2020-05-29_jpatchett_Covid-19-Office Opening Guidance.docx

Return to Work Safety and Health Policy

This COVID-19 Return to Work Safety and Health Policy (“Policy”) provides the steps we are taking to reduce the risk of employee exposure to COVID-19 while the office remains open during the COVID-19 pandemic.

The Policy sets forth the preventative measures that must be implemented at each office as it relates to work practice controls, cleaning, and disinfecting procedures, what to do if a worker becomes sick, and face coverings/personal protective equipment (“PPE”).

Every team member has a responsibility to know and follow these polices. Failure to follow the Policy by any employee may result in discipline. All questions regarding this policy should be directed to your supervisor.

WE REMAIN AN ESSENTIAL BUSINESS

Home care and home health care services are considered essential businesses under state stay-at-work orders. We have therefore not been mandated to close offices and we are permitted to remain open or to reopen as needed to provide essential services.

Offices are required to follow all applicable state or local orders regarding how essential businesses are to operate in a Covid-19 environment.

EACH TEAM MEMBER IS ACCOUNTABLE

Each employee is accountable to himself and herself to follow the Company’s policies. We rely on each and every person to do their part.

Employees are required to frequently wash hands with soap and water for at least 20 seconds. If soap and running water are unavailable, use an alcohol-based hand product with at least 60% alcohol.

Avoid touching your eyes, nose, or mouth with unwashed hands.

Follow appropriate respiratory etiquette, which includes covering coughs and sneezes with tissue or crook of elbow (not hands) and immediately dispose of tissue.

Avoid close contact with people who are sick and stay home if you are sick.

OFFICE CLEANLINESS, HYGIENE & SAFETY

The Company has secured adequate supply of tissues, trash receptacles, alcohol-based hand sanitizers and/or wipes.  We have set forth protocols for wiping down and disinfecting surfaces each day, and tracking cleaning supplies to ensure sufficient availability. As an example, each person is responsible for wiping down their own work-space in the morning, afternoon, and before leaving for the day. The last person in the office wipes down community equipment such as phones, printers, etc. If your office needs additional supplies please contact your supervisor.

Enhanced cleaning requirements includes cleaning and disinfecting frequently used surfaces and equipment (i.e., common printer, tables, doorknobs, light switches, countertops, handles, desks, phones, keyboards, toilets, faucets, sinks, etc.) Employees should also regularly clean their assigned work areas. Employees are encouraged to have a clean space without unnecessary personal items (keys, purses, food, personal items, etc.)

Employees should not use coworkers’ workstations, computers, phones, desks, offices, tools, or equipment to the extent possible.

Open windows to increase ventilation in the office.

DAILY EMPLOYEE SCREENING

Employees reporting to the office are required to self-screen for fever and other symptoms, as identified by the CDC and certify that they are symptom-free upon arrival at the office every day.

Each office is required to maintain an Employee Certification form (attached in Appendix 1) at the front desk or other accessible area, and employees should sign their certification immediately upon arriving in the office every day. Completed Employee Certification forms should be retained in a secure location until further notice.

Monitoring of symptoms includes the follows:

Fever of over 100 degrees Fahrenheit,

Respiratory symptoms: coughing, shortness of breath.

Other symptoms as listed and updated from time to time by the CDC: https://www.cdc.gov/coronavirus/2019-ncov/symptoms-testing/symptoms.html.

PHYSICAL DISTANCING IN THE OFFICE

Offices should consider the ability of team members to retain physical distancing or barriers between employee work areas. Consider ways to avoid sharing work-spaces, such as through visual or physical barriers. To the extent possible, offices should increase the physical space between employee’s work- stations (i.e., seating employees in every other work-station) so they are at least six (6) feet apart.

Meal and rest breaks should be taken outside if at all possible (unless an employee has access to a private office). Employees should not gather in common areas – one person may utilize break rooms at a time and the space should be wiped down before leaving the room.

