May 14, 2020

COVID-19 Preparedness and Safety Plan

COVID-19 Preparedness and Safety Plan

WHEREAS, on May 1, 2020, Governor Holcomb executed Executive Order 20-26 (“EO 20-26”), which identifies a plan for Indiana to reopen following the multiple COVID-19 related stay-at-home orders.

WHEREAS, pursuant to EO 20-06, each Parish, School, and Agency of the Archdiocese of Indianapolis (“Parish/School/Agency”) is required, as are all Indiana employers, to maintain and implement a Safety Plan. This Safety Plan will largely track with prior safety policies and procedures which the Parish/School/Agency began implementing since the start of the COVID-19 pandemic.

WHEREAS, the Parish/School/Agency takes the health and safety of our employees and parishioners very seriously. With the spread of the coronavirus or “COVID-19,” a respiratory disease caused by the SARS-CoV-2 virus, the Parish/School/Agency must remain vigilant in mitigating the outbreak. In order to be safe and maintain operations, and in compliance with EO 20-26, we have developed this COVID-19 Exposure Prevention, Preparedness, and Response Plan to be implemented, to the extent feasible and appropriate, throughout the Parish/School/Agency. The Parish/School/Agency has also identified the COVID-19 Task Force of the Archdiocese as the 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.

WHEREAS, this Plan is based on information available from the CDC and OSHA at the time of its development and is subject to change based on further information provided by the CDC, OSHA, and other public officials. The Parish/School/Agency may also amend this Plan based on operational needs and as required by subsequent Executive Orders.

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 set a good example by following this Plan at all times. This involves practicing good personal hygiene to prevent the spread of the virus. Managers and supervisors must encourage this same behavior from all employees.

As provided in prior correspondence, the following recommended OSHA and CDC guidance should be followed which includes:

  • If an employee is sick, encourage him or her to stay home. Encourage the employee to follow applicable call-in procedures to report his/her absence to the appropriate supervisor.
  • Encourage employees to frequently wash hands with soap and water for at least 20 seconds. When soap and running water are unavailable, encourage use of an alcohol-based hand rub with at least 60% alcohol.
  • Remind and encourage employees to avoid touching their eyes, nose, mouth, particularly with unwashed hands.
  • Remind and encourage employees to follow appropriate respiratory etiquette, which includes covering the mouth and nose (with tissue, arm, or something other than his/her hands) when coughing or sneezing.
  • Remind and encourage employees to avoid close contact with people who are sick.

Responsibilities of Employees

The Parish/School/Agency is asking every one of our employees to help with our prevention efforts while at work. In order to minimize the spread of COVID-19 in the workplace, everyone must play their part. As set forth below, the Parish/School/Agency has instituted various housekeeping, social distancing, and other best practices. 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 the Archdiocesan Human Resources Office at hr@archindy.org or (317) 236-1594.

OSHA and the CDC have provided the following control and preventative guidance for all workers, regardless of exposure risk:

  • 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.
  • 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, which include the following:

  • Coughing;
  • Fever;
  • 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.

Workplace Protective Measures

The Parish/School/Agency has instituted the following protective measures.

General Safety Policies and Rules

  • Any employee/contractor/visitor showing symptoms of COVID-19 will be asked to leave and return home.
  • During any in-person 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 (co-workers/contractors/visitors) to increase personal space to at least six (6) feet, where possible.
  • All in-person meetings will be limited. To the extent possible, meetings will be conducted by telephone or web-based video calls/conferences.
  • To the extent practical, employees are encouraged to work remotely.
  • 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.
  • Employees are encouraged to minimize ridesharing. While in vehicles, employees must ensure adequate ventilation

Screening

All employees entering the Parish/School/Agency will be subject to a health screening process in accordance with EO 20-26. Screening questions which may be asked include the following:

  1. Are you currently experiencing, or have you in the last 14 days experienced, any symptoms such as fever, cough, shortness of breath or difficulty breathing, chills, repeated shaking with chills, body aches or muscle pain, sore throat, headache, diarrhea, nausea/vomiting, runny nose, and new loss of taste or smell?

