COVID Operations Protocols

Addendum to Dale Corp. Safety, Health & Environment Loss Prevention Program

Continued Operations Protocol for Exposure Prevention, Preparedness and Response for the COVID-19 Pandemic Updated 04/01/2020, 04/29/2020, 07/9/2020

During this unprecedented time in our industry, Dale Corp remains committed and focused on protecting and supporting our employees, clients, subcontractors and operations.  By sharing knowledge and information, we can help reduce the potential of spreading the Coronavirus by developing protocols to follow while performing our work.  Every construction project is different, and site-specific protocols should be implemented to each project site. 

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. 

Dale Corp. is familiarizing and training their Project Managers and Superintendents with this PlanAll subcontractor managers and supervisors must be familiar with this Plan and be ready to answer questions from their employees.  Managers and supervisors must set a good example by following this Plan at all times.  This involves practicing good personal hygiene and jobsite safety practices to prevent the spread of the virus.  Managers and supervisors must encourage this same behavior from all employees.  If employees are not taking this COVID-19 Pandemic seriously, or not following the protocols laid out in this Plan, the contractor must take disciplinary action.  If to no avail, Dale Corp. may remove their employee and ban them from the project.  

Dale Corp. has implemented a daily sign-in sheet that acknowledges that Dale Corp. is asking every one of our employees to help with our prevention efforts while at work.  In order to minimize the spread of COVID-19 at our jobsites, everyone must play their part.  As set forth below, Dale Corp. has instituted various housekeeping, social distancing, and other best practices at our jobsites.  All employees must follow these.  In addition, employees are expected to report to their managers or supervisors if they are experiencing signs or symptoms of COVID-19, as described below.  If you have a specific question about this Plan or COVID-19, please ask your manager or supervisor.  If they cannot answer the question, please contact the Dale Corp. Superintendent or Director of Safety, Health & Environment for more information. 

OSHA and the CDC have provided the following control and preventative guidance for all workers, regardless of exposure risk: 

  • Frequently wash your hands with soap and water for at least 20 seconds.  When soap and running water are unavailable, use an alcohol-based hand rub with at least 60% alcohol. 
  • Avoid touching your eyes, nose, or mouth with unwashed hands. 
  • Follow appropriate respiratory etiquette, which includes covering for coughs and sneezes. 
  • Avoid close contact with people who are sick. 

In addition, employees must familiarize themselves with the symptoms of COVID-19, which include the following:   

  • Coughing; 
  • Fever; 
  • Shortness of breathand/ordifficulty breathing; and  
  • Early symptoms such as chills, body aches, sore throat, headache, diarrhea, nausea/vomiting, and runny nose.  

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.  

Dale Corp. has instituted the following protective measures at all jobsites.  See site-specific protocols developed for each project with included daily sign-in sheets. 

  1. General Safety Policies and Rules  
  • Any employee/contractor/visitor showing symptoms of COVID-19 will be asked to leave the jobsite and return home. 
  • Safety meetings will be by telephone, if possible.  If safety meetings are conducted in-person, attendance will be collected verbally and the foreman/superintendent will sign-in each attendee.  Attendance will not be tracked through passed-around sign-in sheets or mobile devices.  During any in-person safety meetings, avoid gathering in groups of more than 10 people and participants must remain at least six (6) feet apart. 
  • Employees must avoid physical contact with others and shall direct others (coworkers/contractors/visitors) to increase personal space to at least six (6) feet, where possible.  Where work trailers are used, only necessary employees should enter the trailers and all employees should maintain social distancing while inside the trailers. 
  • All in-person meetings will be limited.  To the extent possible, meetings will be conducted by telephone. 
  • Employees will be encouraged to stagger breaks and lunches, if practicable, to reduce the size of any group at any one time to less than ten (10) people. 
  • Dale Corp.understands that due to the nature of our work, access to running water for hand washing may be impracticable.  In these situations, Dale Corp. will provide, if available, alcohol-based hand sanitizers and/or wipes.    
  • Employees should limit the use of co-workers’ tools and equipment.  To the extent tools must be shared,Dale Corp.will provide alcohol-based wipes to clean tools before and after use.  When cleaning tools and equipment, consult manufacturing recommendations for proper cleaning techniques and restrictions.  
  • Employees are encouraged to limit the need for N95 respirator use, by using engineering and work practice controls to minimize dust.  Such controls include the use of water delivery and dust collection systems, as well as limiting exposure time. 
  • Dale Corp.will divide crews/staff into two (2) groups where possible so that projects can continue working effectively in the event that one of the divided teams is required to quarantine.  
  • As part of the division of crews/staff,Dale Corp.will divide employees into dedicated shifts, at which point employees will remain with their dedicated shifts for the remainder of the project.  If there is a legitimate reason for an employee to change shifts, Dale Corp. will have sole discretion in making that alteration.   
  • Employees are encouraged to minimize ride-sharing.  While in vehicles, employees must ensure adequate ventilation. 
  • If practicable, each employee should use/drive the same truck or piece of equipment every shift. 
  • In lieu of using a common source of drinking water, such as a cooler, employees should use individual water bottles.  
  1. Workers entering Occupied Building
  • Construction and maintenance activities within occupied buildings present unique hazards with regards to COVID-19 exposures.  Everyone working within such establishments should evaluate the specific hazards when determining best practices related to COVID-19. 
  • During this work, employees must sanitize the work areas upon arrival, throughout the workday, and immediately before departure. Dale Corp.will provide Sanitizer for the common areas of concern. 
  • Employees should ask other occupants to keep a personal distance of six (6) feet at a minimum.  Workers should wash or sanitize hands immediately before starting and after completing the work.  
  1. Job Site Visitors are to follow the same site-specific protocols with sign-in sheet 
  • The number of visitors to the job site, including the trailer or office, will be limited to only those necessary for the work.  
  • All visitors will be screened in advance of arriving on the job site.  If the visitor answers “yes” to any of the following questions, he/she should not be permitted to access the jobsite:  

