Mount Sinai Selikoff Centers for Occupational Health COVID-19 Workplace Health and Safety Guide

COVID-19

Health and Safety Resource Guide for Workplaces › Updated April 2022

About Us

If you would like tailored support, connect with us at occmed@mountsinai.org or 888-702-0630 to learn more.

https://www.mountsinai.org/ care/occupational-health

The Mount Sinai Selikoff Centers for Occupational Health are leaders in workplace health and safety. We are here to help organizations develop programs to reduce risk for coronavirus exposure and better protect their workers. Our team of occupational health physicians and safety professionals has developed this guide to assist with safe operations.

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CONTENTS

3 Our Services

Employee Education and Training

4 Develop a Written COVID-19 Safety Program

12 Testing

5 Communications Planning

13 Long COVID

6 Risk Reduction Strategies

14 Wellness and Mental Health

C OVID-19 Vaccination Ventilation and Filtration Space Design and Distancing Cleaning and Disinfection H and Hygiene Personal Protective Equipment

10 Medical Screenings

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11 Return to Work (RTW)

15 Commuting and Travel 16 Accommodation Lactation in the Workplace ADA Compliance and Qualifying Conditions

17 OSHA’S Recordkeeping Rule 18 Checklist and Guidance

Our Services • One-on-one consultations providing tailored guidance to meet your occupational health and safety needs • Virtual site visits to evaluate workplace safety, facility layout, and activity flow • Medical evaluations: post-exposure assessment, quarantine and isolation guidance, return-to-work clearance, functional capacity assessment • COVID-19 / SARS-CoV-2 testing coordination at various Mount Sinai practice locations • Injury prevention and ergonomics education and guidance in best practices for working remotely or on site • Medical clearance for respirator use • Education and training in all of the above areas

The COVID-19 Health and Safety Resource Guide and any associated information or materials, whether oral or written, are not intended to provide medical, legal, or other professional advice. The Guide is for general information purposes only.

Before finalizing your plan, we recommend that you obtain advice from qualified professionals. To the fullest extent allowed by law, the Icahn School of Medicine at Mount Sinai, including the Mount Sinai Selikoff Centers for Occupational Health, and its affiliates within the Mount Sinai Health System (collectively, “Mount Sinai”) disclaim all representations as to the accuracy or completeness of this guide and have no duty to supplement the information in this guide. Mount Sinai will not be liable for any errors or omissions in content or for any losses, injuries, or damages arising from the display or use of content.

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Developing a multi-faceted, dynamic COVID-19 prevention and control strategy is the key to an effective safety program.

Develop a Written COVID-19 Safety Program

The initial step is to organize a committee of individuals familiar with your work site, processes, and potential COVID-19 exposure scenarios. The committee should include management and employees or their representatives. The committee should produce a written program that should be considered a living document that may be modified as conditions change. New York State companies’ COVID-19 risk mitigation programs should include all required provisions of the NYS Hero Act.

New York State (NYS) Hero Act The Act applies to NYS private-sector employers. Under the Act, employers must develop a written exposure prevention plan. Employers can develop their own or adopt one of the industry-specific programs available online. The plan must account for specific work site and industry hazards, e.g., health care or construction industry. The Act requires the participation of employees or their designated representatives in developing the plan. The plan must select appropriate exposure controls, such as medical screening, masks, distancing, hand hygiene, cleaning, and disinfection. The Act comes into effect when a highly contagious communicable disease is designated by the NYS Health Commissioner. For general templates, or industry-specific templates, visit the NYS Department of Labor’s website.

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Communications Planning How you communicate your COVID-19 safety program information is critical. Communicate the program guidelines, policies, and procedures to all employees and share any customerdirected information publicly. Communication about your program should help increase worker awareness and encourage their adherence by providing new and updated information as it becomes available.

