverings, respirators (e.g., N95s) and other personal protective equipment (PPE) and other items needed to implement this policy are available on the worksite.
COVID-19 Screening and Assessment Protocols
Company Name will institute worker screening and assessment protocols for everyone who enters the workplace, including employees and visitors (e.g., vendors, inspectors, subcontractors and state officials). The COVID-19 Compliance Officer will ensure these screenings and assessments occur before employees and visitors gain entry to the site. Screening and assessment protocols may include a visual scan and temperature check, self-certification or a questionnaire regarding symptoms and exposure or a combination of these strategies.
The COVID-19 Compliance Officer will choose appropriate and feasible screening and assessment protocols based on the needs of the worksite (see Appendix A – Guidance for Conducting COVID-19 Workplace Screenings and Assessments). The COVID-19 Compliance Officer will communicate these protocols clearly to all employees and subcontractors prior to their implementation.
Critical Infrastructure Employees
The CDC advises that critical infrastructure workers may be permitted to continue work following a potential exposure to COVID-19, provided they remain asymptomatic and additional precautions are implemented to protect them and the community.
For critical infrastructure workers who have had a potential exposure to COVID-19 but remain asymptomatic, the COVID-19 Compliance Officer will ensure adherence to the following practices prior to and during their work shift:
- Pre-screening: Measurement of the employee’s temperature and assessment of symptoms prior to starting work. If possible, temperature checks will happen before the employee enters the facility.
- Social distance: The employee will maintain a distance of six feet from other workers and practice social distancing as work duties permit while in the workplace.
- Regular monitoring: As long as the employee remains asymptomatic, the employee will self-monitor and be under supervision.
- Clean and disinfect work spaces: Clean and disinfect all equipment and areas such as trailers, bathrooms, common areas and shared tools.
- Wear a mask: The employee will wear a face mask without an exhalation valve at all times while in the workplace for 14 days after last known exposure.
If any critical infrastructure employee becomes symptomatic during the day, they will be sent home immediately. Surfaces in their workspace will be cleaned and disinfected. Information on persons who had contact with the sick employee during the time the employee had symptoms and two days prior to symptoms will be compiled. Others at the facility with close contact within six feet of the employee during this time are considered exposed. These workers will follow exposure protocols detailed in Appendix A – Guidance for Conducting COVID-19 Workplace Screenings and Assessments.
Worker Hygiene Policy
Good hygiene and infection control practices will be followed according to CDC guidelines, as a minimum. Employees are required to wash hands frequently with soap and water for at least 20 seconds or use hand sanitizer when soap and water are not available. Workers should following handwashing practices:
- Upon arriving at the workplace and before going home at the end of the day
- Before and after eating
- Between tasks
- After using the toilet
Temporary handwashing stations will be supplied when there is no ready access to an indoor bathroom and washing facilities. Garbage cans will be supplied next to handwashing stations and toilets for disposal of tissues/towels.
Employees are required to practice good cough/sneezing etiquette –cover their mouth and nose during coughs or sneezes and use their sleeve or elbow when tissues are not available. Employees will not use their hands to cover coughs and sneezes and will avoid touching their eyes, nose and mouth as much as possible.
Company Name is instituting a regimen of frequent cleaning and disinfection of high-touch surfaces, including but not limited to toilets, machinery, tools, PPE, handles, smartphones, doors, door knobs, railings, laptops and furniture. EPA-approved cleaning disinfectants will be used. Disinfectants will be allowed to saturate surfaces for a minimum time of one minute in order to adequately disinfect them. Regular cleaning and disinfecting of all common and meeting areas will occur at least once and preferably twice a day. The COVID-19 Compliance Officer will ensure there is a schedule for cleaning, sanitizing and stocking of all restroom facilities, porta-potties and handwashing stations. In addition, workers must clean and disinfect all machines, tools or vehicles before use.
All employees performing sanitation and disinfecting will:
- Wear PPE. This will include N95 respirators or similar (if a respirator cannot be obtained because of PPE shortages, a facemask or covering will be worn until a respirator can be obtained), disposable gloves, protective clothing and eye protection.
- Discard gloves after each cleaning.
- Clean dirty surfaces using a detergent or soap and water prior to disinfection.
- Be trained on safe donning, doffing and disposal of PPE to avoid infectious disease transmission.
- Clean hands immediately after PPE is removed.
- Be medically able to wear the type of respirator needed and trained on how to use it.
- Be aware of the differences between dust masks and N95s. Dust masks do not reliably protect the wearer from airborne respiratory droplets.
Company Name will practice physical (also called social) distancing by limiting person-to-person contact within six feet (Six-Foot Rule). All employees will follow the Six-Foot Rule on the workplace, whether indoors or outdoors. Specific Six-Foot Rule guidelines include:
- Instituting a “No Congregation” policy to maintain physical distancing during breaks and when eating. Employees may take a lunch break, but the Six-Foot Rule does not.
- Practicing physical distancing at all times, including at crew meetings/toolbox talks. Toolbox talks will be conducted outdoors.