Anyone answering “yes” should not be permitted in the workplace. Subject to obtaining

further information from the employee and in accordance with the screening protocols of applicable State and County Public Health Orders, the employee may not return to the workplace until:

  • At least 3 days (72 hours) have passed since symptoms have resolved (without the use of fever-reducing medications) AND
  • At least 10 days have passed since symptoms first appeared. Note: The above criteria do not apply to anyone who, after showing symptoms, receives a negative COVID-19 test.
  1. Have you been in close contact (less than six feet) in the last 14 days with any persons who have been diagnosed COVID-19 or were experiencing any symptoms such as fever, cough, shortness of breath or difficulty breathing, chills, repeated shaking with chills, body aches or muscle pain, sore throat, headache, diarrhea, nausea/vomiting, runny nose, and new loss of taste or smell?

Anyone answering “yes” should not be permitted in the workplace. Subject to obtaining further information from the employee and in accordance with the screening protocols of applicable State and County Public Health Department Orders, the employee may not return to the workplace until:

  • Either 14 days have passed since the last close contact with the sick or symptomatic individual OR
  • The symptomatic individual receives a negative COVID-19 test.
  1. Have you traveled via airplane in the last 14 days?

Anyone answering yes should not be permitted in the workplace until 14 days have passed since the individual returned home from travel or the person receives a negative COVID-19 test.

  1. Have you been advised by a healthcare provider to self-quarantine due to COVID-19?

Anyone answering yes should be asked when they were told to self-quarantine and for how long. The employee may not return to the workplace until they have completed their quarantine as advised.

  1. Have you tested positive for COVID-19?

Anyone answering yes should be asked: (i) when they were swabbed for the test, (ii) how many days it has been since they first experienced symptoms, and (iii) how many days they have been symptom-free?

  • The employee may not return to the workplace until at least 3 days (72 hours) have passed since symptoms have resolved (without the use of fever-reducing medications) AND
  • At least 10 days have passed since the employee was swabbed for the positive COVID-19 test

Cleaning and Disinfecting

  • The Parish/School/Agency has instituted regular housekeeping practices, which include 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.
  • 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. Notwithstanding this, the Parish/School/Agency will clean those areas that a confirmed-positive individual may have contacted, and it will do so before employees can access that workspace again.
  • The Parish 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 Parish will maintain Safety Data Sheets of all disinfectants used on site.

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 Parish 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). 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 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; 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 Parish will require an employee to provide documentation clearing his or her return to work. Recovery as used in this section is defined as (1) resolution of fever without the use of fever-reducing medications and (2) improvement in respiratory symptoms (e.g., cough, shortness of breath) without the use of cough suppressants.

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 for a prolonged period of time.

If the Parish/School/Agency learns that an employee has tested positive, the Parish/School/Agency 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. If applicable, the Parish 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 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 Parish/School/Agency will determine if it meets the criteria for recordability and reportability under OSHA’s recordkeeping rule. For purposes of COVID-19, OSHA also requires employers to report to OSHA any work-related illness that (1) results in a fatality, or (2) results in the in-patient hospitalization of one or more employees. “In-patient” hospitalization is defined as a formal admission to the in-patient unit 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 does not have a confirmed diagnosis, the recordability analysis is not necessarily triggered at that time.

If an employee has a confirmed case of COVID-19, the Parish/School/Agency 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 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 COVID-19 that is considered work-related, the Parish/School/Agency 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.

Confidentiality / Privacy

Except for circumstances in which the Parish/School/Agency is legally required to report workplace occurrences of communicable disease, the confidentiality of all medical conditions will be maintained in accordance with applicable laws 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 Parish/School/Agency 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 Parish/School/Agency 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.

Additional Health and Safety Information

The information in this section is not required by Executive Order 20-26. Employers may choose to include these links in their safety plans so employees know where to search for additional relevant information.

Employees can find helpful resources and guidance related to COVID-19 at the U.S. Centers for Disease Control and Prevention (“CDC”) and Indiana State Department of Health (“ISDH”) websites. Information about how COVID-19 spreads can be found here.

The CDC has issued a detailed Reopening Guidance for Cleaning and Disinfecting Workplaces, with information about how to effectively disinfect various surfaces. The CDC also has published FAQs about COVID-19 covering a wide range of topics and has issued guidance for making and wearing cloth face coverings.

Indiana Governor Eric Holcomb’s Executive Orders are available online, as well as his Roadmap to Safely Reopen Indiana, which includes descriptions of each of the five stages of the reopening plan.

The EEOC has issued Technical Assistance Questions and Answers that include employee screening questions.

General Questions

Given the fast-developing nature of the COVID-19 outbreak, the Parish/School/Agency may modify this Plan on a case by case basis. If you have any questions concerning this Plan, please contact the Archdiocesan Human Resources Office at hr@archindy.org.

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