COVID RISK DIAL & BUSINESS GUIDANCE COMPREHENSIVE COVID-19 MITIGATION STRATEGIES FOR

EMPLOYERS AND WORKPLACE SETTINGS LINCOLN-LANCASTER COUNTY HEALTH DEPARTMENT

MAY 19, 2020

Comprehensive COVID-19 Mitigation Strategies for Employers and Workplace Settings This document provides local business a starting point to develop strategies and implement measures to ensure a place of business is instituting practices commensurate with where our community is at in this pandemic.

The strategies used to reduce negative impacts of COVID-19 are based on a modified hierarchy of controls developed by the John’s Hopkins Bloomberg School of Public Health as a part of their guidance for governors for a phased reopening during COVID-19. A comprehensive strategy will incorporate components from all four areas.

The four mitigation strategies are best described as follows: • Physical Distancing: Physical distancing is limiting close, prolonged contact with

others. This strategy is one of the best ways of preventing the spread of COVID-19. To practice physical distancing: - Stay at least 6 feet (about 2 arms’ length) away from other people - Do not gather in groups - Stay out of crowded places and avoid mass gatherings Businesses need to plan for and implement physical distancing. Mitigation through physical distancing can range from having people work from home, to placing stickers on the floor in the checkout aisles to mark where people should stand. Businesses will need to analyze how they will ensure both employees and customers can achieve this. As long as there is COVID-19 in our community, businesses are encouraged to have as many employees work from home or telework as possible.

• Engineering Controls: Creating physical barriers between people and using technology to reduce incidence of close contact. This is especially important when maintaining physical distancing is difficult. This could include constructing new barriers using materials such as rigid sheets of clear plastic or modifying practices to make use of existing barriers such as doors and windows. This could also include utilization of ‘no-touch’ technology systems for taking payment, clock-in/clock-out, client check-in, or other similar applications. While one of the most utilized engineering controls for COVID-19 are physical barriers, increasing fresh air intake through ventilation systems can also be of helpful.

• Administrative Controls: Administrative controls are training, procedures, policies, or shift designs that lessen the threat of a hazard to an individual. The use of administrative controls is very important to operating a business during the COVID-19 pandemic. Some relative administrative controls may include, but are not limited to: redistributing responsibilities to reduce contact between individuals, using technology to facilitate communication, arranging staggered shift change times, or training staff in effective sanitizing and hygiene protocols. This would also include establishing policies that support and enable employees to remain at home if they are unwell, or if they have been in close contact with someone who is sick.

Physical Distancing Engineering Controls

Administrative Controls

Personal Protective Equipment (PPE)

Comprehensive Strategy

• Personal Protective Equipment (PPE): PPE is protective clothing or equipment designed to protect the wearers body from infection, exposure or injury. Having people utilize equipment such as cloth face coverings, disposable gloves, respirators (i.e. N95, FFR), and face shields can reduce the user’s risk getting infected, and also reduce the risk of infecting others.

Building upon the Lincoln/Lancaster County COVID Risk Dial, the following describes how different businesses and organizations can apply these strategies to their workplace to protect their business, their employees, and their customers. This should be a starting point. Businesses will need to analyze their place of business, workflows, policies, and procedures and apply these mitigation strategies.

Two other factors that should be considered as you make decisions on what actions to take in your business setting are contact frequency and contact intensity. Think through your business operations in terms of an average number of human contacts at the same time (frequency) and the type of contact ranging from close to distant, and the duration ranging from brief to prolonged (intensity). A higher number of contacts (high frequency) poses higher risk. Low contact intensity activities are interactions that are brief and fairly distant, like walking past someone in a shop. High contact intensity activities involve prolonged close contact, like sharing a workspace with someone. Of course, inside a business environment there may be physical spaces and/or activities that range in contact frequency and intensity from low to medium to high, and that should be taken into account during the decision-making process. Risk to employees who may have different exposures should also be considered.

The COVID Risk Dial provides a context for where Lincoln and Lancaster County is in the COVID-19 pandemic. It is a tool to help the public and businesses know what steps to take to protect their employees, their customers and the health of everyone in our community. Each color on the COVID Risk Dial provides specific guidance for what you can do to keep your employees and customers safe. Special guidance is included for people who are most at risk and vulnerable to the COVID-19 virus. This tool will help you better understand our local situation and how it affects your workplace. The COVID Risk Dial is updated weekly.

At the end of this document is a blank graph where you as a leader within your business, can begin to build upon your mitigation strategies to become even more effective in reducing the potential of COVID-19.

COVID Red – Severe Risk of COVID-19 Spread

• For businesses and industries allowed to remain open, strategies surrounding strict adherence to physical distancing must be employed. If modifications cannot ensure physical distancing, strong consideration should be given to discontinuing that specific practice or duty. Employers must be focused on actively identifying employees displaying COVID symptoms, separating them from others, and excusing them from the workplace for medical follow-up. Businesses should strongly consider requiring customers to wear face coverings prior to entering. Curbside/drive-through business is strongly encouraged. Telework and/or working from home is strongly encouraged.

COVID Orange – High Risk of COVID-19 Spread

• Strategies surrounding strict adherence to physical distancing must be employed. If modifications cannot ensure physical distancing, strong consideration should be given to discontinuing that specific practice or duty. Employers must be focused on actively identifying employees displaying COVID symptoms, separating them from others, and excusing them from the workplace for medical follow-up. Businesses should consider requiring customers to wear face coverings prior to entering. Curbside/drive-through business is strongly encouraged. Telework and/or working from home is strongly encouraged.

COVID Yellow – Moderate Risk of COVID-19 Spread

• Strategies surrounding adherence to physical distancing, while eased, must still be employed. Employers will still need modifications to prevent the spread of COVID. Monitoring of employees for signs and symptoms of COVID-19 are still strongly encouraged. Those with COVID symptoms should be separated from others, and excused from the workplace for medical follow-up. Focus should be to keep at-risk employees and customers safe. Telework and/or working from home is strongly encouraged for at-risk employees.