Offices should limit the number of visitors and in-person meetings in the office. Consider in advance who will come in and out of the office and limit the number of people attending in-person meetings. Keep internal in-office meetings short and efficient to conduct business.

Offices may consider staggering days or hours in the office so fewer people are working in the office at any given time if the office lacks space for physical distancing.

Minimize hallway and common area interactions. Examples include tracking entries and exits and/or staggering of lunches and breaks.

MANDATORY FACE COVERINGS AND PERSONAL PROTECTIVE EQUIPMENT

Employees are required to wear a face covering while in the office or performing work on the field on company related matters. The Company recommends that employees use company-provided masks; however, personal face coverings can be used in the office so long as they comply with the requirements of this policy.

In order to properly use a mask or face covering, you must ensure that the covering fits snugly but comfortably against the sides of your face and covers your nose and mouth, the covering is secured either by ties or ear loops, and you can breathe without restrictions.

Employees who plan to wear a respirator such as an N95 mask must read and complete the Employee Safety Training which is attached as Appendix 6 to this Policy.

An employee must not wear a mask or face covering if doing so will adversely affect his/her health. If an employee believes the use of a face covering will affect his/her health, s/he should contact their supervisor.

Each office is responsible for requesting and tracking PPE supplies to ensure sufficient availability. If your office needs additional supplies, please contact your supervisor.

POLICY FOR EMPLOYEES WHO HAVE BEEN EXPOSED OR HAVE SYMPTOMS OF COVID-19

Employee Exhibiting COVID-19 Symptoms. An Employee who is experiencing COVID-19 symptoms (such as fever or cough) cannot report to work, and must immediately contact their supervisor. The Company encourages symptomatic employees to seek medical care. The Company and the symptomatic employee will reassess a return to work strategy once the employee obtains a medical diagnosis. Prior to returning to work, employees must complete the Self-Certification Form which is attached here as Appendix 2.

Employees Who Have Been Directed To Quarantine. Employees who have been instructed to quarantine by a healthcare provider cannot report to work, and must immediately contact their supervisor. Employees must remain at home until 14 days from last close contact with COVID-19 positive individual and may return if no symptoms are experienced during the period of self-quarantine.

1This Policy does not cover mandatory use of a filtering facepiece respirator (FFR) (e.g., N95 mask), nor are the face coverings described in this Policy intended to replicate the protections provided by FFRs and/or surgical masks.

Prior to returning to work, employees must complete the Self-Certification Form which is attached here as Appendix 2.

Employee Who Have Come Into Contact With Covid-19 Positive Individual. Employees who have come into close contact with a COVID-19 positive person (coworker or otherwise) must self-quarantine for 14 days from the last date of close contact with the COVID-19 positive individual. Close contact is defined as 6 feet or fewer for a prolonged period of time. (more than 10 minutes). Prior to returning to work employees must complete the Self-Certification Form which is attached here as Appendix 2.

If the Company learns that an employee is COVID-19 positive, the Company will conduct an investigation into coworkers who may have had close contact with the COVID-19 positive employee in the 48 hours preceding the COVID-19 positive employee’s onset of symptoms and direct those individuals who have had close contact with the COVID-19 positive employee to self-quarantine for 14 days from the last date of close contact with the COVID-19 positive individual.

Employees who are not able to work from the office will be permitted to work from home where appropriate. The Company’s Covid-19 Telework policy will apply where. Employees should communicate with their supervisor regarding any telework arrangement.

POLICY FOR EMPLOYEE RETURNING TO WORK AFTER POSITIVE COVID-19 DIAGNOSIS

Positive Test but Remains Asymptomatic. An Employee who tests positive but remains asymptomatic may return to work when at least 10 days have passed since the date of his or her first positive test, and s/he has not had a subsequent illness or symptoms.

