This CPP is designed to control exposures to the SARS-CoV-2 virus that may occur in our workplace.
Date: February 10, 2021
Authority and Responsibility
Laura Troendle, Vice President for Finance, Administration and Treasurer has overall authority and responsibility for implementing the provisions of this CPP in our workplace. In addition, all managers and supervisors are responsible for implementing and maintaining the CPP in their assigned work areas and for ensuring employees receive answers to questions about the program in a language they understand.
All employees are responsible for using safe work practices, following all directives, policies and procedures, and assisting in maintaining a safe work environment.
The goal of Pitzer College is to ensure that we have effective two-way communication with our employees, in a form they can readily understand, and that it includes the following information:
- Who employees should report COVID-19 symptoms and possible hazards to, and how.
- Supervisor via call or email.
- Pitzer’s HHB Nurse (909 607-2180; email@example.com)
- Employees can report symptoms and hazards without fear of reprisal.
- Employees with medical or other conditions that put them at increased risk of severe COVID-19 illness should report it to their Supervisor or HR for reasonable accommodations.
- Where testing is not required, how employees can access COVID-19 testing.
- Employee(s) who had contact with someone who has tested positive for COVID-19 or Employees who have COVID-19 symptoms must complete COVID-19 testing through one of the following resources:
- Primary Care/Medical Provider
- State Testing Sites (Appointment required)
- In the event we are required to provide testing because of a workplace exposure or outbreak, we will communicate the plan for providing testing and inform affected employees of the reason for the testing and the possible consequences of a positive test.
- If we are required to provide testing because of an employee exposure, we have a plan for how this will be accomplished at no cost to the employee during working hours, including when the testing is in response to 8 CCR section 3205.1, Multiple COVID-19 Infections and COVID-19 Outbreaks, as well as section 3205.2, Major COVID-19 Outbreaks.
- We will utilize Hamilton Health Box as a first option or we will utilize the county program as directed by Supervisor Solis: with Fulgent Diagnostics, designated test centers.
- Information about COVID-19 hazards employees (including other employers and individuals in contact with our workplace) may be exposed to, what is being done to control those hazards, and our COVID-19 policies and procedures.
- COVID-19 related communication will be in the form of:
- Email communication from HR or other Pitzer administrative offices
- Email communication from Hamilton Health Box
- Formal training via virtual meetings and video training modules
- Supervisor communication when returning staff to the workplace
- COVID-19 information posted on Pitzer’s website
Identification and Evaluation of COVID-19 Hazards
CalOSHA defines a “COVID-19 hazard” as exposure to potentially infectious material that may contain SARS-CoV-2, the virus that causes COVID-19. Potentially infectious materials include airborne droplets, small particle aerosols, and airborne droplet nuclei, which most commonly result from a person or persons exhaling, talking or vocalizing, coughing, sneezing, or procedures performed on persons which may aerosolize saliva or respiratory tract fluids, among other things. This also includes objects or surfaces that may be contaminated with SARS-CoV-2.
Pitzer will implement the following in the workplace:
- Conduct workplace-specific evaluations using the Appendix A: Identification of COVID-19 Hazards form.
- Evaluate employees’ potential workplace exposures to all persons at, or who may enter our workplace. See Appendix A for potential workplace exposures.
- Review applicable orders and general and industry-specific guidance from the State of California, Cal/OSHA, and the local health department related to COVID-19 hazards and prevention.
- Evaluate existing COVID-19 prevention controls in our workplace and the need for different or additional controls.
- Conduct periodic inspections as needed to identify unhealthy conditions, work practices, and work procedures related to COVID-19 and to ensure compliance with our COVID-19 policies and procedures.
All staff and faculty are encouraged to participate in the identification and evaluation of COVID-19 hazards. Staff and faculty should contact their Pitzer’s Human Resources office, their supervisor (staff) or the Dean of Faculty’s office (faculty) if they learn of a COVID-19 Hazard on campus.
Pitzer screens employees in the following manor:
- Employees who have been instructed to return to the workplace must conduct symptom monitoring every day before reporting to work. They must be free of ANY symptoms potentially related to COVID-19.
