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Injury Illness Prevention Plan

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PURPOSE
The Injury Illness Prevention Plan (“Plan” or “IIPP”) sets forth procedures that will assist management
in maintaining a safe and healthy work environment for all Allied Universal employees.

SCOPE
This Plan outlines the elements of Allied Universal’s safety and health Plan. These elements include
management and employee responsibilities, Plan compliance, internal communications, hazard
assessment and correction, incident investigation, safety training and record keeping.

APPLICATION
This Plan applies to all Allied Universal offices and personnel. The requirements of this Plan are
based on the Federal OSHA General Duty Clause; 29 CFR 1910, and 8 CCR 3203.

Allied Universal Safety Policy

It is the policy of Allied Universal and its subsidiaries to work continually toward improving our safety
expectations, process and procedures with the goal of evolving our safety culture.

It is Allied Universal’s intent to provide a safe working environment in all areas, for all employees.
Accidents and injuries are prevented by proactively controlling and maintaining the work environment
and the actions of employees. Therefore, safety will take precedence in all areas of our business
operations practices through the evaluation, planning and execution of injury prevention measures at
all client sites. Every attempt will be made to reduce the possibility of accident occurrence.
Protection of employees, the public, and company property and operations is paramount. We
consider no phase of our operations more important than the health and safety of our employees.

Safe work and safe driving practices on the part of the employees must be part of all operations at our
client sites. Employees must understand their personal responsibility for the prevention of injuries and
be held accountable for working in a safe manner. Management teams shall embrace safety as a
core value and do everything in their power to prevent injuries. Accident prevention and efficient
service go hand in hand. Allied Universal maintains that all workplace injuries can and should be
prevented. Allied Universal’s IIPP sets the expectations for safety across all AU service lines.
Management and our Service Line operations teams will continue to be guided and motivated by this
policy and, with the cooperation of all employees, will actively pursue a safer working environment.

(Chief Safety/Risk Officer): ________________________

Date: . 10/25/2021 .

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RESPONSIBILITIES
The IIPP administrator will be the Vice President of Risk Management, who has the authority and
responsibility for implementing the provisions of this Plan for Allied Universal. Local branch
management will have the overall responsibility for implementing and maintaining this Plan at their
respective site or location. All managers and supervisors are responsible for implementing the IIPP in
their work areas and for answering employee questions about the IIPP. A copy of this IIPP shall be
made available for review by all Allied Universal employees.

INFECTIOUS DISEASE / PANDEMIC THREAT PROVSION


This Injury Illness Prevention Plan (IIPP) is applicable to all operations and functions conducted by
Allied Universal personnel and management. The Plan outlines Allied Universal’s commitment to
implement policies and procedures to prevent all potential employee injuries and illnesses. This
commitment includes concerns resulting from infectious disease and pandemic threats such as the
COVID-19 virus and similar concerns.

Management of pandemic threat concerns is controlled by the Allied Universal Corporate Pandemic
Response Plan, which includes the requirement that each branch office and job site complete a Site
Specific Pandemic Action Plan. This site specific plan has been structured to provide field operations
the format to identify local procedures to ensure the safety and protection of Allied Universal
employees during the time of a pandemic threat. Local branch and site leadership is responsible for
developing policies and procedures to ensure compliance with Federal, State and local executive
orders and requirements as well as recommendations from the CDC, OSHA and other regulatory
agencies and public health professionals.

Site Specific Pandemic Action Plans are required to include sections relating to:
• Hazard Assessment - identify hazards associated with pandemic threat within the work
environment, including identification of potential hazards
• Prevention Measures and Controls – identify and adopt prevention measures and controls to
mitigate the identified hazards, including steps such as establishing schedules and procedures
for cleaning of office and workspace environments, and access to handwashing facilities and
cleaning and disinfecting supplies
• Instances of Actual or Possible Infection – Reporting Policies and Procedures for Suspected
and Confirmed Cases
• Employee Schedules and Leave – Establish employee schedules, leave and compensation
criteria in compliance with Federal State and Local requirements
• Employee Training Requirements – designation of Allied Universal training modules as well as
any client-required material. Training content includes reference to recommendations from
CDC and other public health entities regarding best practices for employee safety and
awareness

NOTE: All jobsites and operations within the State of California will develop and maintain Site
Specific Pandemic Action Plans in compliance with recommendations established by California
Department of Labor Relations: Cal/OSHA Interim General Guidelines on Protecting Workers from
COVID-19.

Employees at each site should be trained on best practices, including the Prevention Measures and
Controls and the Reporting Policies and Procedures for Suspected and Confirmed Cases as identified
in the Site Action Plans.

Additional guidance is regularly provided by the Pandemic Crisis Management Team which closely
monitors developments and the latest guidance from authorities.
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Injury Illness Prevention Plan
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Specific Infection Prevention Measures
In addition to the foregoing, it is Allied Universal’s policy that:

• Sick employees should stay home.


• Employees should immediately be sent home or to medical care, as needed, if they have a
frequent cough, fever, difficulty breathing, chills, muscle pain, headache, sore throat, or recent
loss of taste or smell.
• Employees who are out ill with fever or acute respiratory symptoms should not return to work
until both of the following occur:
o At least three full days pass with no fever (without the use of fever-reducing
medications) and no acute respiratory illness symptoms; and
o At least 10 days pass since the symptoms first appeared.
• Employees who return to work following an illness should promptly report any recurrence of
symptoms.
• Employees should discuss with their supervisors whether it is possible for them to work from
home.
• Employees should practice physical distancing by cancelling in-person meetings, using video
or telephonic meetings, and maintaining a distance of at least 6 feet between persons at the
workplace when possible.
• Employees should use company-provided cloth face covers whenever employees may be in
workplaces with other persons.
• Employees should avoid shared workspaces (desks, offices, and cubicles) and work items
(phones, computers, other work tools, and equipment) when possible.
o If they must be shared, employees should clean and disinfect shared workspaces and
work items before and after use.
• As appropriate and identified in the Site Action Plan, employees should routinely clean and
disinfect commonly touched objects and surfaces such as elevator buttons, handrails, copy
machines, faucets, and doorknobs. Surfaces should be cleaned with soap and water prior to
disinfection. These procedures should include:
o Using disinfectants that are EPA-approved for use against the virus that causes
COVID-19.
o Providing EPA-registered disposable wipes for employees to wipe down commonly
used surfaces before use.
o Following the manufacturer’s instructions for all cleaning and disinfection products
(e.g., safety requirements, PPE, concentration, contact time).
o Ensuring there are adequate supplies to support cleaning and disinfection practices.
• If an employee is confirmed to have COVID-19 infection:
o Other employees should be informed of their possible exposure to COVID-19 in the
workplace but confidentiality should be maintained as required by the Americans with
Disabilities Act (ADA).
o The general area where the infected employee worked should be closed until cleaning
is completed.

