COVID-19 PROTOCOL

Create a Workplace Committee

The Committee will be responsible Consider setting up a hotline so

for COVID-19 issues and their that employees can report they
impact at the workplace. are experiencing symptoms and
receive direction to a company
The Committee is responsible for -designated testing facility.
all communications regarding
COVID-19. The Committee maintains
prepared statement to use with
The Committee will maintain a inquiries regarding COVID-19.
centralized database of COVID-19
action. REMAIN CALM
The Committee will be the contact
point for employees subject to
COVID-19 testing and restrictions.

Perform Routine Environmental Cleaning

Routinely clean all frequently Provide tissues and no-touch

touched surfaces in the workplace, disposal receptacles for use by
such as workstations, countertops, employees.
and doorknobs. Use the cleaning
agents that are usually used in Instruct employees to clean their
these areas and follow the hands often with an alcohol-
directions on the label. based hand sanitizer that contains
at least 60-95% alcohol, or wash
Provide disposable wipes so that their hands with soap and water
commonly used surfaces (for for at least 20 seconds. Soap and
example, doorknobs, keyboards, water should be used preferentially
remote controls, desks) can be if hands are visibly dirty.
wiped down by employees before
each use. Provide soap and water and
alcohol-based hand sanitizer in the
Place posters that encourage workplace. Ensure that adequate
staying home when sick, cough supplies are maintained. Place
and sneeze etiquette, and hand hand rubs in multiple locations or
hygiene at the entrance to your in conference rooms to encourage
workplace and in other workplace hand hygiene.
areas where they are likely to be
seen.

Social Distancing Guidelines

6’
Allow for flexible work polices such Create lunch slots to control the
as telecommuting when allow- number of people.
able.
Limit the number of people
Allow for staggered shifts, if possi- allowed in the elevator at one
ble, to reduce in person interac- time.
tions.
Opt for virtual meetings when
Create seating at least six (6) feet possible.
apart.
Recommend the use of face
Create one way hallways. coverings or masks if social
distancing cannot be maintained.
Close shared spaces such as meeting
rooms and pantries.
 COVID-19 PROTOCOL

Acceptable Medical Inquiries

For any inquiries, there should be Measure an employee’s body temperature in a secure
objective evidence that a specific (not public) area.
employee may pose a risk of contagion.

?
Implement a safe and consistent procedure designed
The inquiry or medical examination to reduce the risk of coronavirus exposure (i.e., with
of an employee must be job-related respect to the individual administering the screening,
and consistent with business necessi- as well as among those being screened).
ty when there is a reasonable belief,
based on objective evidence, that an
Ensure that the screening applies to all those entering
employee poses a direct threat due to
the workplace, not just employees.
a medical condition. According to the
EEOC guidance, the COVID-19
pandemic meets the direct threat Give employees and others prior notice about the
standard. screening and encouraging them to self-monitor for
symptoms and stay away from the workplace if they
Determinations should not be based are experiencing symptoms.
on stereotypes or generalizations
about members of specific racial, Keep any documented results confidential in a file
ethnic, religious or other protected separate from the employee’s personnel file.
groups.
Share the screening results on a purely need-to-know
Acceptable inquiries:
basis as necessary to protect against the threat of
exposure to coronavirus. Do not include the employ-
Ask employees who report feeling ill questions
ee’s name and/or identifying information in any
about their symptoms to determine if they
notification.
have or may have COVID-19.

Accommodations for Employees

The ADA is still applicable. The Evaluate if the accommodation

ADA
District should continue to provide creates an undue hardship during
accommodations under the ADA. this time. Weigh the cost of the
accommodating with budget
Consider all requests for an accom- restrictions.
modation.
Provide modifications to personal
Ask questions or request medical protective equipment (“PPE”)
documentations to see if the requirements if it does not create
accommodation is needed. an undue hardship. This may
include an employee requiring
non-latex gloves or a modified
face mask to facilitate lip reading.

Steps In Response to Physical Symptoms / Diagnosis

Employees who test positive for Take steps to limit the spread of the
the virus are required to notify the respiratory secretions of a person who
committee as soon as possible. may have COVID-19.

Immediately separate employees Isolate people suspected of

who appear to have symptoms having COVID-19 separately
(i.e., fever, cough, or shortness of from those with confirmed cases
breath) upon arrival at work, or of the virus to prevent further
transmission—particularly in
who become sick during the day,
worksites where medical screen-
from other employees, customers, ing, triage, or healthcare activi-
and visitors. ties occur, using either perma-
Identify an area for isolation until poten- nent (e.g., wall/different room)
or temporary barrier (e.g., plastic
tially sick people can be removed from
sheeting).
the worksite.
 COVID-19 PROTOCOL

Steps In Response to Physical Symptoms / Diagnosis (Cont.)

