Emergency Response Plans: OSHA Guidance & COVID Preparedness for Open Doors

Healthy Buildings webinar Series

Peterson Cullimore, Alliance Consultants

Healthy Buildings webinar Series

1. Major OSHA Regulations affected by COVID-19

2. Response and Preparedness Planning

3. Industrial Hygiene Thoughts

Agenda

Introductions

Healthy Buildings webinar Series

Moderator: Gillian Giem, Program Managerof USGBC West Michigan

Speaker: Peterson Cullimore, Group Manager, Alliance Consultants

Alliance Consultants Healthy Buildings webinar Series

Services include:1. Facility Support Services

2. Industrial Hygiene

3. Commercial and Residential IAQ Testing

4. EHS Regulatory Compliance

5. Environmental Risk Management and Due

Diligence

6. Sustainability Management

All of Michigan and Northern Indiana

Major OSHA Regulations affected Healthy Buildings webinar Series

General Duty Clause: OSH Act of 1970: 5(a)

Personal Protective Equipment

● 29 CFR 1910.132 General Requirements

● 29 CFR 1910.134 Respiratory Protection

Equipment

GENERAL DUTY CLAUSE Healthy Buildings webinar Series

“Employer shall furnish to each of his

employees employment and a place of

employment which are free from

recognized hazards that are causing or

are likely to cause death or serious

physical harm to his employees”

● Hazard Assessment

● Reasonable steps to address hazard

● Enforcement Priorities

PPE Major Considerations Healthy Buildings webinar Series

Last Resort

● CDC recommends cloth masks for General Public

● OSHA expects High/V.High EL to wear N95

General Requirements

● Cloth Masks are not PPE● Surgical Masks are PPE, but not

Respiratory Protection● Employee supplied or employer

supplied

VOLUNTARY USE Healthy Buildings webinar Series

Filtering Facepiece Respirator: N95 Mask “Dust Mask”

● However, you must:○ Ensure respirator itself does not create a

hazard.○ Provide employee with Appendix D of

1910.134 ("Information for Employees Using Respirators When Not Required Under the Standard").

● No written respiratory protection program needed.

Elastomeric APRs or Powered APRs● Written Respiratory Protection Program:

Limited○ Administrator; Sections on medical

evaluations and Inspection, Care, and Maintenance.

ERP and Preparedness Healthy Buildings webinar Series

1. Goals

2. Pandemic Response Team

3. Exposure Risk Assessment

4. Engineering Controls

5. Administrative and Work Practice Controls

6. Disinfection

7. Training

8. HR Considerations

9. Engagement & Communication

10. Other: Supplier/Partner Considerations

Goals & Pandemic Response Team Healthy Buildings webinar Series

1. Unifying Company Leadership in Goals

2. PRT (PM, PRC, DPRC, PHSL)

○ Access Control Leadership

○ Virus Prevention & Protocols Leadership

○ PPE & Supplies Leadership

○ Job Hazard Leadership

○ Disinfection Leadership

○ Communication and Training Leadership

○ Monitoring and Audit Leadership

○ Supplier and Inventory Leadership

Exposure Risk Assessment Healthy Buildings webinar Series

Very High Exposure Risk: High potential for exposure to known or suspected sources of COVID-19 during specific medical, postmortem, or laboratory procedures.

High Exposure Risk: High potential for exposure to known or suspected sources of COVID-19.

Medium Exposure Risk: Employees frequently less than six (6) feet in distance from other workers, work with public, or travel.

Low Exposure Risk (Caution): Employees that do not require contact with other employees known or suspected to be infected with SARS-CoV-2. Can generally conduct work without being less than six (6) feet in distance from another person.