COVID Green – Low Risk of COVID-19 Spread

• While there is little or no spread of COVID within the immediate community or region, employers should develop long-term strategies to limit impacts to their community, business, employees, and customers. The focus of these strategies is to prevent a resurgence of the COVID-19 virus or another pandemic illness. Some level of physical distancing should remain, and modifications will likely be the “new normal”. Focus will be to continue to protect the at-risk population and prepare for future outbreaks.

The Centers for Disease Control and Prevention (CDC) has developed a set of ‘General Business Frequently Asked Questions’ as well as ‘Interim Guidance for Businesses and Employers Responding to COVID-19’ that provide more specific guidance for workplace settings.

In addition to the control strategies above, the LLCHD has prepared the following workplace-specific guidance documents for businesses and organizations to implement programs of enhanced sanitation, employee illness monitoring, and exclusion of sick employees from the workplace.

• Restaurant In-Room Dining • Child Care Facilities (daycares & preschools) • Body Art Practices • Massage Therapy Services • Barber Shops & Cosmetology Salon Hair Services • Esthetic Salon Services • Nail Technology Salons

Additional workplace-specific guidance documents will be made available.

COVID Red – Severe Risk of COVID-19 Spread Control Type General Guidance for Essential Businesses and Industry Employers

Physical Distancing

• Keep workers at least 6 feet apart while working through workspace/desk spacing • Install signage for distancing • Require distancing at clock-in/check-in • Require distancing in outdoor smoking areas

Engineering Controls

• Install physical barriers between workers where 6-foot distancing is not possible or practical • Utilize a ‘no-touch’ or ‘touchless’ clock-in/check-in • Close meeting rooms and break rooms • Where possible, leave doors open to minimize touch • Provide sanitizing stations or portable handwashing stations in areas with high volume foot traffic or high touch surfaces • Increase air exchanges in the HVAC system to provide increased fresh air intake and air dilution

Administrative Controls

• Screen employees upon arrival for COVID signs and symptoms and dismiss employees with the following symptoms. Refer sick employees for medical follow-up and direct them to follow CDC recommendations. o Fever >100.4°F, cough, shortness of breath, difficulty breathing, chills, repeated shaking with chills, muscle pain, headache, sore

throat, new loss of taste or smell • Sick employees should not be allowed to return to work until they meet criteria for discontinuing home isolation • Where possible, provide paid leave for employees who test positive for COVID-19, or who display COVID symptoms (e.g. sick leave or

emergency paid sick leave under FFCRA) • Reduce or limit the number of people in any single space (offices, common areas, elevators, etc.) • Prohibit employees from entering work areas where access is not necessary, and from intermingling in other work areas • Use of web- or phone-based platforms for meetings (e.g. Zoom, Webex, GoToMeeting, Microsoft Teams, conference call, etc.) • Follow the CDC’s recommendations for cleaning and disinfection using products that meet EPA’s criteria for use against SARS-CoV-2 • Encourage frequent handwashing, use of hand sanitizer, and provide hand sanitizer if and where possible • Establish policies/protocols limiting non-essential visitors and strongly discouraging non-essential personal travel • Require single occupant travel in company vehicles, and suspend all non-essential work-related travel • Stagger breaks and lunch • If your business has an in-house cafeteria, provide food ‘to-go’ • Close areas that cannot be modified for distancing

PPE • Face coverings required for all employees, customers, and visitors (personal or company provided) o Disposable mask; or o Cloth face covering (bandana, sewn mask, etc.) laundered daily

• Disinfectants provided and encouraged use for: o Mouse, keyboards, pens, other high contact surfaces

At-Risk and Vulnerable

• For employees and customers over the age of 65 and anyone with underlying health conditions (diabetes, cancer, heart disease, lung disease, etc.), employers should consider the following protections for people at higher risk of severe illness from COVID-19, in addition to the General Guidelines and any Workplace-Specific Guidance: o Physical Distancing: Provide options to work from home or telework Offer a temporary workspace with greater distancing from customers and other employees Offer curb side, drive-up, or no-contact delivery service for vulnerable customers Consider options to reduce contact frequency or intensity

o Engineering Controls: Offer to install physical barriers between vulnerable workers and others, even if 6-foot distancing is provided Establish designated points of ingress/egress for vulnerable workers and customers

o Administrative Controls: Offer duties that minimize their contact with customers and other employees Discourage vulnerable workers, customers, and visitors from sharing elevators

o Personal Protective Equipment (PPE): If medically approved, supply vulnerable workers with higher level PPE (such as N95 mask)

COVID Orange – High Risk of COVID-19 Spread Control Type General Guidance for Employers

Physical Distancing

• Keep workers at least 6 feet apart while working through workspace/desk spacing • Install signage for distancing • Require distancing at clock-in/check-in • Require distancing in outdoor smoking areas

Engineering Controls

• Install physical barriers between workers where 6-foot distancing is not possible or practical • Utilize a ‘no-touch’ or ‘touchless’ clock-in/check-in • Close meeting rooms and break rooms • Where possible, leave doors open to minimize touch • Provide sanitizing stations or portable handwashing stations in areas with high volume foot traffic or high touch surfaces • Increase air exchanges in the HVAC system to provide increased fresh air intake and air dilution

