COVID-19 Prevention Program

Workplace COVID-19 cases or exposures

Multiple COVID-19 infections and COVID-19 outbreaks

Major COVID-19 outbreaks

COVID-19 prevention in employer-provided housing

COVID-19 prevention in employer-provided transportation

Cleaning and disinfecting

 

COVID-19 Prevention Program

1. Do I have to have a COVID-19 Prevention Program and what must be included?

All employers covered by the regulation must have a COVID-19 Prevention Program. There are specific requirements for the COVID-19 Prevention Programs that employers must follow. The eleven areas that a Covid-19 Prevention Plan must cover are:

  1. A system for communicating with employees about COVID-19
  2. A system for reporting, identifying, and evaluating COVID-19 hazards in the workplace
  3. A plan for investigating and responding to COVID-19 cases in the workplace
  4. A plan for correcting COVID-19 hazards in the workplace
  5. A training and instruction program for employees regarding COVID-19 in the workplace
  6. A plan for physical distancing of employees in the workplace
  7. A plan for providing face coverings for employees in the workplace
  8. A plan for other engineering controls, administrative controls and personal protective equipment
  9. A plan for reporting, recordkeeping, and access to records regarding COVID-19 in the workplace
  10. A plan for exclusion of COVID-19 cases from the workplace
  11. Return to work criteria

2. Does my COVID-19 Prevention Program have to be in writing?

Yes.

3. Does my COVID-19 Prevention Program have to be a separate document or can it be included in the IIPP?

It can be integrated into existing programs like an IIPP or be a stand-alone document.

4. What needs to be covered in the employee training?

Employee training must cover:

    • The employer’s COVID-19 policies and procedures to protect employees from COVID-19 hazards.
    • Information about COVID-19-related leave benefits to which the employee may be entitled under federal, state, or local laws. Some of these benefits are:
      • Workers’ compensation law
      • The federal Families First Coronavirus Response Act
      • Local governmental requirements
      • The employer’s own leave policies
      • Leave guaranteed by contract
    • Information about the COVID-19 including what it is, what the symptoms are, and how it spreads.
    • Ways to physically distance at least six feet and the importance of combining physical distancing with wearing face coverings.
    • 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 and hand hygiene, to be effective.
    • The importance of frequent hand washing:
      •  Use soap and water and wash for at least 20 seconds.
      • If a sink or handwashing facility is not available, use hand sanitizer.
      •  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.
    • The importance of employees staying out of the workplace if they have COVID-19 symptoms and .

5. Do I have to provide face coverings at no cost for my employees?

Yes. The regulations require that employers provide face coverings. Employer must also ensure that they are worn by employees over the nose and mouth when indoors, when outdoors and less than six feet away from another person, and where required by orders from the California Department of Public Health or a local health department.

“Face covering” means a tightly woven fabric or non-woven material with no visible holes or openings that covers the nose and mouth.

6. Are there exceptions to the face covering requirement?

Yes. Face coverings are not required:

  • When an employee is alone in a room.
  • While eating and drinking at the workplace, but employees must stay at least six feet apart. If indoors, employers should open windows and doors to increase outside airflow as much as possible in eating areas.
  • By employees wearing respiratory protection in accordance with section 5144 or other California Code of Regulations Title 8 safety orders.
  • During specific tasks that cannot be performed with a face covering. This exception is limited to the time period when such tasks are actually being performed, and the unmasked employee must be at least six feet away from all other persons unless unmasked employees are tested at least twice weekly for COVID-19.
  • By employees who cannot wear face coverings due to a medical or mental health condition or disability, or who are hearing-impaired or communicating with a hearing-impaired person. However, the employer must provide an alternative, such as a face shield.

7. What if any employee cannot wear a face covering because of a mental or physical condition?

Employees who cannot wear a traditional face covering should wear an effective non-restrictive alternative, such as a face shield with a drape on the bottom, if their condition or disability permits it.

8. What if an employee cannot wear a face covering or a face shield with a drape?

If an employee cannot wear a face covering, face shield with a drape or other effective alternative, or respiratory protection, for any reason, then they must be kept least six feet apart from all other persons unless the unmasked employee is tested at least twice weekly for COVID-19. Employers may not use COVID-19 testing as an alternative to face coverings when face coverings are otherwise required.