Determining Exposure Risk1. Assess job roles 2. Controls where reasonable 3. Assign Exposure Risk Category

Engineering Controls Healthy Buildings webinar Series

Administrative Controls Healthy Buildings webinar Series

Top Written Supplements1. Plant Entry/Exit Protocol (Screening)

2. Employee Environmental Disinfection Responsibilities

3. PPE Requirements and Voluntary Use

4. Monitoring and Enforcement

5. Training Matrix

6. Job Exposure Risk Matrix

7. Observed Symptoms Protocols

8. Employees or Employee Cohabitants Testing Positive for

COVID-19

9. Case Report Form

10. Employee and Visitor Travel & Health Declaration Form

11. Quarantine and Safe Return to Work Protocol

Recordability: Positive Case Healthy Buildings webinar Series

COVID-19 is a recordable illness: Respiratory Illness on Form 300

Recordable Illness per 29 CFR Part 1904 IF:1. Confirmed case, as defined by CDC;2. Case is work-related as defined by 29 CFR § 1904.5: ; and3. Case involves one or more of the general recording criteria set forth in 29

CFR § 1904.7 4. Non-exempt industry with >10 employees

Regarding #2 per OSHA Enforcement Memo: Work Related?:Until further notice, OSHA will not enforce 29 CFR § 1904 to require other employers to make the same work-relatedness determinations, except where:

● Objective evidence that a COVID-19 case may be work-related● The evidence was reasonably available to the employer e.g. Screening

Information

Disinfection Healthy Buildings webinar Series

1. Surface Disinfection: EPA Pesticide

N-List: Concentration and Wet

Contact Time!● Sodium Hypochlorite: If diluting, must be fresh

● Electronics and sensitive surfaces:

Alcohol-based

2. Disinfection Plan:● Routine/Responsibility: Disinfection Categories

● Routine/Targeted/Third-Party Protocols

Training Healthy Buildings webinar Series

1. Module-based: General, Disinfection Teams, Leadership Action

2. Nature of Hazard3. Administrative Controls4. Convey OSHA Exposure Class

and Corresponding Requirements

5. Disinfection6. PPE

HR Considerations Healthy Buildings webinar Series

Most contentious: Michigan: >40%

high risk 18+, 18-65 is 20-25%

● Being 65+ years of age;

● Being on immunosuppressive drug

therapy or otherwise being

immunosuppressed;

● Having a history of smoking; or

● Having any of the following medical

conditions: cardiovascular disease,

asthma or other pulmonary disease,

renal failure, liver disease, cancer, or

diabetes.

How would you solicit such info?

Engagement and Communication Healthy Buildings webinar Series

1. Monitoring of pandemic progress and

related news

2. All stakeholders

3. Safe Shift Meetings

4. Continuous Improvement Process

5. Process-based notification protocols

6. Signage

7. Multiple Locations

Supplier/Partner Considerations Healthy Buildings webinar Series

Do your partners have appropriate measures in place?

IH: Aerosol Transmission Healthy Buildings webinar Series

Breathing, Talking, Coughing, Sneezing

● Mount Vernon, Washington, March 10 Choir Practice

○ 60 singers, 3 weeks later, 45 Diagnosed, >3 hospitalized, 2 fatalities

● Fiegel 2006: Superspreaders: Difference in bioaerosol generation

● Asadi 2019:

Kowalski 1998:

IH: Aerosol Transmission Healthy Buildings webinar Series

● SARS-CoV-2 Size: 0.12 μm● Viral load sufficient to cause infection: 1μm

● Morawska 2006: 1 Meter Drop:

○ 1000 µm, 0.3s

○ 100 µm, 3s

○ 10 µm, 300 s

○ 1 µm, 30,000s

● Chen 2010: 0.1-200 µm: ventilation patterns and the initial velocity vs gravity

IH: Aerosolization Healthy Buildings webinar Series

Xie 2007:

1. Normal Breathing: 1 m/sec 2. Talking: 5m/sec3. Coughing: 10 m/sec 4. Sneezing: 20-50 m/sec

Duguid 1946:van Doremalen 2020:

IH: ENVIRONMENTAL PERSISTENCE Healthy Buildings webinar Series

van Doremalen 2020:

• U.S. Department of Labor: Occupational Safety and Health Administration. (2020). Guidance on Preparing Workplaces for COVID-19 (OSHA 3990-). Retrieved from https://www.osha.gov/Publications/OSHA3990.pdf

• Lear Corporation. (2020). Safe Work Playbook (Version 1). Retrieved from https://lear.com/safeworkplaybook• Kowalski, W., & Bahnfleth, W. (1998). Airborne Respiratory Diseases and Mechanical Systems for Control of Microbes. Heating, Piping, and Air

Conditioning, 70, 34–48.• Morawska, L. (2006). Droplet fate in indoor environments, or can we prevent the spread of infection? Indoor Air, 16(5), 335–347.

https://doi.org/10.1111/j.1600-0668.2006.00432.x• Asadi, S., Wexler, A. S., Cappa, C. D., Barreda, S., Bouvier, N. M., & Ristenpart, W. D. (2019). Aerosol emission and superemission during human

speech increase with voice loudness. Scientific Reports, 9(1), 1–10. https://doi.org/10.1038/s41598-019-38808-z• Morgenstern, J. (2020). Aerosols , Droplets , and Airborne Spread : Everything you could possibly want to know. Retrieved from First10EM Blog website:

https://first10em.com/aerosols-droplets-and-airborne-spread/.• Baron, P. (2010). Generation and Behavior of Airborne Particles (Aerosols). In National Institute for Occupational Safety and Health Centers for Disease

Control and Prevention.• Occupational Safety and Health Administration. (2011). Small Entity Compliance Guide for the Respiratory Protection Standard. Retrieved from

http://www.osha.gov/Publications/3384small-entity-for-respiratory-protection-standard-rev.pdf• Centers for Disease Control and Prevention. (2020). Prepare your Small Business and Employees for the Effects of COVID-19. Coronavirus Disease

2019 (COVID-19). Retrieved from https://www.cdc.gov/coronavirus/2019-ncov/community/guidance-small-business.htmlCamfill. (2020). • Camfil addresses the coronavirus pandemic (p. 2). p. 2. Retrieved from https://www.camfil.com/en-us/insights/life-science-and-healthcare/virus • Koma, W., Neuman, T., Claxton, G., Rae, M., Kates, J., & Michaud, J. (2020). How Many Adults Are at Risk of Serious Illness If Infected with

Coronavirus? | The Henry J. Kaiser Family Foundation. (March), 1–6. Retrieved from https://www.kff.org/global-health-policy/issue-brief/how-many-adults-are-at-risk-of-serious-illness-if-infected-with-coronavirus/

• van Doremalen, N., Bushmaker, T., Morris, D., Holbrook, M., Gamble, A., Williamson, B., … Munster, V. (2020). Aerosol and Surface Stability of SARS-CoV-2 as Compared with SARS-CoV-1. The New England Journal of Medicine, Correspond, 0–2. https://doi.org/10.1056/NEJMc2004973

• Chen WQ, Ling WH, Lu CY, et al. Which preventive measures might protect health care workers from SARS?. BMC Public Health. 2009;9:81. Published 2009 Mar 13. doi:10.1186/1471-2458-9-81 PMID: 19284644

• Xie X, Li Y, Chwang AT, Ho PL, Seto WH. How far droplets can move in indoor environments–revisiting the Wells evaporation-falling curve. Indoor Air. 2007;17(3):211–225. doi:10.1111/j.1600-0668.2007.00469.x PMID: 17542834

• Duguid, J. P. (1946). The size and the duration of air-carriage of respiratory droplets and droplet-nuclei. Journal of Hygiene, 44(6), 471–479. https://doi.org/10.1017/S0022172400019288

Healthy Buildings webinar SeriesReferences

Questions?

Healthy Buildings webinar Series

Peterson Cullimore

Alliance Consultants

petersonc@allianceconsultants.us

810-656-1938

The Workplace: A Plan to Prepare, Restore & Thrive

Healthy Buildings webinar Series

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