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o There should be a deep cleaning of the entire general area where the infected
employee worked and may have been, including breakrooms, restrooms and travel
areas, with a cleaning agent approved for use by the EPA against coronavirus. It
should ideally be performed by a professional cleaning service.
 Any person cleaning the area should be equipped with the proper PPE for
COVID-19 disinfection (disposable gown, gloves, eye protection, mask, or
respirator if required) in addition to PPE required for cleaning products. See
below for further information on PPE.
• Employees should avoid non-essential travel if possible and check CDC’s Traveler’s Health
Notices prior to travel.
For employees working in industries such as retail sales or service industries, to protect those
employees with frequent contact with the public, work should be arranged and measures should be
implemented that account for the possibility that the public is a possible contamination source,
including:

• Employees should conduct even more frequent cleaning and disinfection of surfaces touched
by the public such as credit card machines, touch screens, shopping carts and doors.
• Employees who have frequent interaction with the public should be provided with engineering
controls such as Plexiglas screens or other physical barriers, or spatial barriers of at least six
feet, if feasible.
• If exposures to the general public cannot be eliminated with engineering controls, such
persons should be required or encouraged to wear face coverings, which are mandatory in
some jurisdictions.
• Work should be scheduled to allow frequent hand washing by employees handling items
(cash, credit cards, merchandise, etc.) touched by members of the public.
• Physical distancing should be enforced by limiting the numbers of members of the public in
common space.
• Customers should be asked to take precautions such as only touching items they intend to
purchase, and provided with hand sanitizer stations.
• Workers handling items touched by the public should be provided with PPE (i.e., disposable
gloves).

Employee Training
Training should be provided in a language that is readily understandable by all employees on the
following topics:

• General description of COVID-19, symptoms, when to seek medical attention, how to prevent
its spread, and the employer’s procedures for preventing its spread at the workplace.
• How an infected person can spread COVID-19 to others even if they are not sick.
• How to prevent the spread of COVID-19 by using cloth face covers, including:
o CDC guidelines that everyone should use cloth face covers when around other
persons.
o How cloth face covers can help protect persons around the user when combined with
physical distancing and frequent hand washing.

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o Information that cloth face covers are not protective equipment and do not protect the
person wearing a cloth face cover from COVID-19.
o Instructions on washing and sanitizing hands before and after using face coverings,
which should be washed after each shift.
• Cough and sneeze etiquette.
• Washing hands with soap and water for at least 20 seconds, after interacting with other
persons and after contacting shared surfaces or objects. As noted above, Executive Order N-
51-20 requires that employees working in food facilities (as defined by the California Retail
Food Code) must be permitted to wash their hands every 30 minutes and additionally, as
needed.
• Avoiding touching eyes, nose, and mouth with unwashed hands.
• Avoiding sharing personal items with co-workers (i.e., dishes, cups, utensils, towels.
• Providing tissues, no-touch disposal trash cans and hand sanitizer for use by employees.
• Safely using cleaners and disinfectants, which includes:
o The hazards of the cleaners and disinfectants used at the worksite.
o Wearing PPE (such as gloves).
o Ensuring cleaners and disinfectants are used in a manner that does not endanger
employees.

MANAGEMENT
Local management is responsible for implementing Allied Universal safety policies at their locations.
Following are key responsibilities for effective management of the safety Plan:

• Assess the work environment and work tasks, using the Job Safety Analysis process, to make
the job safe through removing hazards, developing safe work practices, and/or using
protective equipment.
• Motivation, education and training of supervisory personnel on company safety policies and
Plans, and indoctrination of a safety philosophy in each site.
• Maintain open communications in regard to safety with all supervisory personnel / employees.
• Provide full support to supervisors in implementing corporate safety Plans at the site level.
• Analyze injury trends and provide direction on injury prevention.
• Periodically audit safety Plans and inspect facilities to maintain compliance with corporate
mandates.
• Recognize and reward, where appropriate, individual employee safety performance.
• Coordinate activities of loss control consultants to maximize efforts in hazard evaluation and
control.
• Review all new posts and equipment for compliance with applicable federal, state and local
codes prior to placing an employee in the area.
• Formulate, install and administer effective accident prevention Plans, techniques and
procedures.
• Coordinate local participation in company-wide accident prevention Plans and analyze
effectiveness

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Injury Illness Prevention Plan
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SUPERVISORS
The site supervisor is the employees’ direct link to management and it is important that they display to
the employee enthusiasm and pride in the safety Plan. The primary safety goal of the supervisor is to
lead the workplace accident prevention effort. The unique closeness to the line employee requires
that the supervisor do the following safety-related tasks:

• Develop a Job Safety Analyses for each post (see Job Safety Analysis manual tab) and
instruct employees in safe work practices.
• Enforce safety rules, regulations and requirements.
• Implement safety Plans and procedures to meet the needs of the workplace.
• Actively participate in and direct the planning of accident prevention Plans.
• Demonstrate support of the safety Plan through personal participation.
• Recognize and reward where appropriate individual employee safety performance.
• Initiate and conduct incident investigations.
• Conduct safety training as needed and detailed throughout the safety manual.
• Identify and correct unsafe acts and conditions through Supervisor and Employee Safety
Observations.
• Arrange for first aid and medical treatment when necessary.
• Report safety-related items that cannot be readily dealt with to the proper management
authority.