9. Do I have to require members of the public to wear face coverings on my premises?

This will vary by county. Consult your local health department and keep the following in mind:

  • Employers are responsible for protecting employees from those not wearing face coverings, including members of the public.

Employers are required to communicate to non-employees the face mask policy in effect on the worksite.

10. What if the nature of our work does not allow for physical distancing at all times?

When it is not possible to maintain a distance of at least six feet, employees must be kept as far apart as possible.

In cases where the nature of the work does not allow at least six feet of distance, employers should use a combination of other controls to reduce exposure, such as face covers, physical barriers, and using ventilation to dilute or redirect air in the work area. that may contain airborne virus.

11. The regulation says I have to include procedures or policies for accommodating employees with medical or other conditions that put them at increased risk of severe COVID-19 illness. What resources are available to help with this?

Employers must provide a reasonable accommodation if a person with a disability needs one in order to apply for a job, perform a job, or enjoy benefits equal to those you offer other employees. You do not have to provide any accommodation that would pose an undue hardship.

The Equal Employment Opportunity Commission (EEOC) has a great webpage with answers to common questions about accommodating employees at increased risk for COVID-19 while complying with the Americans with Disabilities Act (ADA).

The Job Accommodation Network (JAN) website is a helpful rexource for types of accommodations including some that are specific to COVID-19..

12. What sort of conditions put someone at increased risk of severe COVID-19 illness?

There are a number of conditions that put people at higher risk, such as heart or lung conditions and diabetes. Please visit the CDC’s site for the full list and more information.

13. Can we require a doctor’s note verifying the person has a condition that puts them at increased risk of severe COVID-19 illness?

As with any accommodation request, employers may ask questions to determine whether the condition is a disability and discuss with the employee how the requested accommodation would help him to keep working. The employer should always engage in a timely, good faith, interactive process with the employee. The interactive process is an open dialog between the employee and employer to gather information such as :

  • Physical limitations
  • Work restrictions
  • Ability to perform essential function
  • Possible accommodations to help the employee do the job

The Americans with Disabilities Act (ADA) does not interfere with employers following recommendations by the CDC or other public health authorities.

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Workplace COVID-19 cases or exposures

14. How is the term “exposed worksite” defined in the Emergency Regulations?

 An “exposed worksite” is “any work location, working area, or common area at work used or accessed by a COVID-19 case during the high-risk period (See Question #16), including bathrooms, walkways, hallways, aisles, break or eating areas, and waiting areas. The exposed workplace does not include buildings or facilities that are not entered by a COVID-19 case. It does not apply to buildings, floors, or other locations of the employer that the COVID-19 case did not enter.

15. How is a COVID exposure defined by the regulation?

A COVID-19 exposure means being within six feet of a COVID-19 case for more than 15 minutes in any 24-hour period within or overlapping with the “high-risk exposure period”. This definition applies regardless of the use of face coverings.

16. What is the “high-risk exposure period”?

The “high-risk exposure period” means the following time period:

  • For persons who develop COVID-19 symptoms:
    • From two days before they first develop symptoms until 10 days after symptoms first appeared, and
    • 24 hours have passed with no fever without the use of fever-reducing medications, and
    • Symptoms have improved
  • For persons who test positive who never develop COVID-19 symptoms:
    • From two days before until ten days after the specimen for their first positive test for COVID-19 was collected

17. We just had an employee report they tested positive for COVID-19? What do we have to do now?

  1. Investigate other potential exposures
  • Determine the day and time the employee with COVID-19 was last in the workplace, the date of the positive test result, and the date the employee first experienced symptoms. This information is important for determining who else may have been exposed as well as when the employee can return to work.
  • Determine what other employees may have been exposed. This requires an evaluation of all of the activities of the infected employee during the “high risk exposure period”.
  1. Make any required reports to outside agencies. If you have five or more employees, report any workplace cases to State Fund or your workers’ compensation carrier if you are insured by another carrier to meet the requirements of Senate Bill 1159. See Question #21 on different reporting requirements, including ones to your workers’ compensation carrier.

Note: Reporting this to your workers’ compensation carrier does not automatically result in a claim being filed. Your carrier will discuss with you the circumstances around the case to determine whether it is work-related.

  1. Keep the COVID-19 positive employee as well as any other employees exposed to the positive employee out of the workplace.

