COVID-19 Prevention Program (CPP)

COVID-19 Prevention Program (CPP)

El Centro Elementary School District

 

This CPP is designed to control exposures to the SARS-CoV-2 virus that may occur in our workplace/school sites.

 

Date:  April 12, 2022

 

Authority and Responsibility

 

Jon LeDoux, Superintendent, has overall authority and responsibility for implementing the provisions of this CPP in our workplace. In addition, all managers and supervisors are responsible for implementing and maintaining the CPP in their assigned work areas and for ensuring 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 implement the following in our workplace:

 

  • Conduct workplace-specific evaluations using the Appendix A: Identification of COVID-19 Hazards form.
  • Document the vaccination status of our employees by using Appendix E: Documentation o Employee COVID-19 Vaccination Status, which is maintained as a confidential medical record. Employee’s are not required to submit vaccination status but are encouraged to do so voluntarily. Known vaccination status will be considered when quarantine and isolation practices are enforced
  • Evaluate employees’ potential workplace exposures to all persons at, or who may enter, our workplace.
  • Develop COVID-19 policies and procedures to respond effectively and immediately to individuals at the workplace who are a COVID-19 case to prevent or reduce the risk of transmission in the workplace. All District employees must immediately notify their immediate supervisor or the District Health Coordinator, Teresa Najera, if they test positive or exhibit symptoms of COVID-19. The supervisor and/or Health Coordinator will then notify Candice Ortiz, Director of Human Resources. The Health Coordinator will conduct the contact tracing process and will provide direction to the affected employee in terms of next steps.
  • 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

 

Employees are encouraged to raise concerns regarding the identification and evaluation of COVID-19 hazards to their immediate supervisors and the District’s Director of Maintenance Operations and Transportation (MOT).

 

Employee, Visitor and Student Screening

 

All Employees will self-screen daily, prior to arriving for work. Employees must not have any symptoms in order to report to work for the day.

 

Approved visitors will self-screen per CDPH guidelines when they first arrive to the District/Site. Upon entrance to sites, visitors will review a checklist of potential symptoms of exposure and must not have any symptoms in order to access the District/Site for the day. Temperature checks may be done based on the latest guidance from the CDPH. Directives for masking for visitors will be posted at the school office.

 

Students will self-screen per CDPH guidelines when they first arrive to the school campus. Guidance on identifying symptoms and proper screening practices will be provided to parents. Designated entrances will be manned by multiple staff members who will monitor students and will take appropriate steps if a student presents any symptoms.

 

Visitors may be denied access to any District property for any reason as determined by the site supervisor/principal.

 

Correction of COVID-19 Hazards

 

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

 

The District will work to resolve all hazards in a timely manner. Hazards will be assessed for severity and will be prioritized based on these results. The District will strive to bring about as immediate a correction as possible, but there may be a need to first deal with more severe hazards.

 

The Director of MOT will work with other administrators to follow-up and ensure corrective measures are put in place to eliminate any hazards that are identified.

 

Controls of COVID-19 Hazards

Face Coverings Employees/ Students /Authorized Visitors

 

Employees and students are STRONGLY RECOMMENDED to wear face masks or other approved facial covering, but not required.

 

We will not discourage any student from wearing a face mask/covering.

 

We will not prevent any employee from wearing a face covering when it is not required unless it would create a safety hazard, such as interfering with the safe operation of equipment.

 

Visitors/Parent Volunteers are REQUIRED to wear face masks or approved facial covering, at all times, while on a school campus.

 

Face coverings will also be provided to any employee, student or visitor that requests one.

 

 

Engineering Controls

For indoor locations, using Appendix B, we identify and evaluate how to maximize, to the extent feasible,  ventilation with outdoor air using the highest filtration efficiency compatible with our existing ventilation system, and whether the use of portable or mounted High Efficiency Particulate Air (HEPA) filtration units,  or other air cleaning systems, would reduce the risk of transmission by:

 

We maximize, to the extent feasible, the quantity of outside air for our buildings with mechanical or natural ventilation systems by:

 

  • Assuring accessible windows open and close to allow proper airflow
  • Utilizing District Certified HVAC technicians to evaluate District Ventilation systems in accordance with ASHRAE
  • Installing and maintaining Air Scrubbers
  • Installed updated filtration systems in conjunction with the Imperial County Air Pollution Control District.
  • Currently replacing 121 older HVAC units with more efficient units.
  • Upgraded HVAC system to web-based controls District-wide to better monitor indoor air quality.