- If the Employee has any symptoms, the employee must notify their Supervisor and Pitzer’s HHB nurse (909 607-2180; firstname.lastname@example.org) or, if using the Healthy Pitzer app, a notification will be sent to Pitzer’s on-site nurse who will follow up with instructions.
- The Employee should wear a face covering to avoid possible virus transmission to others.
- The HR department will contact the Employee shortly after reporting symptoms.
- The Employee should self-isolate until cleared by the HR department to return to work.
Correction of COVID-19 Hazards
Unsafe or unhealthy work conditions, practices or procedures will be documented and corrected in a timely manner based on the severity of the hazards, as follows:
- Low Exposure Risk: within 48 hours
- Medium Exposure Risk: within 24 hours
- High or Very High Exposure Risk: within 8 hours or as soon as possible
Responsibility for correction and follow-up will be assigned according to the location and nature of the identified hazard.
Control of COVID-19 Hazards
Pitzer primarily ensures physical distancing by minimizing the number of employees and visitors on campus. Only those employees who are engaged in essential, in-person functions are allowed to work on campus.
Additional measures to facilitate physical distancing include:
- On campus workers are instructed to maintain six feet of separation if at all possible.
- Visual cues such as signs are placed throughout the campus indicate where employees and others should be located or their direction and path of travel.
- In several different offices Pitzer has implemented staggered arrival, departure, work, and break times.
- Staff are no longer required to enter their timecards in-person in order to minimize gatherings around a time clock.
- Individuals are kept as far apart as possible when there are situations where six feet of physical distancing cannot be achieved.
- Supervisor approval is required for campus visitors, including vendors.
Pitzer ensures that face coverings are properly worn by employees over the nose and mouth when indoors, and when outdoors and less than six feet away from another person, including non-employees, and where required by orders from the California Department of Public Health (CDPH) or local health department. Employees may bring their own face coverings or call the Facilities department (909 607-2226) if they need a face covering and one will be provided. Employees are responsible for cleaning of their face coverings daily after use.
The following are exceptions to the use of face coverings in our workplace:
- When an employee is alone in a room.
- While eating and drinking at the workplace, provided employees are at least six feet apart and outside air supply to the area, if indoors, has been maximized to the extent possible.
- Employees who cannot wear face coverings due to a medical or mental health condition or disability, or who are hearing-impaired or communicating with a hearing-impaired person. Alternatives will be considered on a case-by-case basis.
Any employee not wearing a face covering, face shield with a drape or other effective alternative, or respiratory protection, for any reason, shall be at least six feet apart from all other persons unless the unmasked employee is tested at least twice weekly for COVID-19.
- We implement the following measures for situations where we cannot maintain at least six feet between individuals:
- Prior to use, the McConnell Dining Hall will have partitions between the Kitchen staff and serving line staff.
- In campus wide reception and open office areas, partitions will be provided if social distancing cannot be maintained.
- We maximize, to the extent feasible, the quantity of outside air for our buildings with mechanical or natural ventilation systems by:
- Ion generators have been installed campus wide in any buildings without access to outside air via sliding doors or windows
- Air filters have been increased to MERV 10, the maximum possible without compromising the mechanical system
- Outside air exchange has been increased to meet or exceed building code requirements to the extent possible without compromising the mechanical system
Cleaning and Disinfecting Protocols
- Enhanced daily cleaning and disinfecting of public/common spaces such as restrooms, lounges, lobbies, and hallways, including high touch areas and objects, such as light switches, railings and door handles (see below re: process for cleaning and disinfecting protocol)
- Hand sanitizer stations are located at key areas within campus buildings
- Cleaning and disinfecting supplies and PPE are ordered in overage to ensure availability at all times
- All hand towels and soap dispensers are touchless, sinks faucets are automatic, toilets are auto-flush
- Facilities personnel continue to receive COVID-19 safety training, COVID OSHA training, and disinfecting / sanitizing cleaning training
- Facilities staff are informed of any protocol updates and schedule regarding cleaning and disinfection via daily meetings with managers and crew, additionally, a depart wide meeting is held semi-monthly
- Should a COVID outbreak occur, a consultant response team skilled in cleaning and disinfection procedures are on-call for rapid response
- We implement the following cleaning and disinfecting protocol:
- Clean surfaces and objects that are visibly soiled
- Surfaces dirty to sight or touch are cleaned using a detergent, or soap and water prior to disinfection
- An EPA-registered disinfectant is used, which is approved for use against COVID-19. Refer to the American Chemistry Council list of products preapproved for use against emerging enveloped viral pathogens, or the EPA list of registered disinfectants approved for use against SARS-CoV-2 (COVID-19)
- Manufacturer’s instructions are followed for safe and effective use of all cleaning and disinfection products (e.g., dilution concentration, application method and contact time, required ventilation, and use of personal protective equipment)
- Disinfectant concentrations and contact time are critical for effective disinfection of surfaces and manufacturer instructions are followed accordingly
Shared tools, equipment and personal protective equipment (PPE)
- Disinfecting wipes are provided to all office staff upon their request for use on individual tools and equipment, and computer keyboards and peripherals such as printers and copies
- Sharing of vehicles will be minimized to the extent feasible, and high-touch points (for example, steering wheel, door handles, seatbelt buckles, armrests, shifter, etc.) will be disinfected between users.