Administrative Controls

• Screen employees upon arrival for COVID signs and symptoms and dismiss employees with the following symptoms. Refer sick employees for medical follow-up and direct them to follow CDC recommendations. o Fever >100.4°F, cough, shortness of breath, difficulty breathing, chills, repeated shaking with chills, muscle pain, headache, sore

throat, new loss of taste or smell • Sick employees should not be allowed to return to work until they meet criteria for discontinuing home isolation • Where possible, provide paid leave for employees who test positive for COVID-19, or who display COVID symptoms (e.g. sick leave or

emergency paid sick leave under FFCRA) • Reduce or limit the number of people in any single space (offices, common areas, elevators, etc.) • Prohibit employees from entering work areas where access is not necessary, and from intermingling in other work areas • Use of web- or phone-based platforms for meetings (e.g. Zoom, Webex, GoToMeeting, Microsoft Teams, conference call, etc.) • Follow the CDC’s recommendations for cleaning and disinfection using products that meet EPA’s criteria for use against SARS-CoV-2 • Encourage frequent handwashing, use of hand sanitizer, and provide hand sanitizer if and where possible • Establish policies/protocols limiting non-essential visitors and strongly discouraging non-essential personal travel • Require single occupant travel in company vehicles, and suspend all non-essential work-related travel • Stagger breaks and lunch • If your business has an in-house cafeteria, provide food ‘to-go’ • Close areas that cannot be modified for distancing

PPE • Face coverings strongly recommended for all employees, customers, and visitors (personal or company provided) o Disposable mask; or o Cloth face covering (bandana, sewn mask, etc.) laundered daily

• Disinfectants provided and encouraged use for: o Mouse, keyboards, pens, other high contact surfaces

At-Risk and Vulnerable

• For employees and customers over the age of 65 and anyone with underlying health conditions (diabetes, cancer, heart disease, lung disease, etc.), employers should consider the following protections for people at higher risk of severe illness from COVID-19, in addition to the General Guidelines and any Workplace-Specific Guidance: o Physical Distancing: Provide options to work from home or telework Offer a temporary workspace with greater distancing from customers and other employees Offer curb side, drive-up, or no-contact delivery service for vulnerable customers Consider options to reduce contact frequency or intensity

o Engineering Controls: Offer to install physical barriers between vulnerable workers and others, even if 6-foot distancing is provided Establish designated points of ingress/egress for vulnerable workers and customers

o Administrative Controls: Offer duties that minimize their contact with customers and other employees Discourage vulnerable workers, customers, and visitors from sharing elevators

o Personal Protective Equipment (PPE): If medically approved, supply vulnerable workers with higher level PPE (such as N95 mask)

COVID Yellow – Moderate Risk of COVID-19 Spread Control Type General Guidance for Employers

Physical Distancing

• Keep workers at least 6 feet apart while working through workspace/desk spacing • Install signage for distancing • Strongly recommend distancing at clock-in/check-in • Strongly recommend distancing in break rooms and smoking areas

Engineering Controls

• Install physical barriers between workers where 6-foot distancing is not possible or practical • Utilize a ‘no-touch’ or ‘touchless’ clock-in/check-in • Reduce chairs in meeting rooms and break rooms to provide 6-foot distancing • Where possible, leave doors open to minimize touch • Provide sanitizing stations or portable handwashing stations in areas with high volume foot traffic or high touch surfaces • Increase air exchanges in the HVAC system to provide increased fresh air intake and air dilution

Administrative Controls

• Screen employees upon arrival for COVID signs and symptoms and dismiss employees with the following symptoms. Refer sick employees for medical follow-up and direct them to follow CDC recommendations. o Fever >100.4°F, cough, shortness of breath, difficulty breathing, chills, repeated shaking with chills, muscle pain, headache, sore

throat, new loss of taste or smell • Sick employees should not be allowed to return to work until they meet criteria for discontinuing home isolation • Where possible, provide paid leave for employees who test positive for COVID-19, or who display COVID symptoms (e.g. sick leave or

emergency paid sick leave under FFCRA) • Reduce or limit the number of people in any single space (offices, common areas, elevators, etc.) • Prohibit employees from entering work areas where access is not necessary, and discourage intermingling in other work areas • Use of web- or phone-based platforms for meetings (e.g. Zoom, Webex, GoToMeeting, Microsoft Teams, conference call, etc.) • Follow the CDC’s recommendations for cleaning and disinfection using products that meet EPA’s criteria for use against SARS-CoV-2 • Encourage frequent handwashing, use of hand sanitizer, and provide hand sanitizer if and where possible • Establish policies/protocols limiting non-essential visitors, and discouraging non-essential personal travel • Consider reductions in multiple-occupant travel in company vehicles, cautious non-essential work travel • Stagger breaks and lunch • If your business has an in-house cafeteria, provide food ‘to-go’ • Close areas that cannot be modified for distancing

PPE • Face coverings recommended for all employees, customers, and visitors (personal or company provided) o Disposable mask; or o Cloth face covering (bandana, sewn mask, etc.) laundered daily

• Disinfectants provided and encouraged use for: o Mouse, keyboards, pens, other high contact surfaces; and

o Meeting room tables, breakroom counters, greeting counters, etc.

At-Risk and Vulnerable

• For employees and customers over the age of 65 and anyone with underlying health conditions (diabetes, cancer, heart disease, lung disease, etc.), employers should consider the following protections for people at higher risk of severe illness from COVID-19, in addition to the General Guidelines and any Workplace-Specific Guidance: o Physical Distancing: Provide options to work from home or telework Offer a temporary workspace with greater distancing from customers and other employees Offer curb side, drive-up, or no-contact delivery service for vulnerable customers Consider options to reduce contact frequency or intensity

o Engineering Controls: Offer to install physical barriers between vulnerable workers and others, even if 6-foot distancing is provided Establish designated points of ingress/egress for vulnerable workers and customers

o Administrative Controls: Offer duties that minimize their contact with customers and other employees Discourage vulnerable workers, customers, and visitors from sharing elevators

o Personal Protective Equipment (PPE): If medically approved, supply vulnerable workers with higher level PPE (such as N95 mask)

COVID Green – Low Risk of COVID-19 Spread Control Type General Guidance for Employers