 

Cleaning and Disinfecting

 

In accordance with the Centers for Disease Control and Prevention's cleaning and disinfecting guidelines: https://www.cdc.gov/coronavirus/2019-ncov/community/schools-childcare/clean-disinfect-hygiene.html

 

We implement the following cleaning and disinfection measures for frequently touched surfaces and objects, such as doorknobs, equipment, tools, handrails, handles, controls, phones, headsets, bathroom surfaces and steering wheels:

 

  • In addition to routine cleaning and disinfecting, staff are provided supplies so that commonly used surfaces can be wiped down before and after each use.
  • Scheduled routines and training ensure custodial staff have adequate time to complete cleaning and disinfecting directives. Staff are notified of changes in frequency or scope of cleaning and disinfecting, as needed.
  • Provide training from Integrated Pest Management (IPM) and/or ISSA COVID-19 Training.
  • PPE, supplies and other equipment related to cleaning and disinfecting are readily available to staff performing these duties.

 

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

 

  • Custodial staff members trained in proper cleaning and disinfecting procedures and the use of atomizing surface disinfecting systems will clean and disinfect confirmed areas of exposure.
  • Employees performing cleaning and disinfecting will wear the proper PPE according to the product label and Safety Data Sheet.  Depending on circumstances, we may contract outside professional cleaning services to assist us with disinfecting these areas.

 

Hand sanitizing

 

In order to implement effective hand sanitizing procedures, we will:

 

  • Train employees and encourage proper hand washing techniques (min. 20 seconds).
  • Post signage with proper handwashing techniques
  • Provide employees with an effective hand sanitizer and prohibit hand sanitizers that contain methanol (i.e. methyl alcohol).
  • Provide disposable gloves to employees with limited access to handwashing or hand sanitizing. The disposable gloves are to limit hand contact with potentially contaminated surfaces.  

 

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

 

We continuously 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.

 

Upon request, we will provide respirators for voluntary use to all employees who are not fully vaccinated and who are working indoors or in vehicles with more than one person.

 

When it comes to respiratory protection, we will regularly evaluate the need in accordance with CCR Title 8 section 5144 when the physical distancing requirements are not feasible or maintained. [reference section 3205(c)(E) for details on required respirator and eye protection use.] The immediate supervisor will notify the District’s Health Coordinator who will then ensure that the requesting employee receives training on how to properly wear a respirator.

 

We provide and ensure use of eye protection and respiratory protection when employees are exposed to procedures that may aerosolize potentially infectious material such as saliva or respiratory tract fluids. We will ensure respirators are in compliance with section 5144.

 

Testing of Symptomatic Employees

 

We make COVID-19 testing available, at no cost, to employees with COVID-19 symptoms, regardless of vaccination status, during employees’ paid time.

 

Investigating and Responding to COVID-19 Cases

 

We have developed effective procedures to investigate COVID-19 cases that include seeking information from our employees regarding COVID-19 cases, close contacts, test results, and onset of symptoms. This will be accomplished by using the Appendix C: Investigating COVID-19 Cases form.

 

We also ensure the following is implemented:

 

The Human Resources Department will provide no cost options for COVID-19 testing during the workday to employees that have potential COVID-19 exposure in the workplace.  In addition, the Human Resources Department will provide employees direction for reporting COVID-19 testing results and direction regarding return-to-work directives.