The employees exposed at the workplace must isolate at home for 10 days and be paid wages as if they are working. Please see Questions #22-24 for more information on wage requirements and options. Please note, Section 3205 references a 14-day isolation period for employees exposed at work. The length of the isolation period was changed by Governor Newsom’s Executive Order N-84-20 to coincide with recently updated guidance from the CDC and California Department of Public Health regarding isolation periods following an exposure.

  1. Inform employees, independent contractors and other employers present in the workplace of the potential exposure within 1 day.

Do not reveal any personal identifying information about the COVID-19 case

  1. Provide Testing to employees who were exposed to the COVID-19 case

See Question #18 with more information on how to find testing resources for your worksite.

  1. Investigate the case to determine work-relatedness and potential improvements that can be made to your COVID-19 Prevention Program to prevent future cases at work.

Update your program as needed.

  1. Keep a record of and track all COVID-19 cases with the employee’s name, contact information, occupation, location where the employee worked, the date of the last day at the workplace and the date of the positive COVID-19 test.

Keep medical information confidential and secure.

  1. Allow the employees isolating at home to return to work once they have meet the Return to Work criteria.

See Question #26 for more information on the Return to Work criteria.

18. How can I find out about available testing options for my workplace?

We recommend that you contact your local health department to find out options for testing in your local area.

The California Department of Public Health maintains a directory of local health departments

19. Testing is limited in my area. Are test kits by mail an acceptable method of testing employees?

Tests must be approved by the United States Food and Drug Administration (FDA) or has an Emergency Use Authorization from the FDA to diagnose current infection with the virus that causes COVID-19. The test must also be administered in accordance with the FDA approval or the FDA Emergency Use Authorization.

The FDA maintains a list of current test kits, including home collection kits, that have Emergency Use Authorizations. 

20. When must we report COVID-19 cases and to whom do we make the reports?

There are three different COVID-19 reporting requirements that may apply to a business with one or more COVID-19 cases, depending on the circumstances.

  1. Cal/OSHA has a requirement to report fatalities or serious illnesses to the nearest Cal/OSHA district office within 8 hours of learning of the fatality or illness meeting the reporting criteria. For serious illnesses like COVID-19, this would be any illness that requires inpatient hospitalization. For these reports, the fatality or illness must be work-related. Employers must immediately report COVID-19 related serious injuries or deaths.
  1. There are requirements to report to the local health department whenever there are three or more COVID-19 cases at the same worksite within a 14-day period. These requirements come from Assembly Bill (AB) 685 as well as from the new Cal/OSHA regulations 3205.1, Multiple COVID-19 Infections and COVID-19 Outbreaks and 3205.2, Major COVID-19 Outbreaks.
  1. For businesses with five or more employees, there is a requirement to report any employee positive case to your workers’ compensation carrier. This requirement comes from Senate Bill (SB) 1159.

21. Do I have to pay wages to employees who have to isolate at home due to a workplace exposure to COVID-19?

Yes. You must continue wages, seniority, and all other employee rights and benefits, including the employee's right to their former job status, as if the employee had not been removed from their job.. Employers may use employer-provided employee sick leave benefits for this purpose and consider benefit payments from public sources where permitted by law and when not covered by workers’ compensation.

See FAQs on the wage continuation requirements for the Labor Commissioner’s Office for more information.

22. Are wages that must be paid to employees who have an exposure at work and must stay at home for 10 days covered under my workers’ compensation policy?

No, they are not. The majority of our policyholders are subject to providing paid sick leave benefits under the Families First Coronavirus Response Act (FFCRA)  unless the policyholder or an employee qualifies for an exemption. Some employers may also be subject to local laws/ordinances that require they provide supplemental paid sick leave benefits.

If the employee advises the employer that they believe they have been exposed to AND contracted COVID-19 from a workplace exposure, then a workers’ compensation claim form must be provided to the employee. The employee does not have to wait for symptoms to develop. If a COVID-19 claim is accepted, the injured worker will be provided with workers’ compensation benefits. These include: 1) medical care 2) Temporary Disability benefits if the injured worker loses wages 3) Permanent Disability if the injured worker does not recover completely 4) Supplemental Job Displacement voucher if the injured worker needs retraining if they do not recover fully and don’t return to work for their employer and 5) Death Benefits to the spouse, children or dependents if the injured worker dies from the job injury or illness.