- Limiting face-to-face meetings to 10 people or less. As much as possible, meetings between office staff will be conducted via conference call or other virtual meeting tools. Meetings at the jobsite or requiring in-person discussion will be held outdoors if possible and follow the Six-Foot Rule.
- Eliminating coffee and lunch trucks and the use of centralized gathering or eating areas. All employees are advised to bring their own food, drink and utensils.
- Adjusting meeting and lunchroom seating to eliminate large gatherings. Small break areas will be used with limited seating. If break areas cannot be adjusted, employees will take steps to follow the Six-Foot Rule (e.g., sit adjacent to rather than directly across from each other, eat outside of work areas).
- Reviewing and adjusting project schedules to allow for the Six-Foot Rule, including arranging for staggered shifts or longer break times so employees can maintain distance during breaks, including lunch.
- Supplying employees with facial coverings and PPE according to the risk and job task (e.g., face mask or N95 respirator, face shield, gloves and eye protection) in work conditions where the Six-Foot Rule is impossible to achieve.
Personal Protective Equipment (PPE)
Company Name will allow voluntary use of N95 respirators or equivalent. The company will implement a mandatory face covering policy. Although not recognized as PPE, surgical masks and facial coverings will also be permitted. This policy will be continually reviewed and updated according to the specific risks encountered on the jobsite.
All appropriate and required PPE will be provided to employees. The decision to provide specific PPE (e.g., gloves, respirators, protective clothing, eye protection, etc.) to protect against COVID-19 will follow a risk assessment conducted by the COVID-19 Compliance Officer. Use of PPE required by regulatory standards will not be affected by this program.
All employees will receive training regarding this policy and exposure control. This training will include the signs and symptoms of COVID-19, how to prevent exposure and transmission of COVID-19, the reasons for staying home from work when sick and how to use COVID-19 safety supplies and PPE.
All international travel activities will be terminated and future travel activities will be postponed until the COVID-19 outbreak is officially declared over by the federal government. After it has been determined it is safe to travel, international travel will be gradually phased back into our business continuity plan.
Regional and local
We will examine our travel policy and modify it based on the specific state or local guidance in the area where work is being performed. If there is significant community spread within a geographic area, non-essential work travel and work-sponsored conferences, trade shows, etc., within that area will be canceled until further notice. We will take into account the circumstances along the travel route and at the destination of an employee’s proposed travel. Name of Company will abide by any travel restrictions in the destination area and be aware of state or local government policies that may be in place, such as mandatory quarantine upon arrival.
Company Name will follow OSHA’s recordkeeping requirements (29 CFR Part 1904) as it relates to recording cases of COVID-19. Under OSHA’s COVID-19 Interim Guidance for Recordkeeping Requirements, COVID-19 is a recordable illness if all of the following apply:
- Is a confirmed case ofCOVID-19
- Is work-related (as defined by 29 CFR 1904.5)
- Involves one or more of the general recording criteria (29 CFR 1904.7), such as medical treatment beyond first aid or days away from work
Company Name will establish additional policies and practices to increase compliance with the COVID-19 Worksite Safety & Health Program. Strategies under consideration include:
- Flexibility regarding in-person attendance for office staff (e.g., telework).
- Implementing flexible work hours (e.g., staggered shifts).
- Downsizing operations.
- Developing non-punitive leave policies.
- Not requiring a healthcare provider’s note for employees who are sick with acute respiratory illness to validate their illness 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.
- Assigning employees who may be at higher risk for serious illness, such as older adults and those with chronic medical conditions, work tasks that allow them to maintain a distance of six feet from other employees, customers and visitors or to telework if possible.
- Implementing plans to continue essential business functions in the circumstance that higher than usual absenteeism occurs.
- Delivering products through curbside pick-up or delivery.
Company Name will take opportunities to support employee well-being and resilience by helping to address potential health impacts, such as depression, posttraumatic stress disorder (PTSD), substance use disorder and other mental health-related disorders.
- Provide frequent and comprehensive communication with employees before, during and after the transition back to work/jobsites
- Provide resources related to physical, mental, emotional and financial well-being
- Provide available employee assistance program (EAP) or member assistance program (MAP) information to support workers in addressing their mental health
- Provide materials on bereavement, loss and grief to help employees cope with the loss of co-workers, family members or loved ones
- Consider coordination of critical incident stress management services through the EAP or the Laborers’ Health & Safety Fund of North America if an employee passes away due to COVID-19 or a jobsite critical incident
Recommendations to limit the spread of COVID-19 and mitigate the risk to employees may change as public health officials learn more about the virus. The contents of this program were developed based on guidance and best practices from the following sources:
CDCM – Coronavirus (COVID-19) – www.cdc.gov/coronavirus/2019-ncov
OSHA – OSHA Guidance on Preparing Workplaces for COVID-19 – www.osha.gov/Publications/OSHA3990.pdf
NIOSH – Coronavirus Disease-2019 – www.cdc.gov/niosh/emres/2019_ncov.html