COVID-19 Safety Plan
Sample Plan for COVID-19 Exposure Prevention, Preparedness, and Response Developed by Construction Industry Safety Coalition (CISC)1 March 25, 2020 Revised by The Associated General Contractors of America (AGC) March 31, 2020, revised by the Roofing Contractors of Washington (RCAW) April 14, 2020****
Neither the RCAW nor its individual members intend this document to be a definitive statement of the protocols and procedures that are applicable to each and every project. Nor are they endeavoring to provide legal or other professional advice. This document should NOT be construed as legal advice or any other expression of the scope or nature of a construction contractor’s legal obligation to provide employment and a safe place of employment to its employees, particularly under the unprecedented circumstances that the COVID-19 outbreak has created. In addition, new and better information could well supersede the information included in this document. As the situation evolves, construction contractors should continue to monitor the environment in which they are working and related developments and react accordingly.
***** [Name of Company] (hereinafter “Company”) takes the health and safety of our employees very seriously. With the spread of the coronavirus or “COVID-19,” a respiratory disease, the Company must remain vigilant in mitigating the transmission of the virus. The Company is a proud part of the construction industry, which many have deemed “essential” 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 our jobsites. The Company has also identified a team of employees to monitor the related guidance that U.S. Center for Disease Control and Prevention (“CDC”) and Occupational Safety and Health Administration (“OSHA”) continue to make available.
- This Plan is prepared by the Roofing Contractors Association of Washington and based on information available from the CDC and OSHA at the time of its development, and is subject to change or upgrade based on further information provided by the CDC, OSHA, and other public officials. The Company may also amend this Plan based on operational needs.
- The RCAW is comprised of roofing contractors in Washington State, as well as manufacturers, distributors, and other third-party related vendors to the roofing industry. The RCAW was formed to provide information to our members at-large. This document is a “template” that individual contractors should review carefully and tailor to their own work and jobsites.
- Responsibilities of Managers and Supervisors All managers and supervisors must be familiar with this Plan and be ready to answer questions from employees. Managers and supervisors must always set a good example by following this Plan. This involves practicing good personal hygiene and jobsite safety practices to prevent the spread of the virus. Managers and supervisors must require this same behavior from all employees.
- Responsibilities of Employees the Company requires every one of our employees to participate in 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, the Company 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 [Title of Manager or Supervisor] 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.
- To protect all workers, agree to a temperature check using a non-contact thermometer at any time during a work shift.
In addition, employees must familiarize themselves with the symptoms of COVID-19, which include the following:
- Shortness of breath, difficulty 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.
Job Site Protective Measures the Company has instituted the following protective measures at all jobsites.
General Safety Protections and Rules
Each worker shall be trained in the Covid19 symptoms and shall complete a quiz to demonstrate they understand the symptoms. No employee shall be allowed to work before successfully passing the quiz.
- Any employee/contractor/visitor showing symptoms of COVID-19 will be asked to leave the jobsite and return home.
- Employees reporting for work shall have their temperature taken using a touchless thermometer. Any employee with a temperature over 100.4°F (CDC Recommendation) shall be told to go home and isolate to avoid the transmission of the virus.
- 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 directed to stagger breaks and lunches or take breaks or lunches in separate areas, to avoid being within 6 feet of any other person, and to reduce the size of any group at any one time to less than ten (10) people while exercising 6 foot separation between individuals.
- The Company understands that due to the nature of our work, access to running water for hand washing may be impracticable. In these situations, the Company will provide, if available, alcohol-based hand sanitizers and/or wipes.
- Employees shall bring their own hand tools to the jobsite and not share their hand tools with any other worker or individual. Company provided tools shall be check out and returned to the company tool area where the worker shall clean the tools and sanitized before reuse in accordance with best practices and manufacturing recommendations for proper cleaning techniques and restrictions. All handles, adjustment and other items commonly touched on the tool shall be sanitized before reuse.
- Employees shall use N95 respirators when communicating with other employees and are encouraged to limit the need for N95 respirator use, by using electronic communications, 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.