23. Are there any available resources to help pay wages for employees who much stay at home due to a potential workplace exposure to COVID-19?

The Division of Industrial Relations (DIR) website has a chart with a snapshot of paid leave laws that may cover California workers affected by COVID-19.

24. For how long must employees with COVID-19 exposures be kept out of the workplace?

Employees who have had a COVID-19 exposure must be kept out of the workplace for 10 days after the last known exposure to a COVID-19 case. If they develop symptoms and test positive for COVID-19 they must remain away from the workplace until the Return to Work requirements are met.

Please note, Section 3205 references a 14 day isolation period for employees exposed at work. The length of the isolation period was changed by Governor Newsom’s Executive Order N-84-20 to coincide with recently updated guidance from the CDC and California Department of Public Health (CDPH) regarding isolation periods following an exposure. The new CDPH guidance requires that employees who return to work after 10 days of isolation wear face coverings and keep a distance of six feet from others until the at least 14 days have passed since the last exposure.

25. What are the Return to Work requirements for employees who test positive for COVID-19 or are subject to a local health department to isolate?

COVID-19 cases (employees who test positive for COVID-19 or are directed to isolate by a local health department) with COVID-19 symptoms cannot return to work until:

  • 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
  • At least 10 days have passed since COVID-19 symptoms first appeared.

COVID-19 cases who tested positive but never developed COVID-19 symptoms cannot return to work until a minimum of 10 days have passed since the date of specimen collection of their first positive COVID-19 test.

A negative COVID-19 test cannot be required for an employee to return to work.

If a local or state health official tells an employee they must isolate or quarantine at home, then the employee cannot 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 shall be 10 days from the time the order to isolate or the order to quarantine was effective.

If there are no violations of local or state health officer orders for isolation or quarantine, Cal/OSHA may, upon request, allow employees to return to work on the basis that the removal of an employee would create undue risk to a community’s health and safety. In such cases, the employer must develop, implement, and maintain effective control measures to prevent transmission in the workplace including providing isolation for the employee at the workplace and, if isolation is not possible, the use of respiratory protection in the workplace.

26. What records must I maintain under these regulations?

Employers must keep the following documents and records:

  1. The written COVID-19 Prevention Program
  2. Records of the steps taken to implement the written COVID-19 Prevention Program
  3. Records of scheduled and periodic inspections required to identify unsafe conditions and work practices, including person(s) conducting the inspection, the unsafe conditions and work practices that have been identified and action taken to correct the identified unsafe conditions and work practices. These records shall be kept for at least one (1) year
  4. Safety and health training records each employee, including employee name or other identifier, training dates, type(s) of training, and training providers. This documentation shall be maintained for at least one (1) year.
  5. A record of all COVID-19 cases with the employee’s name, contact information, occupation, location where the employee worked, the date of the last day at the workplace, and the date of a positive COVID-19 test.

27. How can we keep medical records secure and confidential?

The ADA requires that all medical information about a particular employee be stored separately from the employee's personnel file, thus limiting access to this confidential information. An employer may store all medical information related to COVID-19 in existing medical files. This includes an employee's statement that he has the disease or suspects he has the disease, or the employer's notes or other documentation from questioning an employee about symptoms.

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Multiple COVID-19 infections and COVID-19 outbreaks

28. When is my workplace considered to have multiple COVID-19 infections or an outbreak?

Your workplace is considered to have an outbreak when:

  • Your local health department indicates you have an outbreak or
  • You have three or more COVID-19 cases at a worksite within a 14-day period.

Your workplace is considered to have a major outbreak when there are 20 or more cases at a worksite within a 14-day period. Note, COVID-19 cases include employees who are subject to a COVID-19 related order to isolate issued by a local or state health official.

29. With respect to an “outbreak,” how is the term “COVID-19 Case” defined in the Emergency Regulations?

A COVID-19 Case is defined as a person who:

    • Has a laboratory-confirmed case of COVID-19, as defined by the State Department of Public Health or
    • Has a positive COVID-19 diagnosis from a licensed health care provider or
    • Has a COVID-19-related order to isolate provided by a public health official; or
    • Died due to COVID-19, in the determination of a county public health department, or per inclusion in the COVID-19 statistics of a county.

