This document was derived from and developed by Construction Industry Safety Coalition (CISC) on March 25, 2020 and revised by The Associated General Contractors of America (AGC) March 30, 2020. This document refers to managers, supervisors and employees and is incorporated by reference to mean those of any contractor, subcontractor, material supplier or vendor on all Dale Corp. construction sites.
Dale Corp. is a proud part of the construction industry, which has been deemed “essential” throughout the country during this Declared National Emergency. In order to be safe and maintain operations, we have developed this COVID-19 Exposure Prevention, Preparedness, and Response Plan to be implemented, to the extent feasible and appropriate, throughout the Company and at all of our jobsites. The Company’s Risk Management Team will continue to monitor the related guidance that U.S. Center for Disease Control and Prevention (“CDC”) and Occupational Safety and Health Administration (“OSHA”) make available and implement the recognized best safe work practices on our projects. Our Safety Plan, along with this addendum, is a living document and is subject to change based on further information provided by the CDC, OSHA, and other public officials.
COVID 19 is a respiratory disease caused by the SARS-CoV-2 virus. Symptoms typically include high fever, dry cough and shortness of breath. These symptoms are somewhat complicated by the fact we are still in the midst of Flu season and now allergy season. Regardless, the rules remain the same. We are directing our subcontractors to follow our daily sign in protocol and if any of their employees have any of those symptoms, direct them to contact their healthcare professional immediately and stay home. We ask in the good fellowship and morality of all contractors during this time, that if any of your employees are sick, to please stay home.
OSHA and the CDC have provided the following control and preventative guidance for all workers, regardless of exposure risk:
In addition, employees must familiarize themselves with the symptoms of COVID-19, which include the following:
If you develop a fever and symptoms of respiratory illness, such as cough or shortness of breath, DO NOT GO TO WORK and call your supervisor and healthcare provider right away. Likewise, if you come into close contact with someone showing these symptoms, call your supervisor and healthcare provider right away.
o Have you been confirmed positive for COVID-19?
o Are you currently experiencing, or recently experienced, any acute respiratory illness symptoms such as fever, cough, or shortness of breath?
o Have you been in close contact with any persons who has been confirmed positive for COVID-19?
o Have you been in close contact with any persons who have traveled and are also exhibiting acute respiratory illness symptoms?
o Gloves: Gloves should be worn appropriate to the task. Employees should avoid sharing gloves.
o Eye protection: Eye protection should be worn at all times while on-site.
o NOTE: The CDC is currently not recommending that healthy people wear N95 respirators to prevent the spread of COVID-19. Nevertheless, employees must wear N95 respirators if required by the work/task they are performing.
o Keep dust down by using engineering and work practice controls, specifically through the use of water delivery and dust collection systems.
o Limit exposure time to the extent practicable.
o Isolate workers in dusty operations by using a containment structure or distance to limit dust exposure to only those employees who are conducting the tasks, to the extent possible, thereby protecting nonessential workers and bystanders.
o Common EPA-registered household disinfectant;
o Alcohol solution with at least 60% alcohol; or
o Approved sanitizer.
Refer to site-specifics for additional cleaning requirements that may be appropriate if hazardous materials are used onsite.
If an employee exhibits COVID-19 symptoms, the employee must remain at home until he or she is symptom free for 72 hours (3 full days) without the use of fever-reducing or other symptom-altering medicines (e.g., cough suppressants). Dale Corp. will similarly require an employee who reports to work with symptoms to return home until he or she is symptom free for 72 hours (3 full days). To the extent practical, employees are required to obtain a doctor’s note clearing them to return to work.
An employee who tests positive for COVID-19 will be directed to self-quarantine away from work. Employees that test positive and are symptom free may return to work when at least ten (10) days have passed since the date of his or her first positive test, and have not had a subsequent illness. Employees who test positive and are directed to care for themselves at home may return to work when: (1) at least 72 hours (3 full days) have passed since recovery; and (2) at least ten (10) days have passed since symptoms first appeared. Employees who test positive and have been hospitalized may return to work when directed allowed to do so by their medical care providers. Dale Corp. will require an employee to provide documentation clearing his or her return to work.
Employees who have come into close contact with an individual who has tested positive for COVID-19 (co-worker or otherwise) will be directed to self-quarantine for 14 days from the last date of close contact with that individual. Close contact is defined as six (6) feet or closer for a prolonged period of time.
If Dale Corp. learns that an employee has tested positive, it will conduct an investigation to determine co-workers who may have had close contact with the confirmed positive employee in the prior 14 days and direct those individuals who have had close contact with the confirmed-positive employee to self-quarantine for 14 days from the last date of close contact with that employee. If applicable, Dale Corp. will also notify any sub-contractors, vendors/suppliers or visitors who may have had close contact with the confirmed-positive employee. If an employee learns that he or she has come into close contact with a confirmed-positive individual outside of the workplace, he/she must alert a manager or supervisor of the close contact and self-quarantine for 14 days from the last date of close contact with that individual.
OSHA has made a determination that COVID-19 should not be excluded from coverage of the rule – like the common cold or the seasonal flu – and, thus, OSHA is considering it an “illness.” However, OSHA has stated that only confirmed cases of COVID-19 should be considered an illness under the rule. Thus, if an employee simply comes to work with symptoms consistent with COVID-19 but is not a confirmed-positive employee, the recordability analysis is not necessarily triggered at that time.
If an employee has a confirmed case of COVID-19, Dale Corp. will also conduct an assessment of any workplace exposures to determine if the case is work-related. Work-relatedness is presumed for illnesses that result from events or exposures in the work environment, unless it meets certain exceptions. One of those exceptions is that the illness involves signs or symptoms that surface at work but result solely from a non-work-related event or exposure that occurs outside of the work environment. Thus, if an employee develops COVID-19 solely from an exposure outside of the work environment, it would not be work-related, and thus not recordable.
Dale Corp.’s workplace assessment will consider the work environment itself, the type of work performed, the risk of person-to-person transmission given the work environment, and other factors such as community spread. Further, if an employee has a confirmed case of COVID–19 that is considered work-related, Dale Corp. will report the case to OSHA if (1) it results in a fatality within 30 days or (2) it results in an in-patient hospitalization within 24-hours of the exposure incident.