EMPLOYEES
Employees have responsibilities that relate to the safe operation of the workplace and should be
aware of them at all times. These responsibilities include:

• Perform job duties in a manner which enhances their personal safety and health as well as the
safety and health of others.
• Follow all established safe work practices related to their job.
• Become familiar with company safety and health rules and regulations and adhere strictly to
them.
• Immediately discontinue work and alert supervisors in the event they discover an unsafe work
practice or situation.
• Immediately report all injuries, illnesses, and near misses to their supervisor.
• Properly use all personal protective equipment issued to them and immediately report any
complications which may hinder the effectiveness of the equipment to their supervisor.

COMPLIANCE
Management is responsible to clearly communicate all safety and health policies and procedures to all
employees. Managers and supervisors are expected to enforce the rules fairly and uniformly.
Employees are responsible for following safe work practices, all directives, policies, procedures and
for assisting in maintaining a safe work environment. The Allied Universal system of compliance with
these practices includes the following:

• Informing employees of the provisions of our Injury and Illness Prevention Plan.
• Evaluating the safety performance of all workers.
• Recognizing employees who perform their job duties using safe work practices.
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Injury Illness Prevention Plan
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• Providing additional training to workers whose safety performance is deficient.
• Disciplining workers for failure to comply with safe work practices and established safety
regulations.

COMMUNICATION
Allied Universal recognizes that open, two-way communication between management and employees
on safety and health related issues is essential to foster a safe and productive workplace. The
following system of communication is designed to facilitate a continuous flow of safety and health
information between management and staff in a form that is readily understandable. This will be
accomplished through:

• New worker orientation including a review of task-specific Job Safety Analysis and discussion
of safety and health policies and procedures.
• Periodic review of the IIPP.
• Workplace safety and health training Plans.
• Regularly scheduled safety meetings.
• Effective communication of safety and health concerns between workers and supervisors.
• Requests for and responses to all safety improvement suggestions/requests by employees to
management.
• Posted or distributed safety information.
• A workplace hazard reporting Plan.

Appendix 2.1 to this policy is a resource available to Supervisors and Managers to communicate the
elements of the Injury & Illness Prevention Plan to employees. This summary can be utilized as a
bulletin board posting, read file document, or handout to employees.

Employees with safety concerns can communicate with their site supervisor/manager, local Human
Resource representative or send safety questions/concerns to safety@aus.com. If further support is
needed employees can also call Allied Universal Employees First at 1-800-461-4330 in the United
States, or at +1-720-514-4400 outside of the United States, or make an anonymous report online at
http://employeesfirst.aus.com if at any time when they:

• Do not feel comfortable contacting the designated supervisor;


• Do not feel your concern was appropriately addressed;
• Do not have the contact information for the appropriate person;
• Have not received a response to your concern within 10 business days.

Employees can make this call 24 hours a day, 7 days a week anonymously; however, providing a
name will allow a more direct and personal response. The sole purpose of the Hotline is to get the
concern to the appropriate person so that the issue can promptly be resolved.

Nothing in this manual prohibits employees from reporting possible violations of federal, state or local
law or regulation to any government agency or entity and any agency inspector general, or making
other disclosures that are protected under the whistleblower provisions of federal, state or local law or
regulation. While Employees are encouraged to bring any such possible violation to the attention of
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Allied Universal. Employees do not need the prior authorization of Allied Universal to make any such
reports or disclosures to these entities.

HAZARD ASSESSMENT
Upon initial start-up of a site/account the Job Safety Analysis process will be completed by the site
manager to identify and mitigate conditions which could pose a hazard to employees. Managers are
encouraged to include supervisors and/or security professionals in this process. In addition,
inspections will occur in the following instances:

• When new substances, procedures, or equipment which present new hazards are introduced.
• When previously unrecognized hazards are discovered.
• Following an injury event.

Additionally, a Job Safety Analysis will be completed for each post upon initial start-up and at least
annually thereafter. Refer to the Job Safety Analysis tab of the safety manual for further information.

HAZARD CORRECTION
When hazards are identified in the workplace the manager is responsible to take action or coordinate
efforts with the client to eliminate, reduce, guard, or restrict employee access to the hazard to protect
employees from injury. Actions taken to eliminate, reduce, or guard hazards will be taken in
compliance with post orders and contract specifications.

When the hazard is a danger to employees, all but those necessary to abate the hazard shall be
removed beyond the limits of exposure to the hazard. Those who are selected to abate the hazard
shall be equipped with the proper safety equipment and training before performing such work tasks.
All corrective actions taken and the dates of those actions shall be properly documented and retained
on file.

INCIDENT INVESTIGATIONS
Learning from past incidents, and applying corrective actions, is an important part of the Allied
Universal IIPP. Investigations will be completed as described in the Incident Reporting and Response
tab of this manual. Types of incidents to be investigated and documented include:

• Incidents involving work-related injuries and/or illnesses


• Automobile accidents
• Near miss events

TRAINING AND INSTRUCTION


All employees, including managers and supervisors, shall have training and instruction on general as
well as job specific safety and health related procedures and policies. This training and instruction
shall be provided to employees in the following situations:

• When the IIPP is first established.


• When newly hired.
• When reassigned to a post or task for which they have not received prior formal training.
• Whenever new substances, procedures or equipment are introduced that present a hazard
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which is new to the post or job task.
• Whenever the employer is made aware of a new or previously unrecognized hazard.
• To all supervisors to familiarize them with the hazards under which their employees work.
• To all workers with respect to specific hazards of their job task.
• To employees who are observed performing an unsafe act or who are injured during the
commitment of an unsafe act.

RECOGNITION AND DISCIPLINARY POLICY


Recognition:
Allied Universal employees are recognized for working safely, following safety rules, and identifying
safety hazards. Each site will establish a system for recognizing employees who perform their jobs in
a safe manner and follow established safe work practices and safety regulations. All employees are
encouraged to submit ideas that could make work processes in the company safer. Local
management reviews each idea submitted to ensure that the idea is practical and will actually reduce
hazards.

Discipline:
Employees will be disciplined for noncompliance or disregard of safety regulations or safe work
practices up to and including termination.