 

This excludes:

 

  • Employees who were fully vaccinated before the close contact and do not have symptoms.
  • COVID-19 cases who were allowed to return to work per our return-to-work criteria and have remained free of symptoms for 90 days after the initial onset of symptoms, or for cases who never developed symptoms, for 90 days after the first positive test.
  • The information on benefits described in Trainings and Instruction, and Exclusions of COVID-19 cases, below, will be provided to employees.
  • Written notice will be provided within 1 day of knowledge of a COVID-19 case, by District’s Health Coordinator and/or Director of Human Resources, that people at the worksite may have been exposed to COVID-19. This notice will be provided to all employees (and their authorized representative), independent contractors and other employers at the worksite during the high-risk exposure period. These notifications will meet the requirements of T8CCR section 3205(c)(3)(B) and Labor Code section 6409.6 (a)(4); (a)(2); and (c), and be provided in a form readily understandable by employees and can be anticipated to be received by the employee.

 

Investigating and Responding to COVID-19 Cases for Students

 

The school site administration in conjunction with our District’s Health Coordinator and health services staff, will investigate and respond to COVID-19 cases by students, including conducting contact tracing.  Our staff will work with our local public health department to ensure parents are provided with up-to-date guidance on steps they are to take if their child has been exposed or is confirmed positive.

 

System for Communicating to Students/Parents and Employees

 

Our goal is to ensure that we have effective two-way communication with our employees, students and parents in a form they can readily understand, and that includes the following information, as per the appropriate group below:

 

Students/Parents

 

COVID-19 symptoms shall be reported to the school site.  The principal/designee shall report this information to District’s Health Services Coordinator.  Health Services staff will contact the parent and provide information on symptoms being observed and provide further direction.  In the case of potential hazards, parents shall report any concerns to their school principal.

 

Employees

 

COVID-19 symptoms shall be reported to the employee's immediate supervisor.  The supervisor shall report this information to the District’s Health Services Coordinator.  The Health Services Coordinator will contact the employee that reported having symptoms, to provide further direction.  In the case of potential hazards, the employee shall report any concerns to their immediate supervisor.  The supervisor shall report the potential hazard to the Director of MOT.

 

  • Employees can report symptoms, possible close contacts & hazards without fear of reprisal.
  • Employees with medical or other conditions that put them at Risk of severe COVID-19 illness can request accommodations by contacting the Director of Human Resources.

 

Employees may access COVID-19 testing at any time, as follows:

 

The Human Resources Director provides employees with options for testing.  This includes testing that is at no cost to the employee through local testing centers, as well as options for rapid testing.

 

  • In the event we are required to provide testing because of a workplace exposure or outbreak, we will communicate the plan for providing testing and inform affected employees of the reason for the testing and the possible consequences of a positive test.

 

In the case of employee exposure, multiple COVID-19 infections and COVID-19 outbreaks, the District’s Health Services Coordinator will contact employees to provide directions for testing options.  This process will provide options for employees to test during working hours, at no cost to the employee. The employees shall also be informed of their leaves and benefits options in accordance with the law.

 

  • Information about COVID-19 hazards employees (including other employers and individuals in contact with our workplace) may be exposed to, what is being done to control those hazards, and our COVID-19 policies and procedures.

 

The District adheres to a strict policy on confidentiality when it comes to COVID-19 cases.  Information on cases is kept confidential and only shared on a need-to-know basis and with only key personnel.  

 

Training and Instruction for Employees, Students and Families

 

We will provide effective training and instruction that includes:

 

  • Our COVID-19 policies and procedures to protect individuals from COVID-19 hazards.
  • Information regarding COVID-19-related benefits to which employees may be entitled under applicable federal, state, or local laws.
  • The fact that:
    • COVID-19 is an infectious disease that can be 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 may have no symptoms.
  • The fact that particles containing the virus can travel more than six feet, especially indoors, so physical distancing must be combined with other controls, including face coverings, increased ventilation indoors, and respiratory protection decrease the spread of COVID-19 and are most effective when used in combination
  • The right of employees that are not fully vaccinated to request a respirator for voluntary use, without fear of retaliation, and our policies for providing the respirators. Employees voluntarily using respirators will be trained according to section 5144(c)(2) requirements:
    • How to properly wear them.
    • How to perform a seal check according to the manufacturer’s instructions each time a respirator is worn, and the fact that facial hair can interfere with a seal.
  • The importance of frequent hand washing with soap and water for at least 20 seconds and using hand sanitizer when employees do not have immediate access to a sink or hand washing facility, and that hand sanitizer does not work if the hands are soiled.
  • Proper use of face coverings and the fact that face coverings are not respiratory protective equipment. Since COVID-19 is an airborne disease, N95s and more protective respirators protect the users from airborne disease, while face coverings primarily protect people around the user.
    • The conditions where face covering must be worn at the workplace.
    • That face coverings are additionally recommended outdoors for people who are not vaccinated if six feet distance cannot be maintained.
    • Employees can request face coverings and can wear them at work regardless of vaccination status and without fear of retaliation.
  • COVID-19 symptoms, and the importance of obtaining a COVID-19 test and not coming to work/school if the individual has COVID-19 symptoms.
  • Information on our COVID-19 policies and how to access COVID-19 testing and vaccination, and the fact that vaccination is effective at preventing COVID-19, protecting against both transmission and serious illness or death.
  • Additional training provided to staff as needed includes: proper use of disinfectants and how to sanitize an area.
 