- PPE will not be shared.
In order to implement effective hand sanitizing procedures, employees:
- are provided time to wash their hands often with soap and water for at least 20 seconds especially after they have been in a public place, or after blowing their nose, coughing, sneezing, or touching their face.
- Additionally, non-methanol hand sanitizer stations are provided in high traffic lobby areas.
Personal protective equipment (PPE) used to control employees’ exposure to COVID-19
We evaluate the need for PPE (such as gloves, goggles, and face shields) as required by CCR Title 8, section 3380, and provide such PPE as needed.
When it comes to respiratory protection, we evaluate the need in accordance with CCR Title 8 section 5144 when the physical distancing requirements are not feasible or maintained.
Although we currently have no staff who work in circumstances where eye protection or respiratory protection are required, we continue to monitor these circumstances and will provide and ensure use of eye protection and respiratory protection in accordance with section 5144 when employees are exposed to procedures that may aerosolize potentially infectious material such as saliva or respiratory tract fluids.
Investigating and Responding to COVID-19 Cases
This will be accomplished by using the Appendix C: Investigating COVID-19 Cases form.
Employees who had potential COVID-19 exposure in our workplace who work on campus are instructed to notify Pitzer’s HHB nurse (909 607-2180; email@example.com) if they experience COVID-19 symptoms, test positive, or are diagnosed with COVID-19, or if a member of their household fits and of these criteria.
In these cases, employees are instructed to stay home from work. Pitzer then works with the employee’s health care provider and/or third-party providers contracted by Pitzer to provide the employee with appropriate quarantine and isolation instructions, as well as a return to work plan at the appropriate time.
No-cost testing options are available through health care providers or public health testing sites. Pitzer will also soon have testing available on-campus through its Hamilton Health Box Clinic (more information regarding this option will be shared as soon as it is available).
Training and Instruction
We will provide effective training and instruction that includes:
- Our COVID-19 policies and procedures to protect employees from COVID-19 hazards.
- Information regarding COVID-19-related benefits to which the employee may be entitled under applicable federal, state, or local laws.
- The fact that:
- COVID-19 is an infectious disease that can be spread through the air.
- COVID-19 may be transmitted when a person touches a contaminated object and then touches their eyes, nose, or mouth.
- An infectious person may have no symptoms.
- Methods of physical distancing of at least six feet and the importance of combining physical distancing with the wearing of face coverings.
- The fact that particles containing the virus can travel more than six feet, especially indoors, so physical distancing must be combined with other controls, including face coverings and hand hygiene, to be effective.
- The importance of frequent handwashing with soap and water for at least 20 seconds and using hand sanitizer when employees do not have immediate access to a sink or handwashing facility, and that hand sanitizer does not work if the hands are soiled.
- Proper use of face coverings and the fact that face coverings are not respiratory protective equipment – face coverings are intended to primarily protect other individuals from the wearer of the face covering.
- COVID-19 symptoms, and the importance of obtaining a COVID-19 test and not coming to work if the employee has COVID-19 symptoms.
- All employees who work on campus have participated in virtual training sessions provided by CalOSHA staff or will be required to watch the following training video produced by CalOSHA: https://trainingacademy.dir.ca.gov/covid-19-training-for-california-workers-1
Exclusion of COVID-19 Cases
Where we have a COVID-19 case in our workplace, we will limit transmission by:
- Ensuring that COVID-19 cases are excluded from the workplace until our return-to-work requirements are met.