RECORDKEEPING
Allied Universal has taken steps to document certain aspects of its Injury and Illness Prevention Plan.
Items that must be documented include:

1. All employee safety training is documented using WinTeam. Training areas that are
documented include:
• New employee orientation, including on-the-job training
• Required topic-specific safety training of affected employees
• Monthly supervisor safety talks
• JSA Acknowledgement
2. All inspection records and training documents shall be kept current and on file for no less than
five years.
3. Employee medical records are retained and available to employees, as detailed in Tab 17 –
Access to Medical and Exposure Records.
4. All employee injuries/illnesses are documented via an electronic system, as detailed in
Tab 18 – OSHA Recordkeeping.

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Injury Illness Prevention Plan
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INJURY AND ILLNESS PREVENTION PLAN - APPENDIX 2.1

This is a summary of the Plan; complete Plan is located in your post orders.

Policy Statement – It is the policy of Allied Universal to provide safe and healthful working conditions
for all employees and to establish and implement safety procedures and regulations to maintain safe
working conditions.

Compliance – Management and employees are responsible for following safe work practices.
Training will be provided to all employees and additional training will be provided where safety
performance is deficient. Employees will be disciplined for failure to follow established safe work
practices and safety regulations.

Communication – Management is responsible for communicating with all employees about


occupational safety and health issues. Security professionals are expected and encouraged to inform
their supervisors about workplace hazards without fear of reprisal. Communication will be conducted
through periodic meetings, postings, distributed materials, and informal discussions.

Hazard Assessment – Inspections to identify and evaluate workplace hazards shall be performed at
least monthly. Site specific self-inspection checklists should be developed.

Accident/Exposure Investigation – Procedures for investigating workplace incidents and accidents


have been established. All investigations shall be reviewed and evaluated to prevent future incidents.

Hazard Correction – Unsafe or unhealthy work conditions, practices or procedures shall be corrected
in a timely manner based on the severity of the hazards. If serious hazards cannot be corrected when
observed or discovered, workers will be removed from the area until the hazard can be corrected.

Training and Instruction – All employees, including managers and supervisors, shall receive training
and instruction on general and job-specific safety and health practices. Employees training will
include instruction about how to report safety hazards, incidents and suggestions.

Recognition – Management is responsible to hold employees accountable for their performance.


This includes a balance of recognizing safe behavior and suggestions for safety improvements.

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APPENDIX 2.2 - COVID-19 PREVENTION PROGRAM (CPP)
CALIFORNIA LOCATIONS
Introduction
The California OSHA COVID-19 Non-Emergency Regulation (NER) is in effect until February 3, 2025.

This CPP is designed to control Allied Universal (“AUS”) employees’ exposures to the SARS-CoV-2
virus (COVID-19) that may occur in our workplace.
*Note: Many of these COVID-19 precautions and procedures were originally contained within
the company’s IIPP but are now also referenced in this appendix as part of Allied Universal’s
COVID-19 Prevention Program (“CPP”) – California Locations. This appendix will be updated
as needed pursuant to Cal/OSHA, CDPH, and/or CDC guidelines.

The COVID-19 Prevention regulations apply to all Allied Universal places of employment and
employees with the following exceptions:
• Work locations where there is only one employee who does not have contact with other people
(brief interactions with other people counts as contact).
• Employees who are working from home.
• Employees who are covered by the Aerosol Transmissible Diseases regulation (Cal. Code
Regs., tit. 8, § 5199) (section 5199).
• Employees working from a location chosen by the employee that is not under the control of the
employer (for instance, an employee teleworking from a café or a friend's home).

Authority and Responsibility


The Account/Client Manager has overall authority and responsibility for implementing the provisions
of this CPP at their respective site or location. In addition, all local branch management are
responsible for implementing and maintaining the CPP in their assigned work posts and for ensuring
employees receive answers to questions about the program in a language they understand.
Refer also AUS’s Site Specific Pandemic Action Plan for any additional site specific COVID
precautions and emergency contact information.

All employees are responsible for using safe work practices, following all directives, policies, and
procedures, and assisting in maintaining a safe work environment.

Identification and Evaluation of COVID-19 Hazards


The following elements shall be implemented in each workplace:
• Site Specific Pandemic Action Plan
• Conduct workplace-specific evaluations using the Job Safety Analysis form (see IIPP).
• Ensure daily COVID-19 screening is performed
• Evaluate employees’ potential workplace exposures to all persons at, or who may enter, our
workplace.
• 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.
o See “Instructions for Compliance with Cal/OSHA’s Requirements in the Event of
a Workplace COVID-19 Exposure, Outbreak, or Major Outbreak” for details on
actions after a close contact exposure has occurred.
o See also “Detailed Steps for a Suspected Case, Employee Exposure, or
Confirmed Case of Coronavirus (COVID-19), or for Precautionary Self-
Quarantine”
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• Evaluate existing COVID-19 prevention controls in our workplace and the need for
different oradditional controls.
• Conduct periodic COVID-19 safety inspections on a frequency determined by Account
Management in a checklist format to identify and evaluate unhealthy conditions, work
practices, and work procedures related to COVID-19 and to ensure compliance with our
COVID-19 policies and procedures as outlined in the Site-Specific Pandemic Action Plan and
JSA.
Employee participation
Employees and their authorized employees’ representatives are encouraged to participate in the
identification and evaluation of COVID-19 hazards by providing feedback via site
supervisor/manager, local Human Resource representative or send safety questions/concerns to
safety@aus.com.

Employee screening
Allied Universal will screen employees and respond to those with COVID-19 symptoms by having
all employees complete Daily Health Self-Assessments when they arrive at work. Employees self-
screen for symptoms associated with SARS-CoV-2 virus. In addition, we require employees to
stay home if they are sick or are experiencing symptoms with associated with SARS-CoV-2. All
positive COVID-19 cases shall be reported to COVID19@aus.com.

Correction of COVID-19 Hazards


Unsafe or unhealthy work conditions, practices or procedures are documented on the JSA, and
corrected in a timely manner based on the severity of the hazards. Locations will identify possible
hazards and remediate them in a timely manner. They will notate the completion of the tasks in a
checklist format.