Physical Distancing

• Encourage workers to remain at least 6 feet apart while working • Redesign workspaces with consideration for airborne transmission of COVID, influenza, or other airborne illnesses

Engineering Controls

• Physical barriers may be removed, but should not be discarded • Maintain readiness to reemploy engineering controls in the event of COVID resurgence, or other airborne illness outbreak (seasonal or

pandemic)

Administrative Controls

• Transition to a ‘new normal’ mode of operation • Create or modify pandemic plans for future needs • Where possible, provide paid leave for employees who test positive for COVID-19, or who display COVID symptoms (e.g. sick leave or

emergency paid sick leave under FFCRA)

PPE • Develop a plan for PPE needs relevant to COVID or other airborne transmitted illnesses • Develop a schedule to periodically examine PPE, discard expired PPE, and re-stock as necessary

At-Risk and Vulnerable

• For employees and customers over the age of 65 and anyone with underlying health conditions (diabetes, cancer, heart disease, lung disease, etc.), employers should consider the following protections for people at higher risk of severe illness from COVID-19, in addition to the General Guidelines and any Workplace-Specific Guidance: o Physical Distancing: Provide options to work from home or telework Offer curb side, drive-up, or no-contact delivery service for vulnerable customers Consider options to reduce contact frequency or intensity

o Administrative Controls: Offer duties that minimize their contact with customers and other employees Discourage vulnerable workers, customers, and visitors from sharing elevators

o Personal Protective Equipment (PPE): If medically approved, supply vulnerable workers with higher level PPE (such as N95 mask)

Appendix 1 – A Mitigation Template for Businesses This template is intended to give businesses a tool that will aid them in formulating an effective and comprehensive internal plan built upon the 4 strategies listed below. Physical distancing will be the most important aspect of a comprehensive plan. When physical distancing cannot be maintained, look to effective measures from the other strategies. The ideal plan will be inclusive of all 4 strategies.

• Physical Distancing • Engineering Controls • Administrative Controls • Personal Protective Equipment (PPE)

When evaluating where and how to implement strategies to reduce risk, consider these three concepts:

Contact Intensity – Contact intensity is classifying contact type ranging from close to distant as well as the duration of contact. Ideally, strive for the lowest contact intensity possible. An example of low contact intensity would be brief interactions at a distance. An example of high contact intensity would be the sharing of a desk for long periods of time.

Contact Frequency – Contact Frequency assesses the number of contacts and measures them from low to high. The focus here would be to reduce the contact frequency where possible. An example of the would be to create zones for groups of workers within your business. Workers should be discouraged from crossing into other zones throughout their workday and intermingling should be avoided.

Modification Potential – Modification potential is the degree to which mitigation strategies reduce risk. The engineering controls framework was used to inform the risk assessments; sectors and businesses that could effectively incorporate physical distancing and engineering controls were considered to have a higher modification potential than those relying on administrative controls or PPE. This factor should be considered, and if your business has a low modification potential your likelihood on reliance on the use of PPE increases.

Regardless of the business, there are specific strategies that can be implemented to reduce the risk of infection to protect individuals:

1. Use of non-medical cloth masks 2. Prompt identification and isolation of sick persons 3. Cleaning, disinfection, and decontamination procedures 4. Reconfiguring space to enable people to be located apart (ideally, at least 6 feet) 5. Incorporating engineering controls such as physical barriers and administrative controls for physical distancing where possible 6. Supporting and enabling employees to remain home if they are unwell or have been in close contact with someone who was sick 7. Communications and training for managers and workers necessary to implement the plan

If you are a retail business providing for pick-up, drop-off, delivery and/or in store shopping, or are a retail mall, your plan should include and describe how your business will implement the following:

1. Protection and controls for pick-up, drop-off, and delivery 2. Protection and controls for in-store shopping 3. Protection and controls for malls 4. Communications and instructions for customers

In addition to identifying strategies to reduce risk to your business employees and customers, it is important to stay abreast and changing Directed Health Measures (DHM) which are issued by both the State of Nebraska and the Lincoln-Lancaster County Health Department (LLCHD). These measures and your process of following them should be outlined within your plan.

Another important step in developing your plan is to identify what strategies your company or organization will implement to offer increased protective measures to at-risk and vulnerable employees, customers, and visitors. Strong consideration should be given to offer these individuals additional protection, as they are at a higher risk of severe health complications from COVID-19.

Finally, it is important to communicate your plan to all levels of your workforce. This tool is useful in clearly defining your plan and is easily read. It is important to LLCHD that we open our businesses in a way which protects the health of your employees and customers.

COVID [Color] – [Severe / High / Moderate / Low] Risk of COVID Spread Control Type Strategies to be Implemented

Physical Distancing

Describe strategies to be implemented to provide and maintain adequate Physical Distancing (6 feet or more): • • •

Engineering Controls

Describe Engineering Controls to be implemented to reduce risk of COVID spread: • • •

Administrative Controls

Describe Administrative Controls to be implemented to reduce risk of COVID spread: • • •

PPE Describe what PPE will be implemented to reduce risk of COVID spread: • •

At-Risk and Vulnerable

• Describe what strategies will be employed to protect people at higher risk of severe illness from COVID-19, in addition to the protective measures identified above: o Physical Distancing:

o Engineering Controls:

o Administrative Controls:

o Personal Protective Equipment (PPE):

Example Mitigation Plan #1 – Industrial Manufacturing Plant

COVID Orange – High Risk of COVID-19 Spread Strategies surrounding strict adherence to physical distancing must be employed. If modifications cannot ensure physical distancing, strong consideration should be given to discontinuing that specific practice or duty. Employers must be focused on actively identifying employees displaying COVID symptoms, separating them from others, and excusing them from the workplace for medical follow-up. Businesses should consider requiring customers to wear face coverings prior to entering. Curbside/drive-through business is strongly encouraged. Telework and/or working from home is strongly encouraged.