30. Does mere exposure or suspected exposure make someone a “COVID-19 Case” under the Emergency Regulations?

No. Mere exposure does not make someone a qualifying individual or a COVID-19 case.

  1. What must an employer do in response to a COVID-19 Outbreak under the Emergency Regulation?
    • Provide testing for employees
      • When there is an outbreak, the employer must provide COVID-19 testing to all employees at the exposed workplace except for employees who were not present during the period of an outbreak identified by a local health department or the relevant 14-day period(s) when the cases were identified. COVID-19 testing must be provided at no cost to employees during employees’ working hours.
      • Additional COVID-19 testing must be provided a week after the initial testing.
      • After the first two COVID-19 tests, employers must provide continuous COVID-19 testing of employees who remain at the workplace at least once per week, or more frequently if recommended by the local health department, until there are no new COVID-19 cases detected during a 14-day period.
    • Exclude exposed employees
      • Keep employees with COVID-19 and those who have been exposed out of the workplace.
      • Employers must continue to pay wages to an employee who must isolate at home for 10 days following a workplace exposure as if the employee had not been removed from their job.
      • Employers may use employer-provided sick leave benefits to this purpose and consider benefit payments from public sources.
    • Immediately investigate and determine possible workplace related factors that contributed to the COVID-19 outbreak.
      • This must include 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 shall be documented and include:
      • Investigation of new or unabated COVID-19 hazards including the employer's leave policies and practices and whether employees are discouraged from remaining home when sick
      • The employer’s COVID-19 testing policies
      • Insufficient outdoor air or insufficient air filtration
      • Lack of physical distancing.
    • Update COVID-19 policies and procedures to further reduce risk
    • The employer must 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, and other applicable controls.
  • Notify the local health department
    • The employer must 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. The employer shall continue to give notice to the local health department of any subsequent COVID-19 cases at the workplace.
  1. How quickly must I make the report to my local health department if there are three or more COVID-19 cases at my workplace?

The report must be made immediately and no longer than 48 hours after the employer knows, or with diligent inquiry would have known, of three or more COVID-19 cases at a worksite.

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Major COVID-19 outbreaks

31. What is a “a major COVID-19 Outbreak”?

    • A “major COVID-19 Outbreak” is any place of employment where “there are 20 or more COVID-19 cases in an exposed workplace within a 30-day period.” 8 CCR Section 3205.2(a)(1). A major COVID-19 Outbreak continues until there are no new COVID-19 cases detected in a workplace for a 14-day period.” 8 CCR Section 3205.2(a)(2).

32. What does an employer need to do if there is a major COVID-19 outbreak in one of its workplaces under the Emergency Regulations?

  • Provide Employee Testing for COVID-19
    • Employers must provide twice a week COVID-19 testing, or more frequently if recommended by the local health department, to all employees present at the exposed workplace during the relevant 30-day period(s) and who remain at the workplace.
    • COVID-19 testing shall be provided at no cost to employees during employees’ working hours.
    • Employers must ensure COVID-19 cases and employees with COVID-19 exposure are excluded from the workplace
  • Exclude COVID-19 cases from the workplace
    • Employees who have COVID-19 exposures must isolate at home for 10 days.
    • Employers must continue to pay wages to an employee who must isolate at home for 10 days following a workplace exposure as if the employee had not been removed from their job.
    • Employers may use employer-provided sick leave benefits to this purpose and consider benefit payments from public sources.
  • Investigate cases to find potential causes and take steps to improve their COVID-19 Prevention Plan to prevent additional infections.
    • Employers must improve ventilation filtration if possible and consider the use of portable or mounted air cleaners in the workplace
    • Employers must determine if respirators are needed for employees
  • Employers must evaluate whether to halt some or all operations to control COVID-19 hazards.
  • Notify the local health department
    • Employers must notify their local health department of multiple cases within 48 hours.

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COVID-19 prevention in employer-provided housing

33. What is considered employer provided housing?

Employer-provided housing is free or paid living space provided to workers, in connection with the worker’s employment.