Control of COVID-19 Hazards


Training and Instruction
Training and instruction on COVID-19 prevention is provided:
A. When this CPP was first established.
B. To new employees.
C. To employees given a new job assignment involving COVID-19 hazards and they have not
been previously trained.
D. Whenever new COVID-19 hazards are introduced.
E. When we are made aware of new or previously unrecognized COVID-19 hazards.
F. For supervisors to familiarize themselves with the COVID-19 hazards to which employees
under their immediate direction and control may be exposed.
Allied Universal provides effective employee training and instruction that includes:
• Our COVID-19 policies and procedures to protect employees from COVID-19 hazards,
and how to participate in the identification and evaluation of COVID-19 hazards.
• The fact that:
o COVID-19 is an infectious disease that can be spread through the air.
o COVID-19 may be transmitted when a person touches a contaminated object
and then touches their eyes, nose, or mouth.
o An infectious person may have no symptoms.
o Particles containing the virus can travel more than six feet, especially indoors, so
physical distancing combined with other controls, including face coverings decrease the
spread of COVID-19 and are most effective when used in combination.
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• Methods of physical distancing of at least six feet and the importance of combining physical
distancing with the wearing of face coverings.
• The right of employees to request a respirator for voluntary use, without fear of retaliation,
and our policies for providing the respirators. Employees voluntarily using respirators will be
trained on:
o How to properly wear them.
o How to perform a seal check according to the manufacturer’s instructions each time
a respirator isworn, and the fact that facial hair can interfere with a seal.
• The importance of frequent hand washing with soap and water for at least 20 seconds and
using handsanitizer when employees do not have immediate access to a sink or hand
washing 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. Since COVID-19 is an airborne disease, N95s and more protective respirators
protect the users from airborne disease, while face coverings primarily protect people
around the user.
o The conditions where face coverings musts be worn at the workplace.
o Employees can request face coverings and can wear them at work regardless of
vaccination statusand without fear of retaliation.
• COVID-19 symptoms, and the importance of obtaining a COVID-19 test and how to access
testing and vaccination, and the fact that vaccination is effective at preventing COVID-19
and protecting against both transmission and serious illness or death, and not coming to
work if the employee has COVID-19 symptoms.
• Information regarding COVID-19-related benefits to which the employee may be entitled
under applicable federal, state, or local laws. This includes any benefits available under
legally mandated sick and vaccination leave, if applicable, workers’ compensation law, any
local requirements (if applicable), and any applicable Allied Universal leave policies.

Face Coverings
Allied Universal will provide face coverings and ensure they are worn by employees when the
California Department of Health or local health department requires their use.
• When a CDPH regulation or order requires face coverings indoors, that includes spaces within
vehicles. Face coverings shall be clean, undamaged, and worn over the nose and mouth.

Allied Universal instructs its employees on how to safely put on, remove and clean or replace face
coverings.

Note: Allied Universal Management shall review and continue to monitor CDPH
Guidance for the Use of Face Masks to learn when employees must wear face
coverings.

Face covering: means a surgical mask, a medical procedure mask, a respirator worn voluntarily, or
a tightly woven fabric or non-woven material of at least two layers that completely covers the nose
and mouth and is secured to the head with ties, ear loops, or elastic bands that go behind the head. If
gaiters are worn, they shall have two layers of fabric or be folded to make two layers. A face covering
is a solid piece of material without slits, visible holes, or punctures, and must fit snugly over the nose,

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mouth, and chin with no large gaps on the outside of the face. A face covering does not include a
scarf, ski mask, balaclava, bandana, turtleneck, collar, or single layer of fabric.

This definition includes clear face coverings or cloth face coverings with a clear plastic panel that
otherwise meet this definition and which may be used to facilitate communication with people who
are deaf or hard-of-hearing or others who need to see a speaker’s mouth or facial expressions to
understand speech or sign language respectively.

The following exceptions apply:


A. When an employee is alone in a room or vehicle.
B. While eating or drinking at the workplace, provided employees are at least six feet apart and, if
indoors, the supply of outside or filtered air has been maximized to the extent feasible.
C. While employees are wearing respirators required by the employer and used in compliance
with section 5144 Respiratory Protection.
D. 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. Such
employees shall wear an effective non-restrictive alternative, such as a face shield with a
drape on the bottom, if the condition or disability permits it.
E. During specific tasks which cannot feasibly be performed with a face covering. This exception
is limited to the time period in which such tasks are actually being performed.

If an employee is not wearing a face covering pursuant to the exceptions D. and E., above Allied
Universal shall assess COVID-19 hazards and take action as necessary.

Employees will not be prevented from wearing a face covering, including a respirator, when not
required by this section, unless it creates a safety hazard.

Face coverings – Outbreaks


Employees in the exposed group, regardless of vaccination status, shall wear face coverings when
indoors, or when outdoors and less than six feet from another person, unless one of the exceptions
applies.

Note:
• Allied Universal Employees still have the right to wear face coverings at work and to request
respirators from the employer when working indoors and during outbreaks.
• Allied Universal will not prevent any employee from wearing a face covering when it is not
required unless it would create a safety hazard, such as interfering with the safe operation of
equipment. Face coverings will also be provided to any employee that requests one,
regardless of their vaccination status, without fear of retaliation.

Respirators: Upon request, Allied Universal shall provide respirators for voluntary use to all
employees who are working indoors or in vehicles with more than one person.
• Whenever Allied Universal makes respirators for voluntary use available, Allied Universal
shall:
o Encourage their use
o Employees are provided with a respirator of the correct size
o Employees are trained on:
 How to properly wear the respirator provided.
 How to perform a user seal check according to the manufacturer’s instructions
each time a respirator is worn.
 The fact that facial hair interferes with a seal.
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Respirators – Outbreaks
Allied Universal shall notify employees of their right to request and receive a respirator for voluntary
use as outlined in the CPP.