- The Company 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, the Company will divide employees into dedicated shifts, at which point employees will remain with their dedicated shifts for the reminder of the project. If there is a legitimate reason for an employee to change shifts, the Company will have sole discretion in making that change.
- Employees shall not travel in the same vehicle to from or around the jobsite. Employees are to travel to and from the jobsite using their own vehicle without riders or passengers.
- Employees shall use individual and sanitized water bottles in lieu of using a common source of drinking water, such as a cooler.
- Employees shall wash or sanitize their hands when:
- At the time of arrival at the job site and before beginning work
- Each time before they use a company provided tool or equipment
- Each time after they use a company provided tool or equipment
- Before taking a rest break
- After taking a rest break
- Before taking a lunch break
- After taking a lunch break
- After using the restroom facilities
- Before leaving the job site
Additional Jobsite Safety Precautions Include: Additional Precautions that May be Appropriate for Specific Companies, Business Operations or Projects.
- Social distancing can help stop the spread of COVID-19. Health and government officials recommend avoiding large gatherings with more than 10 people and maintaining 6 feet of space between other people. This reduces the chance of contact with those who knowingly or unknowingly carry the virus. If employees exhibit symptoms of COVID-19, they should not report to work.
- Employees reporting for work shall have their temperature taken using a touchless thermometer. Any employee with a temperature over 100.4°F (CDC Recommendation) shall be told to go home and isolate to avoid the transmission of the virus.
- Consider using crews with the same workers. Crew consistency can help minimize virus spread. New federal guidelines suggest in addition to social distancing, workers should wear nonsurgical cloth face coverings to minimize the unintentional spread of the virus.
- Before any work begins, the jobsite manager shall prepare a work plan to maximize worker separation of 6 feet or more at all times during the workday or provide other means (such as respirators) where social distancing is not possible to avoid the transmission of the virus. All workers at the job site shall be advised about the plan, have their questions answered and shall carry out the plan.
- Comply with all items in sections of this document.
- Roofing materials shall be laid out to facilitate the workers installing roofing in separate areas
- Employees shall be assigned to work on different parts of the roof to do tear-off and to do installing.
- When workers come within 6 feet of one another, one worker shall move to another area or take a break while the other worker finishes the work in that area.
Roofing generally is considered an essential job at this time. Sequencing work is a way to maintain or create social distancing. Consider the following:
- Staggering crews’ arrival and departure times to and from the yard to minimize interaction to fewer than 10
- Sequencing arrival at and departures from job sites to avoid gatherings at access
- Brainstorming to rethink installation of roof system or repair work protocols to accommodate social distancing and other virus-prevention work practices, such as hand washing and/or Refer to RCAW’s Toolbox Talk: Coronavirus Disease 2019 (COVID-19) Awareness.
- Sequencing work to use only necessary workers during specific
Communication is key between you and your customers. Some ways to maintaining open communication include:
- Informing customers that in-person communication between them and your company’s workers increases the possibility of spreading the virus and will be kept to a
- Establishing an electronic communication protocol among your customers, your office and the job-site foreman and/or crew leader to eliminate in-person
- Considering prioritizing projects according to roof system condition and building use; for example, those where securing the health and/or safety of a building’s occupants is most in
Typically, service technicians are transported together in a vehicle. But to practice social distancing, consider the following:
- Staggering worker shifts to eliminate groups gathering at the yard or job sites.
- Having workers meet at job sites in their own vehicles.
- Limiting company vehicle use to one driver.
- Cleaning and disinfect surfaces of vehicles before and after use.
- If necessary, considering social distancing when there are multiple passengers in a vehicle and wear masks during transport.
- If necessary, increasing the number of trips so there are no more than two riders per trip.