- Excluding employees with COVID-19 exposure from the workplace for 14 days after the last known COVID-19 exposure to a COVID-19 case.
- Continuing and maintaining an employee’s earnings, seniority, and all other employee rights and benefits whenever we’ve demonstrated that the COVID-19 exposure is work related. This will be accomplished by:
- Providing employee sick leave benefits
- Utilize accrued paid sick time
- Workers’ Compensation Leave (if work related transmission or work-related close contact)
- Providing employees at the time of exclusion with information on available benefits.
Reporting, Recordkeeping, and Access
It is Pitzer’s policy to:
- Report information about COVID-19 cases at our workplace to the local health department whenever required by law, and provide any related information requested by the local health department.
- Through TCCS Worker’s Compensation Administrator, report immediately to Cal/OSHA any COVID-19-related serious illnesses or death, as defined under CCR Title 8 section 330(h), of an employee occurring in our place of employment or in connection with any employment.
- Maintain records of the steps taken to implement our written COVID-19 Prevention Program in accordance with CCR Title 8 section 3203(b).
- Make our written COVID-19 Prevention Program available at the workplace to employees, authorized employee representatives, and to representatives of Cal/OSHA immediately upon request.
- Use the Appendix C: Investigating COVID-19 Cases form to keep a record of and track all COVID-19 cases. The information will be made available to employees, authorized employee representatives, or as otherwise required by law, with personal identifying information removed.
COVID-19 Prevention in Employer-Provided Housing
Assignment of housing units
We will ensure that shared housing unit assignments are prioritized in the following order:
- Residents who usually maintain a household together outside of work, such as family members, will be housed in the same housing unit without other persons.
- Residents who work in the same crew or work together at the same worksite will be housed in the same housing unit without other persons.
- Employees who do not usually maintain a common household, work crew, or worksite will be housed in the same housing unit only when no other housing alternatives are possible.
Note that the provisions that follow (physical distancing and controls, face coverings, cleaning and disinfecting, screening, and isolation of COVID-19 cases and persons with COVID-19 exposure) do not apply to occupants, such as family members, who maintained a household together prior to residing in employer-provided housing, but only when no other persons outside the household are present.
Physical distancing and controls
We will ensure:
- The premises are of sufficient size and layout to permit at least six feet of physical distancing between non-family residents in housing units, common areas, and other areas of the premises.
- Beds are spaced at least six feet apart in all directions and positioned to maximize the distance between sleepers’ heads. For beds positioned next to each other, i.e., side by side, the beds will be arranged so that the head of one bed is next to the foot of the next bed. For beds positioned across from each other, i.e., end to end, the beds will be arranged so that the foot of one bed is closest to the foot of the next bed. Bunk beds will not be used.
- Maximization of the quantity and supply of outdoor air and increase filtration efficiency to the highest level compatible with the existing ventilation system in housing units.
We will provide face coverings to all residents and provide information to residents on when they should be used in accordance with state or local health officer orders or guidance.
We will encourage residents to report COVID-19 symptoms to Pitzer’s Human Resources department
We will establish, implement, and maintain effective policies and procedures for COVID-19 testing of occupants who had a COVID-19 exposure, who have COVID-19 symptoms, or as recommended by the local health department.
Isolation of COVID-19 cases and persons with COVID-19 exposure
- Effectively isolate COVID-19 exposed residents from all other occupants. Effective isolation will include providing COVID-19 exposed residents with a private bathroom, sleeping area, and cooking and eating facility.
- Effectively isolate COVID-19 cases from all occupants who are not COVID-19 cases. Effective isolation will include housing COVID-19 cases only with other COVID-19 cases, and providing COVID-19 case occupants with a sleeping area, bathroom, and cooking and eating facility that is not shared by non-COVID-19-case occupants.
- Keep confidential any personal identifying information regarding COVID-19 cases and persons with COVID-19 symptoms, in accordance with our CPP Investigating and Responding to COVID-19 Cases.
- End isolation in accordance with our CPP Exclusion of COVID-19 Cases and Return to Work Criteria, and any applicable local or state health officer orders.