Restrict the number of personnel If an employee is confirmed to have

entering isolation areas. COVID-19 infection, inform fellow
employees of their possible exposure
Protect workers in close contact with to COVID-19 in the workplace but
(i.e., within 6 feet of) a sick person or
maintain confidentiality as required by
who have prolonged/repeated
the Americans with Disabilities Act
contact with such persons by using
additional engineering and adminis- (ADA). The identity of the infected
trative controls, safe work practices, employee must be kept confidential
and PPE. and shared only on a “need to know”
basis.
Before sending an employee home, ask
the employee to re-trace his or her Consider having potentially infected
steps to identify all office areas and co-workers self-quarantine at home for
co-workers with which the employee up to 14 days.
interacted.
The fellow employees should then
Solicit voluntary exclusion. The self-monitor for symptoms (i.e., fever,
employee should be sent home imme- cough, or shortness of breath).
diately and instructed to follow up with
a medical provider. The employee may Consider ADA accommodations if
not return to work until he or she is appropriate to identify interim solu-
symptom-free for at least 14 days tions to enable employees to keep
and/or presents documentation from a working as much as possible.
medical provider indicating the
employee is clear to return to work. Extra measures should be taken to
sanitize any areas of the office that the
If an employee refuses to remain infected employee trafficked.
home, consider involuntary exclusion
based on a determination that an Consider a report to local or state CDC
employee poses a direct threat to the authority.
health or safety of the employee or
others in the workplace.

Discontinuing Home Isolation

The decision to discontinue home

Test-based strategy (simplified from
isolation should be made in the context
initial protocol) A test-based strategy is
of local circumstances. Options include:
contingent on the availability of ample
1) a time-since-illness-onset and time-
testing supplies and laboratory capacity
since-recovery (non-test-based) strate-
as well as convenient access to testing.
gy, and 2) a test-based strategy.
All test results should be final before
isolation is ended.
Fever is considered (100.4° F [37.8° C] or
greater using an oral thermometer)
Persons who have COVID-19 who have
symptoms and were directed to care
Time-since-illness-onset and time-since
for themselves at home may
-recovery strategy (non-test-based-
discontinue home isolation under
strategy)
the following conditions:
Persons with COVID-19 who have
symptoms and were directed to care Resolution of fever without the use of
for themselves at home may discon- fever-reducing medications; and
tinue home isolation under the
following conditions: Improvement in respiratory symp-
toms (e.g., cough, shortness of
At least 3 days (72 hours) have breath); and
passed since recovery defined as
resolution of fever without the Negative results of from at least two
use of fever-reducing medica- consecutive tests of an FDA Emergen-
tions and improvement in respi- cy Use Authorized test for COVID-19
ratory symptoms (e.g., cough, collected ≥24 hours apart (total of
shortness of breath); and, two negative specimens).

At least 7 days have passed since

symptoms first appeared.
 COVID-19 PROTOCOL

Discontinuing Home Isolation (Cont.)

Individuals with laboratory-confirmed Individuals who are exposed and/or

COVID-19 who have not had any have family members who have symp-
symptoms may discontinue home toms of, and/or a positive test for,
isolation when at least 7 days have COVID-19 the recommended length of
quarantine is 14 days. The goal is to
passed since the date of their first
prevent potentially spreading the virus
positive COVID-19 diagnostic test and
by separating yourself from other
have had no subsequent illness. people long enough to determine
whether or not you're infected and
showing symptoms.

Employees Who Refuse to Come to Work – Fear of Coronavirus

An employee who refuses to come to

Reasonable accommodation may
work is subject to discipline if the com-
include excusing an employee from
pany remains open, unless the employ-
work due to a mental or physical
ee is eligible for leave.
impairment associated with an
infectious disease—even if the
Consider whether reasonable accom-
employee has no available paid leave.
modations are needed for an employee’s
physical and/or mental impairment.
Some employees may have physical
conditions that preclude them from
risking exposure to a contagious
disease. Similarly, an employee may
have extreme anxiety or another
mental impairment associated with
fear of exposure to contagions.

Guidance provided by the CDC:

https://www.cdc.gov/coronavirus/2019-ncov/community/guidance-business-response.html
https://www.cdc.gov/coronavirus/2019-ncov/if-you-are-sick/steps-when-sick.html
https://www.cdc.gov/coronavirus/2019-ncov/hcp/disposition-in-home-patients.html

At ARBH, we will continue to monitor the modifications to the stay-at-home order and
will be happy to help with any questions you may have. Please call us at 214-544-4000.