It includes any place or area of land, any portion of any housing accommodation, or property upon which a housing accommodation is located and consisting of:

  • Living quarters
  • Dwelling
  • Boardinghouse
  • Tent
  • Bunkhouse
  • Maintenance-of-way car
  • Mobile home
  • Manufactured home
  • Recreational vehicle
  • Travel trailer, or
  • Other housing accommodations

Housing includes a “labor camp” as referred to in Title 8 of the California Code of Regulations and Title 25 California Administrative Code, section 610 - Employee Housing

Employer-provided housing can be in one or more sites, including:

  • Hotels and motels, or the surrounding property
  • An area set aside and provided for parking of mobile homes or camping

34. What businesses are excluded from the employer-provided housing requirements?

The following business are excluded from the requirements:

  • Government entities that provide housing for emergency response
    • Firefighting, rescue, and evacuation
    • Support activities directly aiding response such as utilities, communications, and medical operations
  • Private employers providing temporary housing that is necessary to conduct the emergency response operations.
  • Occupants who maintained a household together with family members, when no other persons outside the household are present, prior to residing in employer-provided housing.

35. How must bedrooms be set up in employer provided housing?

Bedrooms must be arranged as follows:

  • No bunk beds are allowed.
  • Set beds at least six feet apart in all directions.
  • Position beds to maximize the distance between sleepers’ heads.

36. What do I do if an employee in employer provided housing tests positive for COVID-19?

Employers must do the following:

  • Develop policies and procedures to effectively isolate COVID-19 exposed residents from all other occupants.
  • Provide COVID-19 exposed residents with a private bathroom, sleeping area, and cooking and eating facility that is not shared by non-COVID-19 case occupants.
  • House COVID-19 cases only with other COVID-19 cases.
  • Keep personal information about employees with COVID-19 symptoms and cases confidential.
  • Follow the Return to Work criteria before allowing employees with COVID-19 to resume housing with other employees.

The State of California’s Housing for the Harvest Program offers temporary hotel housing to agricultural workers who need to isolate due to COVID-19. Check their website for more information and a listing of the counties where the program is available.

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COVID-19 prevention in employer-provided transportation

37. What is considered employer-provided transportation?

Employers who provide, arrange for, or secure transportation of employees to and from work in vehicles are required to take these precautions for COVID-19 protection. This includes carpools, rideshare/shuttle vehicles, and private charter buses.

38. What businesses are excluded from the employer-provided transportation requirements?

This emergency temporary standard applies to all employers except:

  • Workplaces where there is only one employee who does not have contact with other people
  • Employees who are working from home
  • Employees who are covered by the Aerosol Transmissible Diseases regulation

These requirements also do not apply to residents of the same household who share the same vehicle, emergency response workers such as fire-fighting, rescue and evacuation workers, and their support, such as utilities, communications, and medical operations.

39. Do we have to keep the windows open in our vehicles?

Windows should be open in the vehicle in order to maximize the outdoor air supply. Windows may be closed when:

  • The air conditioner is in use and the temperature exceeds 90 degrees Fahrenheit
  • The heater is in use and the temperature is below 60 degrees
  • The cabin air filter is in use, and the potential contaminants have an air quality index greater than 100
  • Weather protection is needed, such as for rain and snow

40. What is the distance that needs to be maintained between passengers in a vehicle?

Employees must stay six feet apart while waiting for transportation, and three feet apart in all directions while in the vehicle. Face coverings are required during screening, while waiting and being transported.

This distance may be increased through the use of large vehicles like passenger vans, or busses as opposed to cars. This will allow for more distance and headspace within the vehicle.

41. What if our employees do not want to wear face coverings in the vehicles?

You would handle these employees just as you would any employee not following any other safety policy you have put into place. This should be done according to the provisions you have established under the compliance section of your IIPP. Those would include your disciplinary procedures and retraining of employees. is effective at making employees understand the hazard and the risks associated with not following the safety rule.

For more information about IIPPs and how to successfully implement them, visit Injury and Illness Prevention Program (IIPP).

If you do not have an IIPP, you can use State Fund’s IIPP Builder℠ to create one.

State Fund cannot answer questions or give advice about employee relations and discipline.

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Cleaning and disinfecting

42. It’s difficult for us to provide handwashing facilities for our employees, particularly those who travel to different locations. Is hand sanitizer an acceptable substitute?

