Star Cooling Towers, LP takes the health and safety of our employees very seriously. With the spread of the coronavirus 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 jobsites. 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.
This Plan is based on currently available information from the CDC and OSHA and is subject to change based on further information provided by the CDC, OSHA, and other public
officials. The Company may also amend this Plan based on operational needs.
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 jobsite safety practices to
prevent the spread of the virus. Managers and supervisors must encourage this same behavior
from all employees.
*For the CDC’s definition of “close contact,” refer to the full definition on pg. 11 of this Plan.
In addition, employees must familiarize themselves with the symptoms of COVID-19:
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.
The CDC has provided guidance for employers regarding safety practices for “critical infrastructure workers” who may have been exposed to a person with a suspected or confirmed case of COVID-19. Construction has been deemed as critical infrastructure by the U.S. Department of Homeland Security’s Cybersecurity and Infrastructure Security Agency (“CISA”) and many state and local jurisdictions have similarly deemed construction as critical infrastructure during the COVID-19 pandemic. Given this, Star Cooling Towers, LP is adopting the following protocol for employees exposed or potentially exposed to a suspected or confirmed case of COVID-19, consistent with CDC recommendations.
If a critical infrastructure employee has been exposed or potentially exposed to a suspected or confirmed case of COVID-19, Star Cooling Towers, LP will permit the employee to continue to work, but will implement the following practices:
Depending upon workforce needs, Star Cooling Towers, LP may choose to keep the exposed or potentially exposed employee away from work for 14 days. See also Section VI below.
The Company has instituted the following protective measures at all jobsites.
A. General Safety Policies and Rules
C. Job Site Visitors
D. Personal Protective Equipment and Work Practice Controls
E. Face Covering
Star Cooling Towers, LP has reviewed OSHA’s workplace classification scheme for worker exposure potential to COVID-19. While construction work could generally be considered
“low risk” for viral transmission, some construction tasks or activities may involve working with others in proximity closer than six feet, including sitting in the same vehicle, and therefore might be considered as “medium risk” under the Agency’s risk pyramid.
Due to this and CDC recommendations, we are implementing a face covering policy for certain work activities for the foreseeable future, including those situations where (1) it is mandated by state or local rule, or (2) employees must work in proximity of six (6) feet from other employees. A face covering is a cloth, bandana, or other type of material that covers a person’s nose and mouth. Five general criteria for “cloth face coverings” are that the face covering should:
For further information, the CDC has issued guidance on how to wear, take off, and wash reusable face coverings.
Use of a face covering is not a substitute for the important workplace preventative technique of maintaining six (6) feet of physical distance from others.
The Company 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.
**NOTE TO EMPLOYERS: The CDC guidance currently recommends that the individual be symptom free for 24 hours. However, this is updated from the CDC’s initial guidance that recommended an individual be symptom free for 72 hours. As such, many state and local jurisdictions are still requiring a full 72 hours of being symptom free before being able to return to work and because these jurisdictions have enforcement authority (whereas the CDC does not), employers should be cognizant of whether they are still subject to the 72 hour time period.
***Recovery is defined as: (1) resolution of fever without the use of fever-reducing medications; and (2) improvement in other symptoms (e.g., cough, shortness of breath).
****NOTE TO EMPLOYERS: The CDC guidance currently recommends that the individual be symptom free for 24 hours. However, this is updated from the CDC’s initial guidance that recommended an individual be symptom free for 72 hours. As such, many state and local jurisdictions are still requiring a full 72 hours of being symptom free before being able to return to work and because these jurisdictions have enforcement authority (whereas the CDC does not), employers should be cognizant of whether they are still subject to the 72 hour time period.
Close contact is defined as being within six (6) feet of a COVID-19 positive individual for a cumulative total of 15 minutes or more over a 24-hour period. For example, three 5-minute exposures with three different COVID-19 positive individuals (or with just one COVID-19 positive individual) in a 24-hour period would be considered close contact.
Factors to consider include proximity (closer distance likely increases exposure risk), the duration of exposure (longer exposure time likely increases exposure risk), whether the infected individual has symptoms (the period around onset of symptoms is associated with the highest levels of viral shedding), if the infected person was likely to generate respiratory aerosols (e.g., was coughing, singing, shouting), and other environmental factors (crowding, adequacy of ventilation, whether exposure was indoors or outdoors). Additionally, because most employees have not been trained on the use of respirators and/or are not wearing respirators, and the efficacy of face coverings varies greatly by type, the use of respirators/face coverings by the infected person or the potentially exposed individual should not be considered in making a determination of “close contact.”
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.
However, if the employee who has had close contact with a tested positive COVID-19 individual previously developed COVID-19 within the previous three months and has recovered and remains without COVID-19 symptoms, the employee does not need to stay home.
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.
When to Record a COVID-19 Case on the OSHA 300 Log
Record the case on your OSHA 300 log if: (1) the case is a tested-positive confirmed case of COVID-19; (2) the case is work-related (see below for more information); and (3) the case involves death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, loss of consciousness, and/or a significant injury or illness diagnosed by a physician or other licensed healthcare professional.
The key to determining if a COVID-19 positive employee’s sickness is recordable is whether the case is work-related. In order to make this determination, at the time the Company learns of a COVID-19 positive employee, the Company must investigate the work-relatedness of the case.
According to OSHA, a reasonable investigation involves:
As noted above, this analysis must be conducted at the time the Company learns that an employee is COVID-19 positive. If, however, the Company later learns of additional evidence related to an employee’s COVID-19 illness, that information should be used to determine the work-relatedness of a case.
OSHA has provided the following scenarios as work-related guideposts.