With site access being limited, workers’ access likely will be restricted by building owners. It is a good idea to discuss ways to increase social distancing with building owners before arriving at job sites. You’ll need to determine which of the following is best:
- Aerial lifts
- Dedicated entry point
- Dedicated elevator—one passenger pre elevator ascent or decent
- Dedicated stairwell and users shall wear gloves and avoid handrail contact to the extent possible
- Dedicated hallway
Tools and Equipment
Tools and equipment are essential to roofing. As much as possible, limit tool use among workers and only allow sharing when necessary. Consider the following:
- Bringing only essential hand tools to job
- Instruct workers to lock tools up, keep tools in their toolbelts, or in their work area to maintain individual
- Instruct workers not to share hand tools
- When possible, wearing protective gloves while using (Follow all recommended manufacturer requirements for personal protective equipment.)
- Clean and disinfect tools before and after
- Communicate to customers your company is only accepting noncontact payment methods. Do not allow in-person payments that require touching of cash, checks or any type of cards.
- Billing and payments should be performed electronically between customer and office personnel, not with on-site personnel.
- Have customers submit payments electronically at the time of service.
Workers entering Occupied Building and Homes
- Workers shall not enter any occupied buildings unless a social distancing plan has been developed for the building to maintain a minimum of 6-foot separation between other employees and building occupants. Any worker entering a building shall wear gloves, a face mask and carry a sanitizing wipe to wipe off all doorknobs and other knobs, buttons, or handles the worker may touch.
- During this work, employees must sanitize the work areas upon arrival, throughout the workday, and immediately before departure. The Company will provide alcohol-based wipes for this purpose.
- 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 their work.
Job Site Visitors including but not limited to subcontractors and Inspectors
- 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 shall be instructed on maintaining 6-foot separation between individuals at all times. Visitors who fail to maintain 6-foot separation shall be directed to leave the jobsite.
- 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 shall not be permitted to access the jobsite:
- Have you been confirmed positive for COVID-19?
- Are you currently experiencing, or recently experienced, any acute respiratory illness symptoms such as fever, cough, or shortness of breath?
- Have you been in close contact with any persons who has been confirmed positive for COVID-19?
- Have you been in close contact with any persons who have traveled and are also exhibiting acute respiratory illness symptoms?
- Visitors may be subject to temperature screening before entering the worksite using a touchless thermometer. A visitor not accepting the temperature screening and other requirements listed below shall be not allowed on the worksite.
- Every visitor must wash or sanitize their hands before entering the worksite and before leaving the worksite.
- Every visitor shall wear an N95 mask while at the worksite.
- Every visitor entering the worksite shall wear appropriate gloves to avoid the transmission of the virus.
- Site deliveries will be permitted and require 6-foot separation between Indi duals and meet the other visitor requirements described in this section 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.
Personal Protective Equipment and Work Practice Controls
In addition to regular PPE for workers engaged in various tasks (fall protection, hard hats, hearing protection), the Company will also provide:
- Gloves: Gloves should be worn at all times while on-site. The type of glove worn should be appropriate to the task. If gloves are not typically required for the task, then any type of glove is acceptable, including latex gloves. Employees must not share gloves.
- Eye protection: Eye protection should be worn at all times while on-site.
- NOTE: The CDC is currently recommending that healthy people wear N95 respirators to prevent the spread of COVID-19. Employees must wear N95 respirators.
- Due to the current shortage of N95 respirators, the following Work Practice Controls should be followed:
- Keep dust down by using engineering and work practice controls, specifically through the use of water delivery and dust collection systems.
- Minimize exposure time to the extent practicable.
- Isolate workers in dusty operations by using a containment structure or distance to limit dust exposure to those employees who are conducting the tasks, thereby protecting other workers and bystanders.
- Institute a rigorous housekeeping program to reduce dust levels on the jobsite
Job Site Cleaning and Disinfecting
The Company has instituted regular housekeeping practices, which include cleaning and disinfecting frequently used company tools and equipment, and other elements of the work environment, where possible. Employees should regularly do the same in their assigned work areas.
- 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. The Company will ensure that hand sanitizer dispensers are always filled. Frequently touched items (i.e. door pulls and toilet seats) will be disinfected frequently.
- Vehicles and company equipment/tools should be cleaned after every use by the person that last used the tool, again before the next person uses a company tool, and at least once per day.
- 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 work environments, unless those environments are visibly contaminated with blood or other bodily fluids.2 Notwithstanding this, the Company 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 work space again.