Control Type Example Protective Strategies to be Implemented

Physical Distancing

Describe strategies to be implemented to provide and maintain adequate Physical Distancing (6 feet or more): • Workspaces will be modified and reorganized to provide at least 6 feet of distance between employees • Non-essential production lines and areas will be closed if 6-foot distancing cannot be achieved • Additional signage will be installed to reinforce distancing requirements • Signs will be posted at plant entries near clock-in/check-in areas to remind employees of 6-foot distancing requirement • Signs will be posted in outdoor smoking areas to remind employees of 6-foot distancing requirement

Engineering Controls

Describe Engineering Controls to be implemented to reduce risk of COVID spread: • Physical barriers will be installed between workers where 6-foot distancing is not possible or practical • A no-contact clock-in/check-in will be purchased and installed • Meeting and break rooms will be closed, or modified to ensure 6-foot distancing at all times • Doors will be blocked open to minimize contact with door and door handles • Portable handwashing stations will be installed near high-traffic entryways • HVAC system will be programmed to provide a higher rate of air exchanges

Administrative Controls

Describe Administrative Controls to be implemented to reduce risk of COVID spread: • Employees will be screened upon arrival for COVID signs and symptoms. Sick employees will be sent home and referred for medical

follow-up. Sick employees will also be directed to follow CDC recommendations. • Sick employees will not be allowed to return to work until they meet criteria for discontinuing home isolation • Employees for who test positive for COVID-19, or who display COVID symptoms, will be provided with paid leave until allowed return

consistent with CDC recommendations. • Signs will be posted to limit the number of people in elevators • Signs will be posted to direct employees to remain in their own work areas, except as necessary to perform work duties • Use of web- or phone-based platforms for meetings (e.g. Zoom, Webex, GoToMeeting, Microsoft Teams, conference call, etc.) • Custodial cleaning will be done in accordance with the CDC’s recommendations for cleaning and disinfection, using products that meet

EPA’s criteria for use against SARS-CoV-2

Example Mitigation Plan #1 – Industrial Manufacturing Plant

Control Type Example Protective Strategies to be Implemented

Administrative Controls

• Signs will be posted to encourage frequent handwashing; hand sanitizer will be provided in areas where hand washing is not easily accessible

• Non-essential visitors will be prohibited from entry, all non-essential personal travel is discouraged • No more than 1 occupant will be allowed in company vehicles, all non-essential work-related travel is suspended • Breaks and lunch breaks will be staggered • In-house cafeteria will provide all meals in ‘to-go’ packaging, seating in lunchroom will be modified to ensure 6-feet of distance

PPE Describe what PPE will be implemented to reduce risk of COVID spread: • Reusable cloth face coverings will be provided and recommended for all employees. • Disposable masks will be provided for plant visitors. • Disinfectants provided for office and clerical staff for frequent disinfection of mouse, keyboards, pens, other high contact surfaces

At-Risk and Vulnerable

• Describe what strategies will be employed to protect people at higher risk of severe illness from COVID-19, in addition to the protective measures identified above: o Physical Distancing: At-risk employees will be given the option to work from home or telework, or offered a temporary workspace with greater

distancing from customers and other employees if telework is not feasible o Engineering Controls: Physical barriers between vulnerable workers and others will be provided at the employee’s request Vulnerable workers will be directed to use designated points of entry and exit, separated from other employees

o Administrative Controls: Vulnerable workers and visitors will be discouraged from sharing elevators

o Personal Protective Equipment (PPE): If medically approved, vulnerable workers will be supplied with higher level PPE (such as N95 mask)

Example Mitigation Plan #2 – Retail and Grocery Stores

COVID Red – Severe Risk of COVID Spread For businesses and industries allowed to remain open, strategies surrounding strict adherence to physical distancing must be employed. If modifications cannot ensure physical distancing, strong consideration should be given to discontinuing that specific practice or duty. Employers must be focused on actively identifying employees displaying COVID symptoms, separating them from others, and excusing them from the workplace for medical follow-up. Businesses should strongly consider requiring customers to wear face coverings prior to entering. Curbside/drive-through business is strongly encouraged. Telework and/or working from home is strongly encouraged.

Control Type Example Protective Strategies to be Implemented

Physical Distancing

Describe strategies to be implemented to provide and maintain adequate Physical Distancing (6 feet or more): • Control the volume of customers - too many customers increase the risk of disease spread and makes physical distancing very difficult. • Control the physical flow of customers. The less customers are close together, the better. Clearly mark how you want them to move

through aisles, including where to stand in line when checking out. Establish "One-Way" aisles to maximize spacing between customers with signs and/or floor markings.

• Keep workers at least 6 feet apart while working through workspace • Install signage for distancing • Create physical distancing at clock-in/check-in and clock out • Require physical distancing in break rooms

Engineering Controls

Describe Engineering Controls to be implemented to reduce risk of COVID spread: • Install Plexiglass in the cash register area to separate customers from cashiers due to the fact that a 6' distance cannot be easily kept • Install physical barriers between workers where 6-foot distancing is not possible or practical • Utilize a ‘no-touch’ or ‘touchless’ time clock-in/check-in • Reduce number of chairs and tables in break rooms to provide 6-foot distancing • Where possible, install automatic doors and leave doors open to minimize touch

Administrative Controls

Describe Administrative Controls to be implemented to reduce risk of COVID spread: • Clearly and frequently communicate the importance of employees staying home if they are sick. • Screen employees upon arrival for COVID signs and symptoms, dismiss employees with the following symptoms:

o Fever >100°F, cough, shortness of breath, difficulty breathing, chills, repeated shaking with chills, muscle pain, headache, sore throat, new loss of taste or smell

• Where possible, provide paid leave for employees who test positive for COVID-19, or who display COVID symptoms (e.g. sick leave or emergency paid sick leave under FFCRA)

• Stagger breaks and lunch • Require employees to wash their hands when they arrive for work and regularly during the shift.