We suggest conveying the guidelines in a tone offering support and encouraging transparency among all. The important characteristics to consider are: • Tone of verbal and written communication • Emphasis of the program’s critical nature • Having an open-door policy for questions • Identifying the established point person(s) for questions and the time frame for turning around inquiries • Clarifying the availability of support if needed

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Risk Reduction Strategies

Your in-house safety strategy should use layers of protection aimed at reducing employee exposure, including promoting vaccination and booster shots, improving ventilation, working remotely, masking, distancing, front-door screening, training, disinfection, and when possible, moving activities outdoors. Your aim, first and foremost, should be to eliminate risk of infection.

Ensure that any strategies you develop do not conflict with existing safety and health protocols.

COVID-19 Vaccination / Resources We recommend checking this New York State resource page for answers to common questions about COVID-19 vaccines and their safety and effectiveness. Mount Sinai’s resource website is also available.

Vaccination is the best available way to protect yourself and others from severe or deadly COVID-19 as well as from “long COVID” syndrome.

How can I get vaccinated?

You can call the New York State COVID-19 Vaccination Hotline at 1-833-NYS-4-VAX (1-833-697-4829) to schedule an appointment. Once you have successfully scheduled an appointment, you will receive a confirmation email that contains a barcode. You will need to bring this to your appointment.

If you live outside of NYS, check your state’s health department website for vaccine eligibility criteria and locations.

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Risk Reduction Strategies

› continued

Ventilation and Filtration Improving ventilation and filtration is a key approach to decreasing the concentration of air pollutants or contaminants in the air. The following strategies identify ways to improve the air quality within your workplace.

• I ncrease ventilation: minimum six air changes/hour, increase the percentage of outside air used, increase system filtration to a minimum MERV 13*.

• O pening windows can help dilute contaminants in the air. The use of natural ventilation is limited by factors such as outdoor noise, temperature, window size and location, and wind direction and velocity. Opening windows will most often not provide the recommended six air changes/hour.

• P ortable HEPA air filters may be used to boost existing ventilation. Check portable air purifiers before purchasing for noise levels and to ensure they do not produce ozone, a known respiratory irritant. Portable air purifying ratings (CADR) are for their highest setting. Placement of portable units can influence their effectiveness. * You should consult with HVAC manufacturer or service provider before changing filters or modifying your system settings.

Space Design and Social Distancing Working remotely is the optimal way to ensure distancing. However, many businesses are unable to provide this option.

Identify potential exposure scenarios by reviewing your operational flow chart. We recommend keeping as much distance as possible between individuals, even if masked. To do this, you may need to modify your layout, activity flow, and locations of work areas.

Once your facility’s flow is assessed, hang signage for direction of movement, guides for distancing, and statements of area capacity.

This is especially important where there might be a wait for entry or exit, such as security checkpoints, breakrooms, restrooms, hallways, and elevators. Signage should be visible as people enter and exit to help prevent bottlenecks and crowded areas.

Translation of signage into commonly used languages is essential. Icons and symbols are most effective for rapid and universal comprehension. In smaller workspaces, we recommend modified work schedules to limit the number of employees on location.

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Risk Reduction Strategies

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Cleaning and Disinfecting The virus can potentially be transmitted through touching contaminated surfaces or objects and then touching one’s face near the mouth, nose, or eyes (mucus membranes). Disinfection is the process of killing microorganisms. Cleaning is the first step of the disinfection process.

Cleaning removes grime and dirt that might prevent disinfection. Before you begin disinfection, create a list of areas that need to be disinfected. Disinfection should concentrate on high-contact areas such as door handles, desks, elevator buttons, railings, and tools. The frequency of cleaning and disinfection will be based on work site and environmental conditions. Based on your risk assessment, other non-high-contact areas may also require scheduled disinfection.

Review the manufacturer’s instructions before using any disinfectant. Use safe work practices, such as increased ventilation to reduce exposure level, and use recommended personal protective equipment (gloves, eye protection, protective garments, and respirators).

Hand Hygiene Promote healthy hand hygiene practices with signage, education, and training.