Alternatively, if testing is available, the employee may return to work after the employee receives two negative results of an FDA Emergency Use Authorized COVID-19 molecular assay for detection of SARS-CoV-2 RNA from at least two consecutive respiratory specimen tests in a row, collected at least 24 hours apart. All test results should be final before the employee is allowed to return to work. Prior to returning to work employees must complete the Self-Certification Form which is attached here as Appendix 3.

Positive Test and Symptomatic. An Employee who tests positive, is symptomatic, and is directed to care for herself/himself at home may return to work when: (1) the employee has had no fever for at least 72 hours without the use of medicine that reduces fever; and (2) other symptoms have improved (for example, when the employee’s cough or shortness of breath have improved); and (3) at least 10 days have passed since symptoms first appeared.

Alternatively, the employee may return once the employee: (1) no longer has a fever; and (2), other symptoms have improved (for example, when the employee’s cough or shortness of breath have improved); and (3) the employee receives two negative results of an FDA Emergency Use Authorized COVID-19 molecular assay for detection of SARS-CoV-2 RNA from at least two consecutive respiratory specimen tests in a row, collected at least 24 hours apart. All test results should be final before the employee is allowed to return to work. Prior to returning to work employees must complete the Self-Certification Form which is attached here as Appendix 4.

Positive Test and Hospitalization. An Employee who tests positive and has been hospitalized may return to work when authorized to do so by his/her medical care provider. The Company will require

the employee to provide medical documentation clearing his/her return to work. In addition, prior to returning to work, employees and their healthcare providers must complete a Fitness for Duty Form which is attached here as Appendix 5.

Offices Will Be Cleaned. If an individual who test positive for Covid-19 was in the workplace for three

(3) days before the onset of symptoms, the office will be closed for deep cleaning and will reopen upon notice to employees.

BUSINESS TRAVEL

Business travel is generally prohibited unless approved by your Supervisor.

We continue to encourage internal virtual meetings and conferences.

OTHER CONSIDERATIONS

For non-exempt employees, time spent on self-screening should be recorded as time worked for nonexempt employees.

Employees are expected to report to work based on their office’s return-to-work timelines. Accommodations may be made on a case by case basis for employees who meet the high-risk definition as established by the CDC or who cannot work due to a protected reason. For questions, please contact your supervisor.

Appendix 1

COVID-19 Employee Self Screening Form

Office Location:

By signing below, each employee certifies that he or she –

Has checked their temperature and does not have a temperature of 100 or higher

Has no respiratory symptoms or other symptoms associated with Covid-19 (cough, shortness of breath, sore threat, new loss of taste or smell) For more symptoms, see https://www.cdc.gov/coronavirus/2019-ncov/symptoms-testing/symptoms.html

To each employee’s knowledge signed below, I have not been in direct contact with anyone with Covid-19 for the past 14 days.

Appendix 2

This document (A) must not be shared with anyone except employees authorized to receive the information, (B) must be filed separately from any personnel files, and (C) may be accessed by the COVID-19 Human Resources and the Rapid Response Team

CONFIDENTIAL

SELF-CERTIFICATION FORM - COVID-19

Employee that Has Self-Quarantined without Becoming Symptomatic or COVID-19 Positive

What was the last date you had close contact with a COVID-19 positive individual?

Date:

Have at least 14 days passed since you had close contact with a COVID-19 positive individual?

Yes	No

During the preceding 14 days, have you experienced any symptoms of COVID-19? Symptoms of COVID-19 include, but are not limited to, cough, fever, shortness of breath, difficulty breathing, chills, muscle pain, sore throat, new loss of taste or smell.

Yes	No

I hereby certify that I self-quarantined for 14 days from the date I had close contact with a COVID-19 positive individual and that I have not, and am not currently, experiencing any symptoms of COVID-19.