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

 

Exclusion of COVID-19 Cases and Employees who had a Close Contact

 

Where we have a COVID-19 case or close contact in our workplace, we limit transmission by:

 

  • Ensuring that persons with a positive COVID-19 test are excluded from the workplace until our return-to-work requirements are met.
  • Excluding employees that had a close contact from the workplace until our return-to-work criteria have been met, with the following exceptions:
    • Employees who were fully vaccinated and boosted (if eligible) before the close contact and who do not develop COVID-19 symptoms.
    • COVID-19 cases who returned to work per our return-to-work criteria and have remained free of COVID-19 symptoms, for 90 days after the initial onset of COVID-19 symptoms, or for COVID-19 cases who never developed COVID-19 symptoms, for 90 days after the first positive test.
  • For employees excluded from work, continuing, and maintaining employees’ earnings, wages, seniority, and all other employees’ rights and benefits. This will be accomplished by providing employees with sick leave benefits as required by state and federal law. Employees will be afforded all appropriate leaves as prescribed by state and federal law.
  • Providing employees at the time of exclusion with information on available benefits.

 

Reporting, Recordkeeping, and Access

 

It is our policy to:

 

  • Report information about COVID-19 cases and outbreaks at our workplace to the local health department whenever required by law, and provide any related information requested by the Imperial County Public Health Department.
  • Maintain records of the steps taken to implement our written COVID-19 Prevention Program in accordance with CCR Title 8 section 3203(b).
  • Make our written COVID-19 Prevention Program available at the workplace/school site to employees, authorized employee representatives, parents and to representatives of Cal/OSHA immediately upon request.
  • Use the 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, and
    • COVID-19 symptoms have improved, and
    • An appropriate number of days have passed since COVID-19 symptoms first appeared, as per public health directives and guidelines.
  • COVID-19 cases who tested positive but never developed symptoms will not return to work until an appropriate number of days have passed since the date of specimen collection of their first positive COVID-19 test, as per public health directives and guidelines.
  • A negative COVID-19 test will not be required for an employee to return to work once the requirements for “cases with symptoms” or “cases who tested positive but never developed symptoms” (above) have been met (except, if they are to return on Day 6.) After Day 10 a negative result is not necessary.
  • Persons who had close contact may return to work as follows:
    • Close contact but never developed symptoms: when an appropriate number of days have passed since the last known close contact, as per current public health directives and guidance .
    • Close contact with symptoms: when the “cases with symptoms” criteria (above) have been met, unless the following are true:
      • The person tested negative for COVID-19 using a polymerase chain reaction (PCR) COVID-19 test with specimen taken after the onset of symptoms; and
      • When an appropriate number of days since the last known close contact, as per current public health directives and guidance, and;
      • The person has been symptom-free for at least 24 hours, without using fever-reducing medications.
  • If an order to isolate or quarantine an employee is issued by a local or state health official and/or the District’s Health Services Coordinator, the employee will not return to work until the period of isolation or quarantine is completed or the order is lifted.

