COVID-19 Exposure Prevention, Preparedness, and Response Plan

Written By Kamal Grewal (HR Manager)

Updated at April 27th, 2021

The Company values the safety and wellbeing of its staff. With the spread of the coronavirus or "COVID-19," the company must take every precaution to prevent the spread of the disease. We have developed this COVID-19 Exposure Prevention, Preparedness, and Response Plan so we can maintain safety and maintain operations, which will be implemented, to the extent possible and appropriate, throughout the property. 


The CDC and OSHA provided information guiding this plan's development; it may change based on new information provided by those agencies. The Company has the right to change the Plan based on operational needs or changes in the CDC and OSHA.


Authority and Responsibility

To execute the program requirements, the General Manager has overall authority, supervisors are responsible for the implementation and maintenance of the program in their assigned work areas, and they ensure employees receive answers to questions about the program in a language they understand.

All employees are responsible for using safe work practices, following all directives, policies, and procedures, and assisting in maintaining a safe work environment.

Identification and Evaluation of COVID-19 Hazards

We will enforce these changes in our workplace:

  • Conduct workplace-specific evaluations using the Appendix A: Identification of COVID-19 Hazards form. 
  • Evaluate employees’ potential workplace exposures to all persons at, or who may enter our workplace.
  • Review applicable orders and general and industry-specific guidance from the State of California, Cal/OSHA, and the local health department related to COVID-19 hazards and prevention.
  • Evaluate existing COVID-19 prevention controls in our workplace and the need for different or additional controls. 
  • Conduct periodic inspections using the Appendix B: COVID-19 Inspections form as needed to identify unhealthy conditions, work practices, and work procedures related to COVID-19 and to ensure compliance with our COVID-19 policies and procedures.

Employee Participation

Staff and their authorized representatives are encouraged to participate by identifying and evaluating COVID-19 hazards and to alert the General Manager of any issues or concerns that they may have.

Employee screening

We screen our employees through the payroll system by having the employees self-screen and answer questions about their health and taking their own temperature prior to clocking into their shift. 

Correction of COVID-19 Hazards

Unsafe or unhealthy work conditions, practices, or procedures will be documented on Appendix B: COVID-19 Inspections form, and corrected in a timely manner based on the severity of the hazards, as follows:

  • Accordingly, the severity of the hazard will be assessed and time frames will be assigned for corrective action. 
  • Individuals are responsible for finishing the corrections on time.
  • Corrective measures are taken to ensure timely correction.

Control of COVID-19 Hazards

Physical Distancing

When physically possible, we maintain a physical distancing distance of at least six feet at all times by: 


    • Reducing the need for workers to be in the workplace– If the employee is NOT scheduled to work, they should not be on-site, unless authorized by the General Manager. 
    • Reducing the number of persons in an area at one time, including guests.
    • Visual cues such as signs and floor markings to indicate where employees and others should be located or their direction and path of travel.
    • Staggered arrival, departure, work, and break times.

Individuals will be kept as far apart as possible when there are situations where six feet of physical distancing cannot be achieved.


Face Coverings

Employees must have their nose and mouth covered when indoors and not closer than six feet from another person outside, including non-employees, and where required to do so by the California Department of Public Health (CDPH) or local health department.  

The following are exceptions to the use of face coverings in our workplace:


    • When an employee is alone in a room.
    • While eating and drinking at the workplace, provided employees are at least six feet apart and outside air supply to the area, if indoors, has been maximized to the extent possible.
    • Employees who are restricted from wearing face coverings due to a medical or mental health condition or disability, or who have hearing difficulties or are communicating with a hearing-impaired person. Please contact your Human Resource Manager regarding this matter.


Cleaning and Disinfecting


During situations when we are unable to maintain clear distances between individuals, we implement the following measures: 


    • Partitions have been or will be installed at the Front Desk areas
    • All offices, restrooms, and other common areas will be disinfected and cleaned daily per CDC guidelines. 
    • Guest rooms are disinfected between A.M. and P.M., bathrooms are and should be disinfected hourly, and all equipment in the business and/or lobby area is disinfected between use. 
    • Cleaning logs will be used to document and ensure cleaning and sanitizing is completed as per protocols

    Should we have a COVID-19 case in our workplace, we will implement the following procedures:


    • All surfaces touched by the positive employee will be sprayed with disinfectant solution and cleaned with disinfectant cloths.
    • Each employee who has come into contact with the positive employee will have to self-quarantine for 10-14 days and will be asked to get tested.
    • Those who return to work after quarantine must show their negative test results.