Signature of Employee		Employee’s Printed Name Date:

Appendix 3

This document (A) must not be shared with anyone except employees authorized to receive the information,

(B) must be filed separately from any personnel files, and (C) may be accessed by the COVID-19 Human Resources and the Rapid Response Team

CONFIDENTIAL

SELF-CERTIFICATION FORM - COVID-19

Employee With Positive Test - Asymptomatic

What was the date you tested positive for COVID-19?

Date:

In the last ten (10) days have you experienced any symptoms of COVID-19 which include, but are not limited to, cough, fever, shortness of breath, difficulty breathing, chills, muscle pain, sore throat, new loss of taste or smell.

Yes	No

Alternatively, if testing is available, you have received two negative results of an FDA Emergency Use Authorized COVID-19 molecular assay for detection of SARS-CoV-2 RNA from at least two consecutive respiratory specimen tests in a row, collected at least 24 hours apart, and both of these test results are final.

Yes	No	Not Applicable

I hereby certify that the above answers are true and I am not currently, experiencing any symptoms of COVID-19.

Signature of Employee		Employee’s Printed Name Date:

Appendix 4

This document (A) must not be shared with anyone except employees authorized to receive the information,

(B) must be filed separately from any personnel files, and (C) may be accessed by the COVID-19 Human Resources and the Rapid Response Team.

CONFIDENTIAL

SELF-CERTIFICATION FORM - COVID-19

Employee With Positive Test - Recovering at Home

What was the date you tested positive for, or were diagnosed positive by a healthcare provider for, COVID-19?

Date:

What was the first date you began experiencing symptoms of COVID-19? Symptoms of COVID-19 include, but are not limited to, cough, fever, shortness of breath, difficulty breathing, chills, muscle pain, sore throat, new loss of taste or smell.

Date:

Have at least ten (10) days passed since you first began experiencing symptoms of COVID-19?

Yes	No

Have you not had a fever for at least 72 hours without the use of medicine that reduces fever, and have your other symptoms improved (for example, have your cough or shortness of breath improved)?

Yes	No

Alternatively, if testing is available, you have received two negative results of an FDA Emergency Use Authorized COVID-19 molecular assay for detection of SARS-CoV-2 RNA from at least two consecutive respiratory specimen tests in a row, collected at least 24 hours apart, and both of these test results are final.

Yes	No	£ Not Applicable

I hereby certify that the above answers are true.

Signature of Employee		Employee’s Printed Name Date:

Appendix 5

Employee with Positive Test – Required Hospitalization

FITNESS FOR DUTY CERTIFICATION FORM- COMMUNICABLE DISEASE CONTEXT

INSTRUCTIONS TO HEALTH CARE PROVIDER

This inquiry was prompted by our understanding that our employee and your patient,

[name]:

(Check all applicable boxes.)

has been diagnosed with 	[insert name of communicable illness] or is presumed by a health care provider to have such communicable illness.

has, within the past 14 days, been in an area (specifically, 		[city/region/state/country]) with a widespread, sustained outbreak of 	[insert name of communicable illness].

has, within the past 14 days, been in close contact, as defined by the CDC, with someone diagnosed with (or presumed by a health care provider to have) 	[insert name of communicable illness], without proper personal protective equipment.

has, within the past 14 days, been in close contact with someone showing symptoms associated with the communicable illness, and (if applicable) person was in the high risk area of  	 [city/region/country].

has, within the past 14 days, been in close contact with someone who has recently traveled from an area

(specifically,

[city/region/state/country]) with a widespread, sustained outbreak of

[insert name of communicable illness].

has been advised or required by his/her health care provider or a public health agency/department to be in quarantine or otherwise avoid close contact with others due to exposure (or potential exposure) to

[insert name of communicable illness].

has  exhibited  the  following  symptoms associated with 	[insert name of communicable illness]: 	[insert symptoms].

other (please specify): 	.

Please answer, fully and completely, any applicable question(s) below. Please do not respond unless the employee authorizes you to do so.