 

Student Return to School Criteria

  • COVID-19 cases with COVID-19 symptoms will not return to school 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 and,
    • COVID-19 symptoms have improved and,
    • An appropriate number of days have passed since COVID-19 symptoms first appeared, as determined by Public Health directives and guidance.
  • COVID-19 cases who tested positive but never developed COVID-19 symptoms will not return to school until an appropriate number of days have passed since the date of specimen collection of their first positive COVID-19 test, as per current public health directives and guidance.
  • A negative COVID-19 test will not be required for a student to return to school unless the student is to return on Day 6. After Day 10 a negative result is not necessary.
  • If an order to isolate or quarantine a student is issued by a local or state health official and or the District’s Health Services Coordinator, the student will not return to school until the period of isolation or quarantine is completed or the order is lifted.

 

 Superintendent signature

 

 

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, trainings, 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.

 

Person Conducting the Evaluation:

 

Date:

 

Name(s) of Employees 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

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Appendix B: COVID-19 Inspections 

Date:

Name of person conducting the inspection:

Work location evaluated:

Exposure Controls

Status

Person Assigned to Correct

Date Corrected

Engineering

 

 

 

Ventilation* (amount of

fresh air and

filtration maximized)

 

 

 

Additional room air

filtration

 

 

 

Administrative

 

 

 

Surface cleaning and

disinfection

(frequently enough and

adequate

supplies)

 

 

 

Hand washing facilities

(adequate numbers and supplies)

 

 

 

Disinfecting and hand sanitizing solutions being used according to

manufacturer instructions

 

 

 

 

Exposure Controls

Status

Person Assigned to Correct

Date Corrected

PPE (not shared, available and being worn)

 

 

 

Face coverings (cleaned

sufficiently often)

 

 

 

Gloves

 

 

 

Face shields/goggles

 

 

 

Respiratory protection

 

 

 

*Identify and evaluate how to maximize ventilation with outdoor air; the highest level of filtration efficiency compatible with the existing ventilation system; and whether the use of portable or mounted HEPA filtration units, or other air cleaning systems, would reduce the risk of COVID-19 transmission. Review applicable orders and guidance from the State of California and local health departments related to COVID-19 hazards and prevention have been reviewed, including the CDPH Interim Guidance for Ventilation, Filtrations,

and Air Quality in Indoor Environments and information specific to your industry, location, and operations. We maximize the quantity of outside air provided to the extent feasible, except when the United States Environmental Protection Agency (EPA) Air Quality Index is greater than 100 for any pollutant or if opening windows or maximizing outdoor air by other means would cause a hazard to employees, for instance from

excessive heat or cold.

 

Appendix C: Investigating COVID-19 Cases

All personal identifying information of COVID-19 cases or persons with COVID-19 symptoms, and any employee required medical records will be kept confidential unless disclosure is required or permitted by law. Un-redacted information on COVID-19 cases will be provided to the local health department, CDPH, Cal/OSHA, the National Institute for Occupational Safety and Health (NIOSH) immediately upon request, and when required by law.

 

Date:                                                            Name of person conducting the investigation:

Name of COVID-19 case (employee or non-employee*) and contact information:

 

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

 

*If we are made aware of a non-employee COVID-19 case in our workplace

 

Names of employees/representatives involved in the investigation:

 

Date investigation was initiated:

 

Locations where the COVID-19 case was present in the workplace during the high-risk exposure  period, and activities being performed:

 

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

 

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

 

Date the case first had one or more COVID-19 symptoms, if any:

 

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

 

Summary determination of who may have had a close contact with the COVID-19 case during the high- risk exposure period. Attach additional information, including:

  • The names of those found to be in close contact.
  • Their vaccination status.
  • When testing was offered, including the results and the names of those that were exempt from testing because.
    • They were fully vaccinated before the close contact and do not have symptoms.
    • They returned to work per our return-to-work criteria and have remained symptom free for 90 days or, for those that never developed symptoms, for 90 days after the initial positive test.
  • The names of those that were excluded per our Exclusion of COVID-19 Cases and Employees who had a Close Contact requirements.
  • The names of those exempt from exclusion requirements because:
    • They were fully vaccinated before the close contact and did not develop COVID-19 symptoms.
    • They returned to work per our return-to-work criteria and have remained symptom free for 90 days or, for those that never developed symptoms, for 90 days after the initial positive test.
 