Shared tools, equipment, and personal protective equipment (PPE)

PPE, such as gloves, goggles, and face shields, may not be shared.

Items that come in regular physical contact with employees, such as phones, headsets, desks, keyboards, writing materials, instruments, and tools, will be disinfected between uses by misting and wiping with disinfecting solution/wipes.


Hand sanitizing

To implement effective hand sanitizing procedures, we:



    • Have assessed handwashing facilities 
    • Encourages and permits time for employee handwashing.
    • Provides employees with an effective hand sanitizer and prohibits hand sanitizers that contain methanol (i.e. methyl alcohol).
    • Encourages employees to wash their hands for at least 20 seconds each time

Personal protective equipment (PPE) used to control employees’ exposure to COVID-19

We evaluate the need for PPE (such as gloves, goggles, and face shields) as required by CCR Title 8, section 3380, and provide such PPE as needed.

When it comes to respiratory protection, we evaluate the need in accordance with CCR Title 8 section 5144 when the physical distancing requirements are not feasible or maintained. 

Investigating and Responding to COVID-19 Cases

This will be accomplished by using the Appendix C: Investigating COVID-19 Cases form. 

Employees who had potential COVID-19 exposure in our workplace will be:


    • Required to take a COVID test at one of the free clinics (please refer to the COVID SOP for a location).
    • The information on benefits described in Training and Instruction, and Exclusion of COVID-19 Cases, below, will be provided to them.
    • Will be advised to adopt CDC regulations for self-quarantine

System for Communicating

We strive to have two-way communication with our employees in a manner they can readily understand, that includes the information that follows:


    • Which employees should report COVID-19 symptoms and possible hazards, and how.
    • Employees can report symptoms and hazards without fear of reprisal.
    • Our procedures or policies for accommodating employees with medical or other conditions that put them at increased risk of severe COVID-19 illness.

Training and Instruction

There will be effective training and instruction including:


    • COVID-19 procedures and policies to protect the employees from COVID-19 hazards.
    • The employee may be entitled to benefits relating to COVID-19 under applicable federal, state, or local laws. 
    • The fact that:
    • Infectious diseases such as COVID-19 are spread through the air.
    • COVID-19 may be transmitted when a person touches a contaminated object and then touches their eyes, nose, or mouth.
    • An infectious person might not display any symptoms.
    • Methods of physical distancing of at least six feet and the importance of combining physical distancing with the wearing of face coverings.
    • Physical distancing alone cannot prevent virus transmission, so other controls, including face coverings and hand hygiene, must be used as well.
    • It is important to wash hands frequently with soap and water for at least 20 seconds and use hand sanitizer when employees do not have immediate access to a sink or handwashing facility, and that hand sanitizer may not work if the hands are soiled.
    • Proper use of face coverings and the fact that face coverings are not respiratory protective equipment - face coverings are supposed to provide people with protection from the wearer of the face covering.
    • COVID-19 symptoms, and the importance of obtaining a COVID-19 test and not coming to work if the employee has COVID-19 symptoms.

Appendix D: COVID-19 Training Roster will be used to document this training.

Exclusion of COVID-19 Cases

In the event that we have a COVID-19 case in our workplace, we will:

    • Until our return-to-work requirements are met, COVID-19 cases can not return to work.
    • Employees with exposure to COVID-19 must be excluded from the workplace for 14 days after the last known COVID-19 exposure to a COVID-19 case.
    • When we demonstrate that the COVID-19 exposure is work-related, employees' earnings, seniority, and rights and benefits will continue and be maintained, such as by extending sick leave and personal days to cover the time necessary for them to quarantine and/or recover.
    • At the time of exclusion, providing employees with information on available benefits.

Reporting, Recordkeeping, and Access

It is our policy to:

    • Whenever required by law, we must report COVID-19 cases encountered at our place of work to the local health department and provide any related information that may be requested by the local health department.
    • Report immediately to Cal/OSHA any serious illness or death that is related to COVID-19, as defined under CCR Title 8 section 330(h) of an employee that occurs at our place of employment or in connection with any employment.
    • Maintain records of the steps taken to implement our written COVID-19 Prevention Program in accordance with CCR Title 8 section 3203(b).
    • Our written COVID-19 Prevention Program should be accessible at the workplace to employees, authorized employee representatives, and representatives of Cal/OSHA upon request.
    • Use Appendix C: Investigating COVID-19 Cases form to keep a record of and track all COVID-19 cases. The information will be made available to employees, authorized employee representatives, or as otherwise required by law, with personal identifying information removed.