NOTE: The Genetic Information Nondiscrimination Act of 2008 (GINA) and similar state laws generally prohibit employers and other entities covered by GINA Title II (and similar state laws) from requesting or requiring genetic information of an individual or family member of the individual, except as specifically allowed by law. To comply with applicable law(s), we are asking that you not provide any genetic information or results of genetic tests, as defined by applicable law(s), when responding to this request for medical information. By way of example, “genetic information” (as defined by federal law) includes an individual’s family medical history, the results of an individual’s or family member’s genetic tests, the fact that an individual or an individual’s family member sought or received genetic services, and genetic information of a fetus carried by an individual or an individual’s family member or an embryo lawfully held by an individual or family member receiving assistive reproductive services.

Disregarding any potential or actual accommodations or other mitigating measures that may be taken, does the employee’s presence in the workplace performing his/her job functions pose a threat of any kind to the health and/or safety of the employee or others (including a threat of transmitting the applicable communicable illness to employees or clients)?

Yes	No

If you answered “No” in response to Question 1, please explain why, given the understanding that prompted our inquiry (as identified on page 1 of this form), you do not believe the employee poses a threat of any kind to the health and/or safety of any employee or client with whom this employee will interact in the workplace, and then skip to Question 5:

If you answered “Yes” in response to Question 1, please continue to Question 2.

Is the threat to the employee’s own or others’ health and/or safety completely eliminated by mitigating measure(s) (such as medication, assistive devices, or other precautions) that the employee currently takes or is using?

Yes	No

If you answered “Yes” in response to Question 2, please describe the mitigating measure(s) that the employee currently takes or is using that completely eliminates any threat, describe how such measure(s) eliminates any threat, then skip to Question 5:

If you answered “No” in response to Question 2, please continue to Question 3 and 4, but skip Question 5.

If you answered “No” in response to Question 2, please respond to the following inquiries in detail:

Explain the threat posed by the employee’s condition or situation (including the specific aspect or aspects of the employee’s condition or situation that would pose the threat):

State approximately how long the threat will exist:

Describe the nature and severity of the potential harm to the employee’s own or others’ health and/or safety (i.e., what type of injury or harm may be caused? Is there a risk of serious injury or harm, or only a risk of minor injury or harm?):

State your best estimate as to how likely it is that the harm will occur (i.e., whether there is a significant certainty that the harm will occur, a substantial possibility, or only a remote or speculative possibility, etc.):

If you answered “No” in response to Question 2, are there accommodations that you believe will reduce or eliminate the threat posed by the employee to the employee’s or others’ health and/or safety?

Yes	No

If you answered “Yes” in response to Question 4, please describe all the accommodations in detail and explain why and to what degree you believe these accommodations will reduce or eliminate the threat.

Please skip Question 5 if you responded to Questions 3 and 4.

Effective as of 	[date], I certify that the above-named employee/patient is fit to return to work duties as follows:

With no restrictions

With the following restrictions (include limitations and duration of limitations):

Signature of Health Care Provider	Provider’s Printed Name

Type of Practice/Medical Specialty: 		Date:

Telephone: (	) 		Fax:  (	)

Provider E-mail:

Appendix 6: HOME CARE ASSISTANCE

VOLUNTARY USE OF FILTERING RESPIRATORS AND MASKS

Employee Safety Training

Review each of the following points with the employee (have employee initial boxes):

FILTERING FACEPIECE RESPIRATORS AND OSHA REQUIREMENTS

Filtering Facepiece Respirators (also called dust masks) are considered true respirators according to OSHA. N95 refers to the NIOSH certification of the filter media that comprises the facepiece. N means that it is not oil resistant and 95 refers to it being 95% effective at filtering particles at the 0.3 micron level. N95 is the most common type of filtering facepiece respirator. Other NIOSH-certified filtering facepiece respirators include R95, P95, N100 and P100.