• Increased signage encouraging frequent handwashing, disinfection, and cleaning for both employees and customers

Example Mitigation Plan #2 – Retail and Grocery Stores

Control Type Example Protective Strategies to be Implemented

Administrative Controls

• Allow “touchless” credit card transaction (Apple, Google Pay) • Raise limit for credit card purchase that requires a signature • Establish a "No Return" policy due to possible contamination of product that has left the store

• Expand hours to decrease customer density • Offer special hours for at risk and vulnerable people - those over 65 years of age, people with underlying health conditions.

• Require all staff to wear face coverings. Require customers to wear face coverings or offer them at a nominal price as they enter the store.

• Control the volume of customers - too many customers increase the risk of disease spread and makes social distancing very difficult. • Control the physical flow of customers. The less customers are close together, the better. Clearly mark how you want them to move

through aisles, including where to stand in line when checking out. Establish "One-Way" aisles to maximize spacing between customers with signs and/or floor markings.

• Install highly visible marks/tape on the floor at 6' distances with signage that says "keep your distance" to help customers understand how far apart they should stand. Place these in high traffic areas in the store. Assign extra staff to help in the process, especially at registers.

• Communicate with your customers - explain what they can do to stay safe. Be clear and helpful. Post signage that asks customers to please stay home if ill, keep physical distance of 6 feet, leave reusable bags at home, and wash hands or use hand sanitizer before shopping. Disinfect credit card keypad after each transaction

• Consider keeping every other register open to improve distancing

• Change your workflow and be conscious of making it easier for your employees to distance (i.e., one employee to break down a pallet)

• Clean and disinfect high contact surfaces on a routine basis (at least 4 times per day), especially door handles. Disinfect cart and basket handles between uses. Provide disinfectant wipes by cart area so customers can disinfect cart handles themselves. Disinfect cash register area, credit card keypads, pens, stylus, etc. on a regular basis.

• Offer shopping over the internet, personal shoppers, home delivery, and curbside pickup. When making deliveries, have customers prepay for their order. Drop the order outside the door.

• Discontinue all self-service foods (salad bar, olive bar) and product sampling\

• Don’t reset your store. Leave everything where it is so customers know exactly where to go to get what they want.

Example Mitigation Plan #2 – Retail and Grocery Stores

Control Type Example Protective Strategies to be Implemented

PPE Describe what PPE will be implemented to reduce risk of COVID spread: • Face coverings required for all employees AND customers

o Cloth face covering (bandana, sewn mask, etc.) laundered daily • Disinfectants provided and encouraged use for:

o Mouse, keyboards, pens, other high contact surfaces o Meeting room tables, breakroom counters, greeting counters, etc.

• Provide hand sanitizer where possible

At-Risk and Vulnerable

• Describe what strategies will be employed to protect people at higher risk of severe illness from COVID-19, in addition to the protective measures identified above: o Physical Distancing: Offer a temporary workspace with greater distancing from customers and other employees Offer curb side, drive-up, or no-contact delivery service for vulnerable customers

o Engineering Controls: Offer to install physical barriers between vulnerable workers and others, even if 6-foot distancing is provided Establish designated points of ingress/egress for vulnerable workers and customers

o Administrative Controls: Offer duties that minimize their contact with customers and other employees Discourage vulnerable workers, customers, and visitors from sharing elevators

o Personal Protective Equipment (PPE): If medically approved, supply vulnerable workers with higher level PPE (such as N95 mask)

Example Mitigation Plan #2 – Retail and Grocery Stores

COVID Orange – High Risk of COVID Spread Strategies surrounding strict adherence to physical distancing must be employed. If modifications cannot ensure physical distancing, strong consideration should be given to discontinuing that specific practice or duty. Employers must be focused on actively identifying employees displaying COVID symptoms, separating them from others, and excusing them from the workplace for medical follow-up. Businesses should consider requiring customers to wear face coverings prior to entering. Curbside/drive-through business is strongly encouraged. Telework and/or working from home is strongly encouraged.

Control Type Example Protective Strategies to be Implemented

Physical Distancing

Describe strategies to be implemented to provide and maintain adequate Physical Distancing (6 feet or more): • Control the volume of customers - too many customers increase the risk of disease spread and makes physical distancing very difficult. • Control the physical flow of customers. The less customers are close together, the better. Clearly mark how you want them to move

through aisles, including where to stand in line when checking out. Establish "One-Way" aisles to maximize spacing between customers with signs and/or floor markings.

• Keep workers at least 6 feet apart while working through workspace • Install signage for distancing • Create physical distancing at clock-in/check-in and clock out • Require physical distancing in break rooms

Engineering Controls

Describe Engineering Controls to be implemented to reduce risk of COVID spread: • Install Plexiglass in the cash register area to separate customers from cashiers due to the fact that a 6' distance cannot be easily kept • Install physical barriers between workers where 6-foot distancing is not possible or practical • Utilize a ‘no-touch’ or ‘touchless’ time clock-in/check-in • Reduce number of chairs and tables in break rooms to provide 6-foot distancing • Where possible, install automatic doors and leave doors open to minimize touch

Administrative Controls

Describe Administrative Controls to be implemented to reduce risk of COVID spread: • Clearly and frequently communicate the importance of employees staying home if they are sick. • Screen employees upon arrival for COVID signs and symptoms, dismiss employees with the following symptoms:

o Fever >100°F, cough, shortness of breath, difficulty breathing, chills, repeated shaking with chills, muscle pain, headache, sore throat, new loss of taste or smell

• Where possible, provide paid leave for employees who test positive for COVID-19, or who display COVID symptoms (e.g. sick leave or emergency paid sick leave under FFCRA)

• Stagger breaks and lunch • Require employees to wash their hands when they arrive for work and regularly during the shift.