Personal protective equipment (PPE) used to control employees’ exposure to COVID-19


Allied Universal will evaluate the need for PPE (such as gloves, goggles, and face shields) as
required by section 3380,and provide and ensure use of such PPE as needed.
Upon request, Allied Universal will provide respirators for voluntary use to all employees regardless of
their vaccination status and who are working indoors or in vehicles with more than one person.
Employees that request respirators for voluntary use are encouraged to use them in compliance with
T8CCR, section 5144. Respiratory Protection, Appendix D: Voluntary Respirator Use. Allied Universal
will provide and ensure use of respirators in compliance with section 5144 when deemed necessary by
Cal/OSHA.
Additionally, employees must follow the steps outlined below to correctly handle and wear a
respirator:
1. Wash your hands with soap
2. Inspect the respirator for damage
3. Put on the respirator by cupping it in your hands with the nosepiece at your fingertips and the
straps hanging below your hand
4. Adjust the respirator by placing both hands over the respirator — inhale quickly and then
exhale
5. Readjust the nosepiece if there is leakage from the nose; if leakage from the respirator
edges, readjust the straps; repeat until you get a proper sea. If unable to get a proper seal,
try another respirator - the presence of facial hair will interfere with the seal.
6. Wear the respirator
7. Remove the respirator from behind and do not touch the front – the front of the respirator
may contain contaminants

Hand sanitizing
To implement effective hand sanitizing procedures, Allied Universal shall:
• Encourage employees to wash/sanitize hands every 30 minutes and between each transaction
and/or customer interaction
• Train employees to wash their hands often with soap and water for at least 20 seconds and/or use
hand sanitizer with at least 60% alcohol, which is provided by Allied Universal and clients.
• Provide employees with time for handwashing

Cleaning and Disinfecting


Implement the following cleaning and disinfecting measures for frequently touched surfaces:
• All facilities have increased the frequency of regular cleaning cycles and documented procedures
to support these requirements. High-traffic areas and commonly touched surfaces are cleaned
and disinfected regularly. Hand sanitizer and disinfectant spray/wipes are located throughout each
facility for employee and customer/visitor use.
• Should Allied Universal have a COVID-19 case in our workplace, we will implement the following
procedures:
o Clean areas and material where a COVID-19 case has been during the "high risk exposure

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period," and disinfect if indoors and used by another employee within 24 hours.
o Tools, equipment, and personal protective equipment (PPE) PPE must not be shared, e.g.,
gloves, goggles, and face shields.
o Items that employees come in regular physical contact with, such as phones, headsets,
desks, keyboards, writing materials, instruments and tools must not be shared, to the
extent feasible. Where there must be sharing, the items will be disinfected between uses
by Allied Universal Employees using EPA approved cleaning supplies as identified in the
EPA List N: Disinfectants for Coronavirus (COVID-19)
o High use areas will be identified in the Site-Specific Pandemic Action Plan, including
recommended cleaning procedures and frequency.

Engineering controls - Ventilation


Allied Universal will partner with client representatives and facilities management to develop,
implement, and maintain effective methods to prevent transmission of COVID-19, including one or
more of the following actions to improve ventilation:
• Maximize, to the extent feasible, the quantity of outside air for our buildings with mechanical or
natural ventilation systems, except when the United States Environmental Protection Agency
(EPA) Air Quality Index is greater than 100 for any pollutant or if opening windows or
maximizing outdoor air by other means would cause a hazard to employees, for instance from
excessive heat or cold.
• In buildings and structures with mechanical ventilation, filter circulated air through filters at
least as protective as Minimum Efficiency Reporting Value (MERV)-13, or the highest level of
filtration efficiency compatible with the existing mechanical ventilation system.
• Use High Efficiency Particulate Air (HEPA) filtration units in accordance with manufacturers’
recommendations in indoor areas occupied by employees for extended periods, where
ventilation is inadequate to reduce the risk of COVID-19 transmission.
• In vehicles, Allied Universal employees shall maximize the supply of outside air to the extent
feasible, except when doing so would cause a hazard to employees or expose them to
inclement weather
• Determine if our workplace is subject to CCR, Title 8 section 5142 Mechanically Driven
Heating, Ventilating and Air Conditioning (HVAC) Systems to Provide Minimum Building
Ventilation, or section 5143 General Requirements of Mechanical Ventilation Systems, and
comply as required.
Note: Allied Universal Management shall review and monitor the California Department of
Health and Cal/OSHA guidance regarding ventilation, including CDPH and Cal/OSHA
Interim Guidance for Ventilation, Filtration, and Air Quality in Indoor Environments.

Ventilation – Outbreaks
Buildings or structures with mechanical ventilation will have recirculated air filtered with Minimum
Efficiency Reporting Value (MERV)-13 or higher efficiency filters, if compatible with the ventilation
system. If MERV-13 or higher filters are not compatible with the ventilation system, filters with the
highest compatible filtering efficiency will be used. High Efficiency Particulate Air (HEPA) air
filtration units will be used in accordance with manufacturers’ recommendations in indoor areas
occupied by employees for extended periods, where ventilation is inadequate to reduce the risk of
COVID-19 transmission.

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These ventilation requirements will continue to be implemented after the outbreak has passed and
CCR, Title 8 section 3205.1 is no longer applicable.

Investigating and Responding to COVID-19 Cases


Allied Universal will investigate and respond to all potential COVID-19 cases. This includes
procedures for seeking information from employees regarding COVID-19 cases and close contacts,
COVID-19 test results, and onset of COVID-19 symptoms, and identifying and recording COVID-19
cases.

Exclusion of COVID-19 Cases and Employees who had a Close Contact


Where we have a COVID-19 case or close contact in our workplace, we limit transmission by:
• Ensuring that COVID-19 cases are excluded from the workplace until our return-to-work
requirements are met.
• Excluding employees that had close contact from the workplace until our return-to-work
criteria havebeen met, with the following exceptions:
• See “Detailed Steps for a Suspected Case, Employee Exposure, or
Confirmed Case of Coronavirus (COVID-19), or for Precautionary Self-
Quarantine”
• See “Instructions for Compliance with Cal/OSHA’s Requirements in the
Event of a Workplace COVID-19 Exposure, Outbreak, or Major Outbreak”

Allied Universal will also take the following actions when there has been a COVID-19 case at
the place of employment:
1. Determine the day and time the COVID-19 case was last present and, to the extent
possible, the date of the positive COVID-19 test(s) and/or diagnosis, and the date the
COVID-19 case first had one or more COVID-19 symptoms, if any were experienced.

2. Determine who may have had a close contact. This requires an evaluation of the activities
of the COVID-19 case and all locations at the workplace which may have been visited by
the COVID-19 case during the high-risk exposure period.