Return-to-Work Criteria


    • COVID-19 cases with COVID-19 symptoms will not return to work until all the following have occurred:
      • At least 24 hours have passed since a fever of 100.4 or higher has resolved without the use of fever-reducing medications.
      • COVID-19 symptoms have improved.
      • At least 10 days have passed since COVID-19 symptoms first appeared.
    • COVID-19 cases who test positive but never develop symptoms of COVID-19 will not be allowed to return to work until 10 days have passed from the date of specimen collection of the first positive COVID-19 test.
    • Employees who test negative for COVID-19 will be allowed to return to work.
    • If an order to isolate or quarantine an employee is issued by a local or state health official, the employee will not return to work until the period of isolation or quarantine is completed or the order is lifted. If no period was specified, then the period will be 10 days from the time the order to isolate was effective, or 14 days from the time the order to quarantine was effective.

Appendix A: Identification of COVID-19 Hazards

All persons, regardless of symptoms or negative COVID-19 test results, will be considered potentially infectious.  Particular attention will be paid to areas where people may congregate or come in contact with one another, regardless of whether employees are performing an assigned work task or not. For example: meetings, entrances, bathrooms, hallways, aisles, walkways, elevators, break or eating areas, cool-down areas, and waiting areas.

Evaluation of potential workplace exposure will be to all persons at the workplace or who may enter the workplace, including coworkers, employees of other entities, members of the public, customers or clients, and independent contractors. We will consider how employees and other persons enter, leave, and travel through the workplace, in addition to addressing fixed work locations.

The person conducting the evaluation

Date

Name(s) of employee and authorized employee representative that participated

Interaction, area, activity, work task, process, equipment, and material that potentially exposes employees to COVID-19 hazards

Places and times

Potential for COVID-19 exposures and employees affected, including members of the public and employees of other employers

Existing and/or additional COVID-19 prevention controls, including barriers, partitions, and ventilation






























Appendix B: COVID-19 Inspections

  

*This form is only designed to get you started. Review the information available at www.dir.ca.gov/dosh/coronavirus/ for additional guidance on what to regularly inspect for, including issues that may be more relevant to your specific type of workplace. You will need to amend the form appropriately.

Date


Name of person conducting the inspection:


Work location evaluated: 


Exposure Controls
Status
Person Assigned to Correct
Date Corrected

Engineering




Barriers/partitions




Ventilation (amount of fresh air and filtration maximized)




Additional room air filtration




[add any additional controls your workplace is using]




[add any additional controls your workplace is using]




Administrative




Physical distancing




Surface cleaning and disinfection (frequently enough and adequate supplies)




Handwashing facilities (adequate numbers and supplies)




Disinfecting and hand sanitizing solutions being used according to manufacturer instructions




[add any additional controls your workplace is using]




[add any additional controls your workplace is using]




PPE (not shared, available, and being worn)




Face coverings (cleaned sufficiently often)




Gloves




Face shields/goggles




Respiratory protection




[add any additional controls your workplace is using]




Appendix C: Investigating COVID-19 Cases

All personal identifying information of COVID-19 cases or symptoms will be kept confidential. All COVID-19 testing or related medical services provided by us will be provided in a manner that ensures the confidentiality of employees, with the exception of unredacted information on COVID-19 cases that will be provided immediately upon request to the local health department, CDPH, Cal/OSHA, the National Institute for Occupational Safety and Health (NIOSH), or as otherwise required by law.

All employees’ medical records will also be kept confidential and not disclosed or reported without the employee’s express written consent to any person within or outside the workplace, with the following exceptions: (1) Unredacted medical records provided to the local health department, CDPH, Cal/OSHA, NIOSH, or as otherwise required by law immediately upon request; and (2) Records that do not contain individually identifiable medical information or from which individually identifiable medical information has been removed.