• Increased signage encouraging frequent handwashing, disinfection, and cleaning for both employees and customers

Example Mitigation Plan #2 – Retail and Grocery Stores

Control Type Example Protective Strategies to be Implemented

Administrative Controls

• Allow “touchless” credit card transaction (Apple, Google Pay) • Raise limit for credit card purchase that requires a signature • Establish a "No Return" policy due to possible contamination of product that has left the store

• Expand hours to decrease customer density • Offer special hours for at risk and vulnerable people - those over 65 years of age, people with underlying health conditions.

• Require all staff to wear face coverings. Require customers to wear face coverings or offer them at a nominal price as they enter the store.

• Control the volume of customers - too many customers increase the risk of disease spread and makes social distancing very difficult. • Control the physical flow of customers. The less customers are close together, the better. Clearly mark how you want them to move

through aisles, including where to stand in line when checking out. Establish "One-Way" aisles to maximize spacing between customers with signs and/or floor markings.

• Install highly visible marks/tape on the floor at 6' distances with signage that says "keep your distance" to help customers understand how far apart they should stand. Place these in high traffic areas in the store. Assign extra staff to help in the process, especially at registers.

• Communicate with your customers - explain what they can do to stay safe. Be clear and helpful. Post signage that asks customers to please stay home if ill, keep physical distance of 6 feet, leave reusable bags at home, and wash hands or use hand sanitizer before shopping. Disinfect credit card keypad after each transaction

• Consider keeping every other register open to improve distancing

• Install Plexiglass in the cash register area to separate customers from cashiers due to the fact that a 6' distance cannot be easily kept • Change your workflow and be conscious of making it easier for your employees to distance (i.e., one employee to break down a pallet) • Require that employees practice social distancing of 6’

• Clean and disinfect high contact surfaces on a routine basis (at least 4 times per day), especially door handles. Disinfect cart and basket handles between uses. Provide disinfectant wipes by cart area so customers can disinfect cart handles themselves. Disinfect cash register area, credit card keypads, pens, stylus, etc. on a regular basis.

• Offer shopping over the internet, personal shoppers, home delivery, and curbside pickup. When making deliveries, have customers prepay for their order. Drop the order outside the door.

• Discontinue all self-service foods (salad bar, olive bar) and product sampling

• Don’t reset your store. Leave everything where it is so customers know exactly where to go to get what they want.

Example Mitigation Plan #2 – Retail and Grocery Stores

Control Type Example Protective Strategies to be Implemented

PPE Describe what PPE will be implemented to reduce risk of COVID spread: • Face coverings required for all employees and strongly recommended for all customers

o Cloth face covering (bandana, sewn mask, etc.) laundered daily • Disinfectants provided and encouraged use for:

o Mouse, keyboards, pens, other high contact surfaces o Meeting room tables, breakroom counters, greeting counters, etc.

• Provide hand sanitizer where possible

At-Risk and Vulnerable

• Describe what strategies will be employed to protect people at higher risk of severe illness from COVID-19, in addition to the protective measures identified above: o Physical Distancing: Offer a temporary workspace with greater distancing from customers and other employees Offer curb side, drive-up, or no-contact delivery service for vulnerable customers

o Engineering Controls: Offer to install physical barriers between vulnerable workers and others, even if 6-foot distancing is provided Establish designated points of ingress/egress for vulnerable workers and customers

o Administrative Controls: Offer duties that minimize their contact with customers and other employees Discourage vulnerable workers, customers, and visitors from sharing elevators

o Personal Protective Equipment (PPE): If medically approved, supply vulnerable workers with higher level PPE (such as N95 mask)

Example Mitigation Plan #2 – Retail and Grocery Stores

COVID Yellow – Moderate Risk of COVID Spread Strategies surrounding adherence to physical distancing, while eased, must still be employed. Employers will still need modifications to prevent the spread of COVID. Monitoring of employees for signs and symptoms of COVID-19 are still strongly encouraged. Those with COVID symptoms should be separated from others, and excused from the workplace for medical follow-up. Focus should be to keep at-risk employees and customers safe. Telework and/or working from home is strongly encouraged for at-risk employees.

Control Type Example Protective Strategies to be Implemented

Physical Distancing

Describe strategies to be implemented to provide and maintain adequate Physical Distancing (6 feet or more): • Consider controlling the volume of customers • Control the physical flow of customers. The less customers are close together, the better. Clearly mark how you want them to move

through aisles, including where to stand in line when checking out. Establish "One-Way" aisles to maximize spacing between customers with signs and/or floor markings.

• Keep workers at least 6 feet apart while working through workspace • Install signage for distancing • Create physical distancing at clock-in/check-in and clock out • Require physical distancing in break rooms

Engineering Controls

Describe Engineering Controls to be implemented to reduce risk of COVID spread: • Install Plexiglass in the cash register area to separate customers from cashiers due to the fact that a 6' distance cannot be easily kept • Install physical barriers between workers where 6-foot distancing is not possible or practical • Utilize a ‘no-touch’ or ‘touchless’ time clock-in/check-in • Reduce number of chairs and tables in break rooms to provide 6-foot distancing • Where possible, install automatic doors and leave doors open to minimize touch

Administrative Controls

Describe Administrative Controls to be implemented to reduce risk of COVID spread: • Clearly and frequently communicate the importance of employees staying home if they are sick. • Screen employees upon arrival for COVID signs and symptoms, dismiss employees with the following symptoms:

o Fever >100°F, cough, shortness of breath, difficulty breathing, chills, repeated shaking with chills, muscle pain, headache, sore throat, new loss of taste or smell

• Where possible, provide paid leave for employees who test positive for COVID-19, or who display COVID symptoms (e.g. sick leave or emergency paid sick leave under FFCRA)

• Stagger breaks and lunch • Require employees to wash their hands when they arrive for work and regularly during the shift.