Yes, hand sanitizer can be used to kill coronavirus on hands as long as it has at least 60% alcohol and is used correctly. Follow the label instructions to make sure you use the correct amount of hand sanitizer. Be sure to spread the sanitizer all over the hand including fingertips, thumbs, between fingers, and around finger nails, and then rub it in until it dries.

If your hands are dirty or oily, hand sanitizers do not work as well. You may want to use the sanitizer and a towel to help remove the dirt and oil, and then apply the sanitizer again.

Never use disinfectant cleaning wipes on skin unless they are made for use on human skin. Always read and follow the instructions of the product label.

43. What should we do with our HVAC system? Any special cleaning or filters that should be used?

The best measures you can take for minimizing virus spread in your workplace is to institute control measures in your workplace:

  • Screen employees entering the workplace
  • Reduce the number of people in indoor work environments
  • Require face coverings, physical distancing, handwashing, and cleaning and disinfecting.

There are some recommendations from the American Society of Heating, Refrigerating and Air-Conditioning Engineers, ASHRAE, regarding Heating, Ventilation and Air-Conditioning (HVAC) systems:

  • Increase outside air ventilation
  • Disable demand control ventilation
  • Further open minimum outdoor air dampers, as high as 100%, thus eliminating recirculation
  • Improve central air filtration to the Minimum Efficiency Reporting Value (MERV) rating of 13 or the highest compatible with the filter rack, and seal edges of the filter to limit bypass
  • Keep systems running longer hours, if possible 24/7, to enhance the effects of improving your filtration and reducing recirculation
  • Consider portable room air cleaners with High Efficiency Particulate Air (HEPA) filters
  • Consider UVGI (ultraviolet germicidal irradiation), protecting occupants from radiation, particularly in high-risk spaces such as waiting rooms, prisons and shelters

If you are not responsible for the maintenance or servicing of your ventilation system, provide the guidance in the link above to your contractor or building manager ask what options are feasible for your particular system.

44. Doesn’t intense heat kill the virus? Would a closed up trailer full of work tools need disinfecting after work if it’s hot outside? What about sunlight as a disinfectant?

An important principle of disinfection is concentration and contact time. You need a certain amount of the disinfectant for a certain period of time for it to work effectively. The exact temperature needed to eliminate the COVID-19 virus is currently unknown. Ultra violet (UV) light is also effective at killing viruses, but exposure to UV light is dangerous to humans so sunlight is not a good disinfectant. At this time, the safest and most effective means of disinfecting is to use products on the EPA’s list according to the manufacturer’s instructions. It is recommended that shared tools be cleaned and disinfected before and after use.

45. Any recommendations for disinfecting items that can’t be washed, like books or fabrics?

Unless entirely necessary, remove these items from the workplace. If you have upholstered furniture, clean according to the manufacturer’s instructions using approved products. Consider purchasing a cover that can be easily removed and laundered. Washing fabrics in the highest water temp recommended for the material and thoroughly drying in a clothes dryer will effectively inactivate any virus. Just be sure to wear a face covering when handling laundry and avoid shaking laundry which can send viral particles into the air.

Studies have shown the virus does not remain viable on cardboard or other porous surfaces for more than 24 hours, so time is the best disinfectant for these items. If you have books that are shared by coworkers or customers, set up a system so the book is “quarantined” for one to two days before being used by another.

The CDC has issued guidelines on which products are effective at safely getting rid of the coronavirus, and the Environmental Protection Agency has released a list of registered cleaning products that meet its criteria for killing it.

46. How can we sanitize the air when Lysol™ spray is non-existent these days? I’ve seen HEPA filters but are they “enough?” Which is better to use, a fogger or a sprayer to clean the air?

Be sure you use disinfectants according to the label, otherwise they can be ineffective and present safety or health hazards. Applying chemicals to the air to try to sanitize the air may create hazardous exposures to the cleaning chemicals for the person spraying the chemical or others working nearby. When it comes to air, the best recommendations are to reduce the number of people in indoor spaces, increase the amount of outside air, improve the filter efficiency of your HVAC, and reduce recirculation.

High efficiency particulate air or HEPA filters can help filter out virus particles in the air. Depending on the size of the unit and the space in which it is located, it can take a long time for the air to circulated and be filtered by the air cleaner and it may not filter all of the air. For this reason, it is best to practice source control, such as wearing face coverings and sneezing into a tissue, to reduce virus particles in the air.

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