COVID-19 Exposure Prevention, Preparedness, and Response Plan
Telcom Logistics takes the health and safety of our employees very seriously. With the spread of the Corona virus or “COVID-19,” a respiratory disease caused by the SARS-CoV-2 virus, we all must remain vigilant in mitigating the outbreak. This is particularly true for the construction industry, which has been deemed “essential” in many locations throughout the United States 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 throughout the Company and at all of our job sites. We have also identified a team of employees to monitor available U.S. Center for Disease Control and Prevention (“CDC”) and Occupational Safety and Health Administration (“OSHA”) guidance on the virus.
Responsibilities of Manager and Supervisors
All managers and supervisors must be familiar with this Plan and be ready to answer questions from employees. Managers and supervisors must set a good example by following this Plan at all times. This involves practicing good personal hygiene and job site safety practices to prevent the spread of the virus. Managers and supervisors must encourage this same behavior from all employees.
Responsibilities of Employees
We are asking every one of our employees to help with our prevention efforts while at work. In order to minimize the spread of COVID-19 at our job sites, we all must play our part. As set forth below, the Company has instituted various housekeeping, social distancing, and other best practices at our job sites. 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 HR at (210) 944-8820.
OSHA and the CDC have provided the following control and preventative guidance to 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.
In addition, employees must familiarize themselves with the symptoms of COVID-19:
- Fever of 100.4 degrees Fahrenheit or higher;
- 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 healthcare provider right away. Likewise, if you come into close contact with someone showing these symptoms, call your healthcare provider right away.
Job Site Preventive Measures
The Company has instituted the following protective measures at all job sites.
General Safety Policies and Rules
- Any employee or contractor showing symptoms of COVID-19 will be asked to leave the job site and return home. Telcom Logistics may determine that taking employee and contractors temperatures at worksites is appropriate and restrict access based upon temperature readings. As an alternative to taking temperatures at the worksite, Telcom Logistics may request employees or contractors to take their own temperatures prior to coming to the worksite.
- 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 direct employees or contractors 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 encouraged to stagger breaks and lunches, if practicable, to reduce the size of any group at any one time to less than ten (10) people.
- 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 should limit the use of co-workers’ tools and equipment. To the extent tools must be shared, the Company will provide alcohol-based wipes to clean tools before and after use. When cleaning tools and equipment, consult manufacturing recommendations for proper cleaning techniques and restrictions.
- Employees are encouraged to limit the need for N95 respirator use, by using 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 designate employees into dedicated shifts, at which point, employees will remain with their dedicated shift 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 alteration.
- Employees are encouraged to minimize ride-sharing. While in vehicle, employees must ensure adequate ventilation and consider the use of face coverings.
- If practicable, employees should use/drive the same truck or piece of equipment every shift.
- In lieu of using a common source of drinking water, such as a cooler, employees should use individual water bottles. Use of tobacco products (chewing tobacco, smoking), vaping, sunflower seeds, etc., should be avoided.
Cleaning and Disinfecting
Telcom Logistics has instituted regular housekeeping practices, which includes cleaning and disinfecting frequently used tools and equipment, and other elements of the work environment, where possible. Employees should regularly do the same in their assigned work areas.
- Job site 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 job site must be changed frequently by someone wearing nitrile, latex, or vinyl gloves.
- Telcom Logistics will ensure that hand sanitizer dispensers are always filled. Frequently touched items (i.e., door pulls and toilet seats) will be disinfected frequently.
- Telcom Logistics 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 (these can be used if appropriate for the surface).
- The Company will maintain Safety Data Sheets of all disinfectants used on site.
- The Company will maintain Safety Data Sheets of all disinfectants used on site.
- Technicians scheduled for on-site work are required to fill out the “Telcom Logistics Health Check” survey before arriving to the location. This survey asks about the employee’s overall health status, any potential recent contact with a COVID-19 patient, and requires they record their temperature. If any questions are answered unfavorably, the employee is restricted from performing the work and the job will either be reassigned to another technician or rescheduled.
- Technicians scheduled for on-site work are required to adhere to the same guidelines as outlined in the “In-Office Policy” and the “Employee Responsibility Policy,” while utilizing the appropriate PPE as outlined in the “Personal Protective Equipment (PPE) Policy.”
Employee Exhibiting 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 that reports to work with symptoms to return home until they are symptom free for 72 hour (3 full days). To the extent practical, employees are required to obtain a doctor’s note clearing them to return to work.
Employee Tests Positive for COVID-19
An employee that 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 that 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; and (2) at least seven (7) days have passed since symptoms first appeared. Employees that test positive and have been hospitalized may return to work when directed to do so by their medical care provider. The Company will require an employee to provide documentation clearing their return to work.
Employee Has Close Contact with a Tested Positive COVID-19 Individual
Employees that have come into close contact with a confirmed-positive COVID-19 individual (co-worker or otherwise), will be directed to either: (1) continue to work, provided they remain asymptomatic in accordance with Section III above; or, if they are symptomatic or the Company chooses to follow more conservative protocols, (2) self-quarantine for 14 days from the last date of close contact with the carrier. Close contact is defined as six (6) feet for a prolonged period of time.
If the Company learns that an employee has tested positive, the Company will conduct an investigation into co-workers that may have had close contact with the confirmed-positive employee in the prior 14 days and direct those individuals that have had close contact with the confirmed-positive employee to either continue to work, provided they remain asymptomatic in accordance with Section III above, or, if they are symptomatic or the Company chooses to follow more conservative protocols, to self-quarantine for 14 days from the last date of close contact with the carrier. 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 manager or supervisor of the close contact.
Except for circumstances in which Telcom Logistics 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 of an employee’s condition will be kept at the minimum needed not only to comply with legally-required reporting, but also to assure proper care of the employee and to detect situations where the potential for transmission may increase. A sample notice to employees is attached to this Plan. The Company reserves the right to inform other employees that a co-worker (without disclosing the person’s name) 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.
Given the fast-developing nature of the COVID-19 outbreak, the Company may modify this Plan on a case by case basis. Please note that these are fast-moving times and the information provided is only accurate as of the day posted. The information provided does not, and is not intended to, constitute legal advice; instead, all information is prepared and provided for general informational purposes only. If you have any questions concerning this Plan, please contact the Human Resource Manager at Telcom Logistics.