Voluntary use is defined as use for employee comfort purposes only. No hazard exists that requires use of a respirator and the use of the respirator does not produce any additional hazard to employee. If employee experiences any problems breathing while wearing the respirator, it should be removed until an evaluation can be completed.

OSHA requires that all employees voluntarily wearing filtering facepiece respirators receive basic information on respirators as provided in Appendix D of their Respirator Standard, 1910.134 (which is found at the end of this document).

HOW TO USE AND WEAR A FILTERING FACEPIECE RESPIRATOR

Inspect respirators prior to use, including new units out of the box. Check for rips and tears. Make sure straps are securely attached, nose piece is attached properly, and that no obvious defects exist.

Proper use of the respirator is important. Without it, the respirator is ineffective against the workplace contaminates. Follow manufacturers’ instructions for use and demonstrate proper use.

Beards and other facial hair negate the effectiveness of the respirator because they prevent an adequate seal between the respirator and the face. Skin conditions, such as dermatitis, or scars, could affect the ability to produce a seal. User seal checks should be done every time the mask is put on and every time it is re-adjusted on the face.

CARE, MAINTENANCE, USEFUL LIFE AND DISPOSAL OF PPE

Filtering Facepiece Respirators and surgical face masks cannot be cleaned when they become wet or soiled. They cannot be shared with other employees.

New respirators should be stored in a clean, dry location, protected from sunlight, chemicals, water, and physical damage. Avoid touching the inside of the respirator. Handling the respirator from the outside is best.

Store used respirators in a clean, breathable container such as a paper bag between uses. To minimize potential cross-contamination, store respirators so that they do not touch each other and the person using the respirator is clearly identified. Storage containers should be disposed of or cleaned regularly.

Clean hands with soap and water or hand sanitizer before and after putting on and taking off respirator.

If working in a facility setting where you visit multiple clients throughout the day, the same respirator may be used throughout the facility. After each use, the respirator should be stored according to guidance.

Use a pair of gloves when putting on a previously used mask.

Discard any respirator that becomes damaged, soiled, or hard to breathe through.

Employee certifies that s/he does not have a medical condition that makes use of a respirator a risk to her/himself, specifically, any breathing or lung problems (i.e., asthma, shortness of breath cardiovascular/heart problems (i.e., heart attack, high blood pressure); skin irritation or allergies. For any questions related to medical fitness, please ask your supervisor.

Acknowledgement of receipt and review of policy.

Name: 		Date:

Signature:

OSHA’s Respiratory Protection Standard, 29CFR1910.134

Appendix D to Sec. 1910.134 (Mandatory) Information for Employees Using Respirators When Not Required Under the Standard

Respirators are an effective method of protection against designated hazards when properly selected and worn. Respirator use is encouraged, even when exposures are below the exposure limit, to provide an additional level of comfort and protection for workers. However, if a respirator is used improperly or not kept clean, the respirator itself can become a hazard to the worker. Sometimes, workers may wear respirators to avoid exposures to hazards, even if the amount of hazardous substance does not exceed the limits set by OSHA standards. If your employer provides respirators for your voluntary use, or if you provide your own respirator, you need to take certain precautions to be sure that the respirator itself does not present a hazard.

You should do the following:

Read and heed all instructions provided by the manufacturer on use, maintenance, cleaning, and care, and warnings regarding the respirators limitations.

Choose respirators certified for use to protect against the contaminant of concern. NIOSH, the National Institute for Occupational Safety and Health of the U.S. Department of Health and Human Services, certifies respirators. A label or statement of certification should appear on the respirator or respirator packaging. It will tell you what the respirator is designed for and how much it will protect you.

Do not wear your respirator into atmospheres containing contaminants for which your respirator is not designed to protect against. For example, a respirator designed to filter dust particles will not protect you against gases, vapors, or very small solid particles of fumes or smoke.

Keep track of your respirator so that you do not mistakenly use someone else's respirator.

Date | Employee Name | Employee Signature