Notice 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:

  1. All employees who were in close contact
  2. Their authorized representatives (If applicable, the notice required by Labor Code section 6(a) and (c))

 

 

Names of employees that were notified:

 

Names of their authorized

representatives:

 

Date

 

 

 

 

 

 

 

 

 

 

 

 

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

 

 

Names of individuals that were notified:

 

Date

 

 

 

 

 

 

 

 

 

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 local health department notified? Date?

 

 

 

Appendix D: COVID-19 Training Roster

 

Date:

 

Name of Person Conducting the Training:

 

Employee/Student Name

Signature

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Appendix E: Documentation of Employee COVID-19 Vaccination Status - CONFIDENTIAL

 

Employee Name

Fully or Partially

Vaccinated1

Method of

Documentation2

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

1Update, accordingly and maintain as confidential medical record

2Acceptable options include:

  • Employees provide proof of vaccination (vaccine card, image of vaccine card or health care document showing vaccination status) and employer maintains a copy.
  • Employees provide proof of The employer maintains a record of the employees who presented proof, but not the vaccine record itself.
  • Employees self-attest to vaccination status and employer maintains a record of who self-attests.

 

 

Additional Consideration #1

Multiple COVID-19 Infections and COVID-19 Outbreaks

 

This addendum will stay in effect until there are no new COVID-19 cases detected in the exposed group for a 14-day period.

 

COVID-19 Testing

 
  • We provide COVID-19 testing at no cost to all employees, during paid time, in our exposed group except for:
    • Employees who were not present during the relevant 14-day period.
    • Employees who were fully vaccinated before the multiple infections or outbreak and who do not  have symptoms.
    • COVID-19 cases who did not develop symptoms after returning to work pursuant to our return-to- work criteria, no testing is required for 90 days after the initial onset of symptoms or, for COVID-19 cases who never developed symptoms, 90 days after the first positive test.
  • COVID-19 testing consists of the following:
    • All employees in our exposed group are immediately tested and then again one week later. Negative COVID-19 test results of employees with COVID-19 exposure will not impact the duration of any quarantine, isolation, or exclusion period required by, or orders issued by, the local health department.
    • After the first two COVID-19 tests, we continue to provide COVID-19 testing once a week of employees in the exposed group who remain at the workplace, or more frequently if recommended by the local health department, until there are no new COVID-19 cases detected in our workplace for a 14-day period.
    • We provide additional testing when deemed necessary by Cal/OSHA.

 

We continue to comply with the applicable elements of our CPP, as well as the following:

  1. Employees in the exposed group wear face coverings when indoors, or when outdoors and less than six feet apart (unless one of the face-covering exceptions indicated in our CPP apply).
  2. We give notice to employees in the exposed group of their right to request a respirator for voluntary use if they are not fully vaccinated.
  3. We evaluate whether to implement physical distancing of at least six feet between persons, or where six feet of physical distancing is not feasible, the need for use of cleanable solid partitions of sufficient size to reduce COVID-19 transmission.

 

COVID-19 investigation, review, and hazard correction

We 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 is documented and includes:

  • Investigation of new or unabated 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 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 feasible.
    • Requiring respiratory protection in compliance with section 5144.

 

Buildings or structures with mechanical ventilation

We will filter recirculated air with Minimum Efficiency Reporting Value (MERV) 13 or higher efficiency filters, if compatible with the ventilation system. If MERV-13 or higher filters are not compatible, we will use filters with the highest compatible filtering efficiency. We will also evaluate whether portable or mounted High Efficiency Particulate Air (HEPA) filtration units or other air cleaning systems would reduce the risk of transmission and, if so, implement their use to the degree feasible.

 

 

Additional Consideration #2

Major COVID-19 Outbreaks

 

 

This addendum will stay in effect until there are fewer than three COVID-19 cases detected in our exposed group for a 14-day period.

 

We continue to comply with the Multiple COVID-19 Infections and COVID-19 Outbreaks addendum, except that the COVID-19 testing, regardless of vaccination status, is made available to all employees in the exposed group twice a week, or more frequently if recommended by the local health department.