• Increased signage encouraging frequent handwashing, disinfection, and cleaning for both employees and customers

Example Mitigation Plan #2 – Retail and Grocery Stores

Control Type Example Protective Strategies to be Implemented

Administrative Controls

• Allow “touchless” credit card transaction (Apple, Google Pay) • Raise limit for credit card purchase that requires a signature • Establish a "No Return" policy due to possible contamination of product that has left the store

• Expand hours to decrease customer density • Offer special hours for at risk and vulnerable people - those over 65 years of age, people with underlying health conditions.

• Require all staff to wear face coverings. Require customers to wear face coverings or offer them at a nominal price as they enter the store.

• Control the volume of customers - too many customers increase the risk of disease spread and makes social distancing very difficult. • Control the physical flow of customers. The less customers are close together, the better. Clearly mark how you want them to move

through aisles, including where to stand in line when checking out. Establish "One-Way" aisles to maximize spacing between customers with signs and/or floor markings.

• Install highly visible marks/tape on the floor at 6' distances with signage that says "keep your distance" to help customers understand how far apart they should stand. Place these in high traffic areas in the store. Assign extra staff to help in the process, especially at registers.

• Communicate with your customers - explain what they can do to stay safe. Be clear and helpful. Post signage that asks customers to please stay home if ill, keep physical distance of 6 feet, leave reusable bags at home, and wash hands or use hand sanitizer before shopping. Disinfect credit card keypad after each transaction

• Consider keeping every other register open to improve distancing

• Install Plexiglass in the cash register area to separate customers from cashiers due to the fact that a 6' distance cannot be easily kept • Change your workflow and be conscious of making it easier for your employees to distance (i.e., one employee to break down a pallet) • Require that employees practice social distancing of 6’

• Clean and disinfect high contact surfaces on a routine basis (at least 4 times per day), especially door handles. Disinfect cart and basket handles between uses. Provide disinfectant wipes by cart area so customers can disinfect cart handles themselves. Disinfect cash register area, credit card keypads, pens, stylus, etc. on a regular basis.

• Offer shopping over the internet, personal shoppers, home delivery, and curbside pickup. When making deliveries, have customers prepay for their order. Drop the order outside the door.

• Do not provide self-service foods (salad bar, olive bar) and product sampling

• Don’t reset your store. Leave everything where it is so customers know exactly where to go to get what they want.

Example Mitigation Plan #2 – Retail and Grocery Stores

Control Type Example Protective Strategies to be Implemented

PPE Describe what PPE will be implemented to reduce risk of COVID spread: • Face coverings required for all employees and recommended for customers

o Cloth face covering (bandana, sewn mask, etc.) laundered daily • Disinfectants provided and encouraged use for:

o Mouse, keyboards, pens, other high contact surfaces o Meeting room tables, breakroom counters, greeting counters, etc.

• Provide hand sanitizer where possible

At-Risk and Vulnerable

• Describe what strategies will be employed to protect people at higher risk of severe illness from COVID-19, in addition to the protective measures identified above: o Physical Distancing: Offer a temporary workspace with greater distancing from customers and other employees Offer curb side, drive-up, or no-contact delivery service for vulnerable customers

o Engineering Controls: Offer to install physical barriers between vulnerable workers and others, even if 6-foot distancing is provided Establish designated points of ingress/egress for vulnerable workers and customers

o Administrative Controls: Offer duties that minimize their contact with customers and other employees Discourage vulnerable workers, customers, and visitors from sharing elevators

o Personal Protective Equipment (PPE): If medically approved, supply vulnerable workers with higher level PPE (such as N95 mask)

Example Mitigation Plan #2 – Retail and Grocery Stores

COVID Green – Low Risk of COVID Spread While there is little or no spread of COVID within the immediate community or region, employers should develop long-term strategies to limit impacts to their community, business, employees, and customers. The focus of these strategies is to prevent a resurgence of the COVID-19 virus or another pandemic illness. Some level of physical distancing should remain, and modifications will likely be the “new normal”. Focus will be to continue to protect the at-risk population and prepare for future outbreaks.

Control Type Example Protective Strategies to be Implemented

Physical Distancing

Describe strategies to be implemented to provide and maintain adequate Physical Distancing (6 feet or more): • Encourage workers to remain at least 6 feet apart while working • Redesign workspaces with consideration to for airborne transmission, such as COVID or influenza

Engineering Controls

Describe Engineering Controls to be implemented to reduce risk of COVID spread: • Maintain readiness to reemploy COVID engineering controls for COVID resurgence or other airborne illness

Administrative Controls

Describe Administrative Controls to be implemented to reduce risk of COVID spread: • Create or modify COVID plans for future needs • Where possible, provide paid leave for employees who test positive for COVID-19, or who display COVID symptoms (e.g. sick leave or

emergency paid sick leave under FFCRA) • Consider maintaining COVID Administrative Controls for influenza and other airborne illness prevention • Update all plans for future outbreaks and Pandemics

PPE Describe what PPE will be implemented to reduce risk of COVID spread: • Plan and stock for PPE needs with a resurgence of COVID or other airborne transmitted illnesses

At-Risk and Vulnerable

• Describe what strategies will be employed to protect people at higher risk of severe illness from COVID-19, in addition to the protective measures identified above: o Physical Distancing: Offer a temporary workspace with greater distancing from customers and other employees Offer curb side, drive-up, or no-contact delivery service for vulnerable customers

o Engineering Controls: Offer to install physical barriers between vulnerable workers and others, even if 6-foot distancing is provided

o Administrative Controls: Offer duties that minimize their contact with customers and other employees

o Personal Protective Equipment (PPE): If medically approved, supply vulnerable workers with higher level PPE (such as N95 mask)