Date

Name of person conducting the investigation:

COVID-19 Case Investigation Information

Employee (or non-employee*) name:


Occupation (if non-employee, why they were in the workplace):


The location where the employee worked (or non-employee was present in the workplace):


Date investigation was initiated:


Was the COVID-19 test offered?


Name(s) of staff involved in the investigation:


Date and time the COVID-19 case was the last present in the workplace:


Date of the positive or negative test and/or diagnosis:


The date the case first had one or more COVID-19 symptoms:



Information received regarding COVID-19 test results and onset of symptoms (attach documentation):


Results of the evaluation of the COVID-19 case and all locations at the workplace that may have been visited by the COVID-19 case during the high-risk exposure period, and who may have been exposed (attach additional information):



Notice is given (within one business day, in a way that does not reveal any personal identifying information of the COVID-19 case) of the potential COVID-19 exposure to:

All employees who may have had COVID-19 exposure and their authorized representatives.

Date:


Names of employees that were notified:


Independent contractors and other employers present at the workplace during the high-risk exposure period.

Date:


Names of individuals that were notified:


What were the workplace conditions that could have contributed to the risk of COVID-19 exposure?


What could be done to reduce exposure to COVID-19?


Was the local health department notified?



Date:



*Should an employer be made aware of a non-employee infection source COVID-19 status.

Appendix D: COVID-19 Training Roster

Date


The person that conducted the training

Employee Name
Signature




















Additional Consideration

Multiple COVID-19 Infections and COVID-19 Outbreaks

This section of the CPP will remain in effect for 14 days or until there are no new cases of COVID-19 in our workplace.

COVID-19 testing

We will provide information for free COVID-19 testing to all employees in our exposed workplace of an outbreak identified by a local health department or the relevant 14-day period. 

COVID-19 testing consists of the following:

All employees in our exposed workplace will be immediately tested and then tested again one week later. Negative COVID-19 test results of employees with COVID-19 exposure will not impact the duration of any quarantine period required by, or orders issued by, the local health department.

After the first two COVID-19 tests, employees will continue to provide COVID-19 testing of who continue at the workplace at least once per week, or more frequently if recommended by the local health department, until there are no additional COVID-19 cases detected in our workplace for a 14-day period.

We will provide additional testing information if Cal/OSHA deems it necessary.

Exclusion of COVID-19 cases

We will ensure that COVID-19 cases and employees exposed to COVID-19 are excluded from the workplace, as per our CPP Exclusion of COVID-19 Cases and The Return to Work Criteria requirements, as well as local health officer orders.

Investigation of workplace COVID-19 illness

We will investigate and determine whether workplace factors contributed to the COVID-19 outbreak in accordance with the CPP Investigating and Responding to COVID-19 Cases.

COVID-19 investigation, review, and hazard correction

In addition to our CPP Identification and Evaluation of COVID-19 Hazards and Correction of COVID-19 Hazards, we will immediately perform a review of potentially relevant COVID-19 policies, procedures, and controls and implement changes as needed to prevent further spread of COVID-19.

The investigation and review will be documented and include:

Investigation of new COVID-19 hazards, including:


    • Our leave policies and practices and whether employees are discouraged from remaining home when sick.
    • Our COVID-19 testing policies.
    • Insufficient outdoor air.
    • Insufficient air filtration.
    • Lack of physical distancing.
Updating the review:

    • Every thirty days that the outbreak continues.
    • In response to new information or to new or previously unrecognized COVID-19 hazards.
    • When otherwise necessary.
    • Implementing changes to reduce the transmission of COVID-19 based on the investigation and review. We will consider:
    • Moving indoor tasks outdoors or having them performed remotely.
    • Increasing outdoor air supply when work is done indoors.
    • Improving air filtration.
    • Increasing physical distancing as much as possible.
    • Respiratory protection.

Notifications to the local health department

Immediately, but no longer than 48 hours after learning of three or more COVID-19 cases in our workplace, we will contact the local health department for guidance on preventing the further spread of COVID-19 within the workplace.

We will provide to the local health department the total number of COVID-19 cases and for each COVID-19 case, the name, contact information, occupation, workplace location, business address, the hospitalization and/or fatality status, and North American Industry Classification System code of the workplace of the COVID-19 case, and any other information requested by the local health department. We will continue to give notice to the local health department of any subsequent COVID-19 cases at our workplace.

Additional considerations will be assessed by the Human Resource Manager and General Manager on a case-by-case basis. 





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