- The Company will ensure that any disinfection shall be conducted using one of the following:
- Common EPA-registered household disinfectant.
- Alcohol solution with at least 60% alcohol; or
- Diluted household bleach solutions (if appropriate for the surface).
- The Company will maintain Safety Data Sheets of all disinfectants used on site. 2 https://www.osha.gov/SLTC/covid-19/controlprevention.html [Additional Cleaning and Disinfection Guidelines Include: Additional Cleaning Requirements that May be Appropriate if Hazardous Materials are Used Onsite ].
Jobsite Exposure Situations
- 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). The Company 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). 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 seven (7) 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;3 and (2) at least seven (7) days have passed since symptoms first appeared. Employees who test positive and have been hospitalized may return to work when directed to do so by their medical care providers. The Company 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 less for five minutes or more. If the Company learns that an employee has tested positive, the Company 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. The Company 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 Recovery is defined as:
- Resolution of fever without the use of fever-reducing medications and;
- improvement in respiratory symptoms (e.g., cough, shortness of breath). Manager or supervisor of the close contact and self-quarantine for 14 days from the last date of close contact with that individual.
OSHA Recordkeeping If a confirmed case of COVID-19 is reported:
- The Company 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
- results in a fatality, or
- 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 diagnosis, the recordability analysis is not necessarily triggered at that time.
If an employee has a confirmed case of COVID-19, the Company will 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.
The Company’s 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, the Company will report the case to OSHA if it results in a fatality within 30 days or an in-patient hospitalization within 24-hours of the exposure incident.
Except for circumstances in which the Company 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. The Company 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. The Company 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, the Company may modify this Plan on a case by case basis. If you have any questions concerning this Plan, please contact: [Title of Designated Individual].
COVID-19 Checklist for Employers and Employees Know the Symptoms of COVID-19
- Coughing, fever, shortness of breath, and difficulty breathing.
- Early symptoms may include chills, body aches, sore throat, headache, diarrhea, nausea/vomiting, and runny nose. If you develop a fever and symptoms of respiratory illness, DO NOT GO TO WORK and call your supervisor and health-care provider immediately. Do the same thing if you come into close contact with someone showing these symptoms. Employer Responsibilities • Develop a COVID-19 Exposure Action Plan.
- Conduct safety meetings (toolbox talks) by phone if possible. If not, instruct employees to maintain 6-feet between each other. The foreman/supervisor will track attendance verbally rather than having employees sign an attendance sheet.
- Access to the job site and work trailer will be limited to only those necessary for the work.
- All visitors will be pre-screened to ensure they are not exhibiting symptoms.
- Employees, contractors, and visitors will be asked to leave the jobsite and return home if they are showing symptoms.
- Provide hand sanitizer and maintain Safety Data Sheets of all disinfectants used on site.
- Provide protective equipment (PPE) to any employees assigned cleaning/disinfecting tasks.
- Become familiar with the Exposure Action Plan and follow all elements of the Plan.
- Practice good hygiene: wash hands with soap and water for at least 20 seconds. If these are not available, use alcohol-based hand rub with at least 60% alcohol. Avoid touching your face, eyes, food, etc. with unwashed hands. Cleaning/Disinfecting Job Sites and Other Protective Measures
- Clean and disinfect frequently used tools and equipment on a regular basis. This includes other elements of the jobsite where possible. Employees should regularly do the same in their assigned work areas.
- Clean shared spaces such as trailers and break/lunchrooms at least once per day.
- Disinfect shared surfaces (door handles, machinery controls, etc.) on a regular basis. • Avoid sharing tools with co-workers. If not, disinfect before and after each use.
- Arrange for any portable job site toilets be cleaned by the leasing company at least twice per week and disinfected on the inside.
- Trash collected from the jobsite must be changed frequently by someone wearing gloves.
Personal Protective Equipment and Alternate Work Practice Controls
- Provide and wear the proper PPE.
- Keep the dust down by using engineering and work practice controls, specifically using water delivery and dust collection systems.