When to Report a COVID-19 Case to OSHA
If you have determined that an employee with a confirmed case of COVID-19 is work-related, you must report the case to OSHA if it results in a fatality or an in-patient hospitalization of one or more employees.
If the fatality due to COVID-19 occurs after 30 days or more from the workplace incident leading to the illness, you are not required to report it.
If the in-patient hospitalization occurs after 24 hours or more from the workplace incident leading to the illness, you are not required to report it.
Several States and localities are issuing orders that prohibit work and travel, except for essential businesses. In general, construction work has been deemed essential and the
Company is committed to continuing operations safely. If upon your travel to and from the worksite, you are stopped by State or local authorities, you will be provided a letter that you can show the authorities indicating that you are employed in an “essential” industry and are commuting to and from work.
Except for circumstances in which the Company 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 legallyrequired 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. If you have any questions concerning this Plan, please contact our safety manager Brandon Solis.
*****Temperature screening involves numerous, difficult legal issues. This Appendix does not represent a comprehensive discussion of all of those issues. It is intended to provide some basic guidance to contractors who might be performing screening. Contractors should consult with legal counsel before implementing a screening program.
Options for Screening
If the individual conducting the screening is able to stand six feet or more from the employee being screened, no additional protective gear is necessary, though a face mask and gloves are recommended.
Re: Shelter-in-Place Orders
To whom it may concern:
Please be informed that the bearer of this letter is employed at Star Cooling Towers, LP located at 9007 FM 2759 Richmond, Texas 77469. The Company is a cooling tower contractor. We have reviewed all applicable Orders and have determined that our operations qualify as essential/critical infrastructure and that we are able to continue to operate under those Orders.
Employees in possession of this letter have been deemed essential to the minimum basic operations of our business. All non-essential personnel have been notified to work remotely until further notice. Employees who are critical to the minimum basic operations of the business have been instructed to comply with social distancing rules/requirements in the jurisdiction, as well as other safety and health precautions.
If you have questions regarding the nature or scope of this letter, please do not hesitate to contact Brian Robertson at 832-309-0511 or email at email@example.com.
James C. Smith
CEO Star Cooling Towers, LP
TO: [CLOSE CONTACT EMPLOYEE]
FROM: [COMPANY REP]
We have been informed by one of our [employees/customer/vendor/etc] working at [SITE] that he/she has a confirmed case of COVID-19, commonly known as “Coronavirus,” based on test results obtained on [DATE]. Per company policy, this [employee/customer/vendor/etc] has been directed to self-quarantine until permitted to return to work.
We are alerting you to this development because, based on the Company’s investigation, we believe that you may have come into contact with the confirmed-positive case, on or about [DATE]. As a critical infrastructure employee, Star Cooling Towers, LP will permit you to work provided you remain asymptomatic. In addition, we are implementing the following practices:
You are also required to wear a face covering at all times while at the worksite for at least 14 days. Please inform Brandon Solis if any of the following occur to you during the next 14 days: you experience flu-like symptoms, including fever, cough, sneezing, or sore throat; or you test positive for COVID-19.
We also want to take this opportunity to remind you that one of our core values as a company is respect for and among our employees. We will treat information regarding the identity of employees with suspected or confirmed cases of COVID-19 as confidential to the extent practicable and will comply with applicable laws regarding the handling of such information. Further, per Company policy, we will not tolerate harassment of, or discrimination or retaliation against, employees or anyone.
Please contact Brandon Solis Safety Manager 281-236-5169 if you have any questions or concerns.
For more information about COVID-19, please visit the CDC website at:
Know the Symptoms of COVID-19
Cleaning/Disinfecting Job Sites and Other Protective Measures
Personal Protective Equipment and Alternate Work Practice Controls
What is COVID-19?
The novel coronavirus, COVID-19 is one of seven types of known human coronaviruses. COVID-19, like the MERS and SARS coronaviruses, likely evolved from a virus previously found in animals. The remaining known coronaviruses cause a significant percentage of colds in adults and children, and these are not a serious threat for otherwise healthy adults.
Patients with confirmed COVID-19 infection have reportedly had mild to severe respiratory illness with symptoms such as fever, cough, and shortness of breath.
According to the U.S. Department of Health and Human Services/Centers for Disease Control and Prevention (“CDC”), Chinese authorities identified an outbreak caused by a novel—or new—coronavirus. The virus can cause mild to severe respiratory illness. The outbreak began in Wuhan, Hubei Province, China, and has spread to a growing number of other countries— including the United States.
How is COVID-19 Spread?
COVID-19, like other viruses, can spread between people. Infected people can spread COVID-19 through their respiratory secretions, especially when they cough or sneeze. According to the CDC, spread from person-to-person is most likely among close contacts (about 6 feet). Person-to-person spread is thought to occur mainly via respiratory droplets produced when an infected person coughs or sneezes, like how influenza and other respiratory pathogens spread. These droplets can land in the mouths or noses of people who are nearby or possibly be inhaled into the lungs. It is currently unclear if a person can get COVID-19 by touching a surface or object that has the virus on it and then touching their own mouth, nose, or possibly their eyes.
In assessing potential hazards, employers should consider whether their workers may encounter someone infected with COVID-19 in the course of their duties. Employers should also determine if workers could be exposed to environments (e.g., worksites) or materials (e.g., laboratory samples, waste) contaminated with the virus.
Depending on the work setting, employers may also rely on identification of sick individuals who have signs, symptoms, and/or a history of travel to COVID-19-affected areas that indicate potential infection with the virus, in order to help identify exposure risks for workers and implement appropriate control measures.
There is much more to learn about the transmissibility, severity, and other features associated with COVID-19, and investigations are ongoing.
General Job Site / Office Practices