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?  

  • Site deliveries will be permitted but should be properly coordinated in line with the employer’s minimal contact and cleaning protocols.  Delivery personnel should remain in their vehicles if at all possible.   
  1. Personal Protective Equipment and Work Practice Controls 
  • In addition to regular PPE for workers engaged in various tasks (fall protection, hard hats, hearing protection, Hi-Vis, task specific gloves),Dale Corp.will also provide:  

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.  

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 

  • Due to the current shortage of N95 respirators, the following Work Practice Controls should be followed: 

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.  

  • Institute a rigorous housekeeping program to reduce dust levels on the jobsite.

Dale Corp. has instituted regular housekeeping practices and the sanitizing of other elements of the work environment, where possible.  Employees should regularly do the same in their assigned work areas, which includes cleaning and disinfecting frequently used tools and equipment.  

  • Dale Corp.’stemporary field offices are closed to non-employees 
  • There is no eating or drinking within the building for sanitary reasons
  • Jobsite trailers and break/lunchroom areas will be cleaned at least once per day.  Employees performing cleaning will be issued proper personal protective equipment (“PPE”), such as nitrile, latex, or vinyl gloves and gowns, as recommended by the CDC. 
  • Any trash collected from the jobsite must be changed frequently by someone wearing nitrile, latex, or vinyl gloves. 
  • Any portable jobsite toilets should be cleaned by the leasing company at least twice per week and disinfected on the inside. Dale Corp.will ensure that hand sanitizer dispensers are always filled or that there is a handwashing station in vicinity.  Frequently touched items (i.e. door pulls and toilet seats) will be disinfected frequently.  
  • Vehicles and equipment/tools should be cleaned at least once per day and before change in operator or rider.  
  • OSHA has indicated that a reliable report that an employee has tested positive for COVID-19 does not typically require an employer to perform special cleaning or decontamination of workenvironments, unless those environments are visibly contaminated with blood or other bodily fluids.  Notwithstanding this,Dale Corp. will clean those areas of the jobsite that a confirmed-positive individual may have contacted, and it will do so before employees can access that workspace again.  
  • Dale Corp.will ensure that any disinfection shall be conducted using one of the following:  

o Common EPA-registered household disinfectant;  

o Alcohol solution with at least 60% alcohol; or   

Approved sanitizer.   

  • Dale Corp.will maintain Safety Data Sheets of all disinfectants used on site.   

Refer to site-specifics for additional cleaning requirements that may be appropriate if hazardous materials are used onsite.   

  • Employee Exhibits COVID-19 Symptoms:  

 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.  

  • Employee Tests Positive for COVID-19:  

 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.  

  • Employee Has Close Contact with an Individual Who Has Tested Positive for COVID-19: 

 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.

If a confirmed case of COVID-19 is reported, Dale Corp. will determine if it meets the criteria for recordability and reportability under OSHA’s recordkeeping rule.  OSHA requires construction employers to record work-related injuries and illnesses that meet certain severity criteria on the OSHA 300 Log, as well as complete the OSHA Form 301 (or equivalent) upon the occurrence of these injuries.  For purposes of COVID-19, OSHA also requires employers to report to OSHA any work-related illness that (1) results in a fatality, or (2) results in the in-patient hospitalization of one or more employee.  “In-patient” hospitalization is defined as a formal admission to the in-patient service of a hospital or clinic for care or treatment.  

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 COVID19 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.

Except for circumstances in which Dale Corp. is legally required to report workplace occurrences of communicable disease, the confidentiality of all medical conditions will be maintained in accordance with applicable law and to the extent practical under the circumstances.  When it is required, the number of persons who will be informed that an unnamed employee has tested positive will be kept to the minimum needed to comply with reporting requirements and to limit the potential for transmission to others.  Dale Corp. reserves the right to inform other employees that an unnamed co-worker has been diagnosed with COVID-19 if the other employees might have been exposed to the disease so the employees may take measures to protect their own health. Dale Corp. also reserves the right to inform sub-contractors, vendors/suppliers or visitors that an unnamed employee has been diagnosed with COVID-19 if they might have been exposed to the disease so those individuals may take measures to protect their own health.  

Given the fast-developing nature of the COVID-19 outbreak, Dale Corp. may modify this Plan on a case by case basis.  If you have any questions concerning this Plan, please contact the Dale Corp. Director of Safety, Health & Environment.