3. Employees who had a close contact in the workplace will be:


• Offered COVID-19 testing at no cost during their working hours
• Provided information on benefits, including leave of absence, temporary-suspension-of
operations pay, supplemental leave, paid sick leave and access to support, such as
our Employee Assistance Program
• Excluded from the workplace as necessary pursuant to CDPH guidelines or longer if
required by local rules. (See Exclusion of COVID cases and Close Contacts section,
see also “Instructions for Compliance with Cal/OSHA’s Requirements in the
Event of a Workplace COVID-19 Exposure, Outbreak, or Major Outbreak.”

“Close contact” means the following, unless otherwise defined by regulation or order of the
California Department of Public Health (CDPH), in which case the CDPH definition shall apply:
A. In indoor spaces of 400,000 or fewer cubic feet per floor, a close contact is defined
as sharing the same indoor airspace as a COVID-19 case for a cumulative total of
15 minutes or more over a 24-hour period during the COVID-19 case’s infectious
period, as defined by this section, regardless of the use of face coverings.
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B. In indoor spaces of greater than 400,000 cubic feet per floor, a close contact is
defined as being within six feet of the COVID-19 case for a cumulative total of 15
minutes or more over a 24-hour period during the COVID-19 case’s infectious
period, as defined by this section, regardless of the use of face coverings.
Spaces that are separated by floor-to-ceiling walls (e.g., offices, suites, rooms, waiting areas,
bathrooms, or break or eating areas that are separated by floor-to-ceiling walls) must be
considered distinct indoor airspaces.
EXCEPTION: Employees have not had a close contact if they wore a respirator required by
the employer and used in compliance with section

“Worksite” means the building, store, facility, agricultural field, or other location where a COVID-19
case was present during the infectious period. It does not apply to buildings, floors, or other locations
of the employer that a COVID-19 case did not enter.

“Infectious period” means the following time period, unless otherwise defined by CDPH regulation
or order, in which case the CDPH definition shall apply:
A. For COVID-19 cases who develop COVID-19 symptoms, from two days before the
date of symptom onset until:
1. Ten days have passed after symptoms first appeared, or through day
five if testing negative on day five or later; and
2. Twenty-four hours have passed with no fever, without the use of fever-
reducing medications, and symptoms have improved.
B. For COVID-19 cases who never develop COVID-19 symptoms, from two days before
the positive specimen collection date through 10 days (or through day five if testing
negative on day five or later) after the date on which the specimen for their first positive
test for COVID-19 was collected.

“Exposed group” means all employees at a work location, working area, or a common area at
work, within employer-provided transportation covered by section 3205.3, or residing within
housing covered by section 3205.2, where an employee COVID-19 case was present at any time
during the infectious period. A common area at work includes bathrooms, walkways, hallways,
aisles, break or eating areas, and waiting areas. The following exceptions apply:
A. For the purpose of determining the exposed group, a place where persons momentarily
pass through, without congregating, is not a work location, working area, or a common
area at work.
B. If the COVID-19 case was part of a distinct group of employees who are not present at
the workplace at the same time as other employees, for instance a work crew or shift
that does not overlap with another work crew or shift, only employees within that
distinct group are part of the exposed group.
C. If the COVID-19 case visited a work location, working area, or a common area at work
for less than 15 minutes during the infectious period, and the COVID-19 case was
wearing a face covering during the entire visit, other people at the work location,
working area, or common area are not part of the exposed group.

NOTE: An exposed group may include the employees of more than one employer. See
Labor Code sections 6303 and 6304.1

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“Returned case” means a COVID-19 case who was excluded from work and did not develop any
COVID-19 symptoms after returning. A person shall only be considered a returned case for 30 days
after the initial onset of COVID-19 symptoms or, if the person never developed COVID-19 symptoms,
for 30 days after the first positive test. If a period of other than 30 days is required by a CDPH
regulation or order, that period shall apply.

Notice of COVID-19 cases


Allied Universal Management shall notify employees and independent contractors who had a close
contact, as well as any employer with an employee who had a close contact. Notice shall be provided
as soon as possible, and in no case longer than the time required to ensure that the exclusion
requirements are met.
• Allied Universal Management shall provide notice of a COVID-19 case, in a form readily
understandable to employees. Notice shall be given to all employees, employers, and
independent contractors at the worksite in accordance with the applicable law.
• If Allied Universal Management should reasonably know that an employee has not received
the notice or has limited literacy in the language used in the notice, AUS shall provide verbal
notice, as soon as practicable, in a language understandable by the employee.
• Allied Universal Management shall provide notice in accordance with the applicable law to the
authorized representative, if any, of:
a. The COVID-19 case and of any employee who had a close contact.
b. All employees on the premises at the same worksite as the COVID-19 case within the
infectious period.

Return-to-Work Criteria
If an order to isolate, quarantine, or exclude an employee is issued by a local or state health official,
the employee shall not return to work until the period of isolation or quarantine is completed or the
order is lifted

Note: Allied Universal shall review current CDPH guidance for persons who had close
contacts, including any guidance regarding quarantine or other measures to reduce
transmission.

Allied Universal shall immediately exclude from the workplace all COVID-19 cases and
employees excluded until Allied Universal can demonstrate it has met the applicable
requirements below:

1. COVID-19 cases who do not develop COVID-19 symptoms shall not return to work during the
infectious period;
a. These requirements apply regardless of whether an employee has previously been
excluded or other precautions were taken in response to an employee’s close contact
or membership in an exposed group.

2. COVID-19 cases who develop COVID-19 symptoms shall not return to work during the shorter
of the following: the infectious period; or through 10 days after the onset of symptoms and at
least 24 hours have passed since a fever of 100.4 degrees Fahrenheit or higher has resolved
without the use of fever-reducing medication

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3. Regardless of vaccination status, previous infection, or lack of COVID-19 symptoms, a
COVID-19 case shall wear a face covering in the workplace until 10 days have passed since
the date that COVID-19 symptoms began or, if the person did not have COVID-19 symptoms,
from the date of their first positive COVID-19 test.

4. The requirements in bullet 1. And 2. apply regardless of whether an employee has previously
been excluded or other precautions were taken in response to an employee’s close contact or
membership in an exposed group.

5. If an order to isolate, quarantine, or exclude an employee is issued by a local or state health


official, the employee shall not return to work until the period of isolation or quarantine is
completed or the order is lifted.