 

In addition to complying with our CPP and Multiple COVID-19 Infections and COVID-19 Outbreaks addendum, we also:

  • Offer employees in the exposed group with respirators for voluntary use in compliance with section 5144(c)(2) and determine the need for a respiratory protection program or changes to an existing respiratory protection program under section 5144 to address COVID-19 hazards.
  • Separate by six feet (except where we can demonstrate that six feet of separation is not feasible and there is momentary exposure while persons are in movement) any employees in the exposed group who are not wearing respirators required by us and used in compliance with section 5144. When it is not feasible to maintain a distance of at least six feet, individuals are as far apart as feasible. We will stagger schedules including break times as appropriate to reduce the amount of employees in a given area. In addition, we will continue to use physical barriers including in areas where visitors have access. We will use visual cues and signage to promote smooth pathways that limit proximity.
  • Install cleanable solid partitions that effectively reduce transmission between the employee and other persons at workstations where an employee in the exposed group is assigned to work for an extended period, such as cash registers, desks, and production line stations, and where the physical distancing requirement (described above) is not always maintained.
  • Evaluate whether to halt some or all operations at the workplace until COVID-19 hazards have been corrected.
  • Implement any other control measures deemed necessary by Cal/OSHA.

 

Additional Consideration #3

COVID-19 Prevention in Employer-Provided Transportation

 

Assignment of transportation

To the extent feasible, we reduce exposure to COVID-19 hazards by assigning employees sharing vehicles to distinct groups and ensuring that each group remains separate from other such groups during transportation, during work activities, and in employer-provided housing. We prioritize shared transportation assignments in the following order:

    • Employees residing in the same housing unit are transported in the same vehicle.
    • Employees working in the same crew or workplace are transported in the same vehicle.
    • Employees who do not share the same household, work crew or workplace are transported in the same vehicle only when no other transportation alternatives are feasible.

 

Face coverings and respirators

Face coverings are strongly recommended for employees.

  • Upon request, we provide respirators for voluntary use in compliance with subsection 5144(c)(2) to all employees in the vehicle who are not fully vaccinated.

 

Screening

We develop, implement, and maintain effective procedures for screening and excluding drivers and riders with COVID-19 symptoms prior to boarding shared transportation. Self-screening will take place prior to gaining access to a District vehicle.

 

Cleaning and disinfecting

We ensure that:

  • All high-contact surfaces (door handles, seatbelt buckles, armrests, etc.) used by passengers are cleaned to prevent the spread of COVID-19 and are cleaned and disinfected if used by a COVID-19 case during the high-risk exposure period, when the surface will be used by another employee within 24 hours of the COVID-19 Custodial/maintenance staff will be trained to properly disinfect for COVID-19. A custodian/maintenance worker will disinfect the vehicle using proper equipment and supplies before the vehicle is used by another employee.
  • All high-contact surfaces used by drivers, such as the steering wheel, armrests, seatbelt buckles, door handles and shifter, are cleaned to prevent the spread of COVID-19 between different drivers and are disinfected after use by a COVID-19 case during the high-risk exposure period, if the surface will be used by another employee within 24 hours of the COVID-19 case. This will be accomplished on a daily basis before the vehicle is cleared for use by employees.
  • We provide sanitizing materials, training on how to use them properly, and ensure they are kept in adequate supply.

 

Ventilation

We ensure that vehicle windows are kept open, and the ventilation system is set to maximize outdoor air and not set to recirculate air. Windows do not have to be kept open if one or more of the following      conditions exist:

  • The vehicle has functioning air conditioning in use and excessive outdoor heat would create a hazard to employees.
  • The vehicle has functioning heating in use and excessive outdoor cold would create a hazard to employees.
  • Protection is needed from weather conditions, such as rain or snow.
  • The vehicle has a cabin air filter in use and the U.S. EPA Air Quality Index for any pollutant is greater  than 100.

 

Hand hygiene

We provide hand sanitizer in each vehicle and ensure that all drivers and riders sanitize their hands before entering and exiting the vehicle. Hand sanitizers with methyl alcohol are prohibited.