To meet the return-to-work criteria, a COVID-19 test may be both self-administered and self-read only
if another means of independent verification of the results can be provided (e.g., a time-stamped
photograph of the results).

Upon excluding an employee from the workplace based on COVID-19 or a close contact, Allied
Universal shall give the employee information regarding COVID-19-related benefits to which the
employee may be entitled under applicable federal, state, or local laws. This includes any benefits
available under legally mandated sick leave, if applicable, workers' compensation law, local
governmental requirements, the employer's own leave policies, and leave guaranteed by contract.

Testing Requirements

“COVID-19 test” means a test for SARS-CoV-2 that is:


A. Cleared, approved, or authorized, including in an Emergency Use Authorization (EUA), by the
United States Food and Drug Administration (FDA) to detect current infection with the SARS-
CoV-2 virus (e.g., a viral test); and
B. Administered in accordance with the authorized instructions.
C. To meet the return-to-work criteria, a COVID-19 test may be both self-administered and self-
read only if another means of independent verification of the results can be provided (e.g., a
time-stamped photograph of the results).

Testing of close contacts


Allied Universal shall make COVID-19 tests available at no cost, during paid time, to all employees
who had a close contact in the workplace, with the exception of returned cases and provide them with
the information on respective benefits.

Outbreaks - Testing
1. Allied Universal shall make COVID-19 testing available at no cost to its employees within the
exposed group, regardless of vaccination status, during employees’ paid time, except for
returned cases and employees who were not present at the workplace during the relevant 14-
day period(s)).

2. Allied Universal shall then make testing available on a weekly basis to all employees in the
exposed group who remain at the workplace.

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3. Employees who had close contacts shall have a negative COVID-19 test taken within three to
five days after the close contact or shall be excluded and follow the return-to-work
requirements starting from the date of the last known close contact.

Major Outbreaks – Testing


1. In addition to the Outbreak Testing requirements outlined above, COVID-19 testing shall be
required of all employees in the exposed group, regardless of vaccination status, twice a
week or more frequently if recommended by the local health department with jurisdiction over
the workplace. Employees in the exposed group shall be tested or shall be excluded and
follow the return-to-work requirements outlined in this policy

COVID-19 Prevention in Employer-Provided Transportation


If there is Allied Universal-provided motor vehicle transportation to and from work, during the course
and scope of employment, which is provided, arranged for, or secured by Allied Universal regardless
of the travel distance or duration involved. The requirements of our CPP will be complied with within a
vehicle, including how a COVID-19 case will be responded to.

Assignment of transportation
To the extent feasible:
• Transportation will be assigned such that cohorts travel and work together, separate
from other workers.
• Employees who usually maintain a household together shall travel together.

System for Communicating


Allied Universal’s goal is to ensure effective two-way communication with employees, in a form they
can readily understand, and that it includes the following information:
• The Allied Universal Employee Safety Orientation requires employees be trained on how to
report COVID-19 symptoms and possible hazards. This training includes information on how
employees who are experiencing symptoms or have tested positive can contact their
management to self-report.
• That employees can report symptoms and hazards without fear of reprisal
• Our procedures or policies for accommodating employees with medical or other conditions that
put them at increased risk of severe COVID-19 illness.
o Employees may discuss their increased risks and engage in a workplace
accommodation interactive process with their management and the HR team. In
addition, and where applicable, employees may apply for leave of absence.
• In the event Allied Universal is required to provide testing because of a workplace exposure or
outbreak, Allied Universal will communicate how affected employees can obtain testing free of
charge and will inform affected employees of the reason for the testing and the procedures for
a positive test result.
• Upon excluding an employee from the workplace based on COVID-19 or a close contact,
Allied Universal shall give the employee information regarding COVID-19-related benefits to
which the employee may be entitled under applicable federal, state, or local laws. This
includes any benefits available under legally mandated sick leave, if applicable, workers'
compensation law, local governmental requirements, the employer's own leave policies, and
leave guaranteed by contract.
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• Information about COVID-19 hazards that employees may be exposed to, what is being done
to control those hazards, and our COVID-19 policies and procedures.

Reporting, Recordkeeping, and Access


It is our policy to:
• Keep a record of and track all COVID-19 cases with the employee's name, contact
information, occupation, location where the employee worked, the date of the last day at
the workplace, and the date of the positive COVID-19 test and/or COVID-19 diagnosis.
These records shall be retained for two years beyond the period in which the record is
necessary to meet the requirements of this section or sections 3205.1 through 3205.3.
• 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.
• Report immediately to Cal/OSHA any major outbreaks (20 or more employee COVID-
19 cases in an exposed group, visited the worksite during their infectious period
within a 30-day period)
• 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.

Additional Resources
All Allied Universal COVID-19 documents can be located on the COVID-19 SharePoint Portal.
1. CA COVID-19 Exposure Notice to Employee
2. CA COVID-19 Exposure Notice to Union
3. Step-by-Step Instructions for Compliance with Cal OSHA COVID-19 Requirements
4. COVID-19 - Steps for Suspected or Confirmed Cases
5. Checklist for Cal OSHA Requirements re COVID-19 Exposure Outbreak or Major Outbreak
6. COVID-19 Potential Outbreak Determination Checklist
7. Tab 005 - Job Safety Analysis (JSA) Program
8. Appendix to CPP - COVID-19 Inspections

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Revision History

Revision Date Initiator of


Description of Change(s)
# (mm/dd/yyyy) Change

1 08/10/2020 Ken Woodlin COVID-19 information added to IIPP (program


requirements and documents were previously managed
individually under the Corporate Pandemic Contingency
Plan)

2 10/25/2021 Ken Woodlin Corporate review and approval

3 01/14/2022 Mike Francis Updated Appendix 2.2 to reflect Cal/OSHA and


California Department of Public Health exclusion and
return to work requirements with the CDPH

4 05/06/2022 Mike Francis Updated Appendix 2.2 to reflect Cal/OSHA and


California Department of Public Health exclusion and
return to work requirements with the CDPH

5 02/03/2023 Mike Francis Updated Appendix 2.2 to reflect Cal/OSHA COVID-19


Prevention Non-Emergency Regulations

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