Handwashing with soap and water for 20 seconds is an effective way to kill the virus that causes COVID-19.

Conveniently located wash stations with warm water are the key to an effective hand hygiene program. When soap and water are not available, you can substitute an alcoholbased hand sanitizer containing at least 60 percent alcohol. Hand disinfectants containing methanol should never be used.

Additional handwashing should take place throughout the day, especially before, during, and after food preparation, and after using the toilet, blowing your nose, coughing, sneezing, or touching your mask or the garbage.

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HOW TO WASH YOUR HANDS THE RIGHT WAY 1

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Wash with cold or warm water

Use liquid or bar soap, rub hands together

Lather the back of your hands

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Between your fingers

Under your fingernails

Scrub for at least 20 seconds

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Rinse with running water

Dry with clean towel or air dry

Risk Reduction Strategies

› continued

Personal Protective Equipment (PPE) Personal protective equipment (PPE), such as masks, gloves, and face shields, has been the most-used risk reduction tool during the COVID-19 pandemic. PPE is an effective risk reduction tool when used alongside other controls to provide an additional level of protection. PPE does have limitations that often reduce its effectiveness. It must be used correctly to be effective, and it places that burden on the employee. Masks must cover both the mouth and nose to be maximally effective. Cloth masks, gaiters, bandanas, and scarves are not recommended. Respirators must be NIOSH-approved.

According to the Centers for Disease Control and Prevention (CDC), mask-wearing will reduce potential exposure (infectious respiratory droplets) from one person to another. More information on the different types of masks and respirators can be found here.

Not all commercially available face masks are designed to meet federal regulatory standards. Three types of face masks are commonly provided by employers: surgical masks, barrier face coverings, and N95 respirators.

1. C loth and other nonsurgical masks are the most common masks used to reduce the spread of the virus (source control). They are loose-fitting and offer limited protection to the user from infectious material.

Masking Is Mandatory

2. FDA-authorized surgical masks are designed to provide source control and a barrier to particles and fluids.

Throughout the Mount Sinai Health System

3. N 95s are a type of respirator and are the most protective of the three masks. N95 respirators are tight-fitting face pieces designed to provide the user protection from very small particulates including viruses, if fit-tested and used correctly. Even when not fit-tested, N95s are more protective than other face masks. Anyone using an N95 to protect themselves from workplace contaminants, such as lead or solvents, must follow OSHA respirator guidance: (1910.134) requirements.

Cover both your nose and mouth

No, no, No, no, no no

Not Notquite quite

Almost Almost

Good to go Good

We recommend that you implement the use of appropriate face coverings as per the CDC and your localup health Mask fordepartment safety guidance.

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We encourage daily self-screening for COVID symptoms and risk of contagion.

Medical Screenings Front Door Screening Protocols Screening protocols prior to entry may consist of: 1. Vaccine status verification 2. A symptom checklist 3. A specific assessment of the risk of coronavirus exposure

High-Risk Individuals Even though the COVID-19 safety program is designed to mitigate risk, some employees may have medical conditions that place them at a higher risk of severe illness if infected with COVID-19 and they may require additional safeguards. We recommend these employees be assessed either by their primary-care physician or by an occupationalmedicine physician with experience in evaluating workplace hazards.

Depending on the degree of risk for an individual worker, the physician may make recommendations for accommodations such as remote work, job reassignment, increased barriers, or enhanced personal protective equipment (PPE).

Front Door Screening We recommend that employers establish a process to screen incoming employees, contractors, and visitors either before they arrive at your facility or at the entrance of the facility. Before you set up a front-door screening, you should consider which personnel will have access to confidential personal health information, as well as current regional COVID-19 activity, regulatory COVID-19 vaccination, and masking mandates.

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If the individual answers “yes” to the symptom check and the exposure assessment, the individual should not enter the facility. They should be referred to their primary-care physician for further recommendations on treatment, quarantine, or isolation. They should have a safe way to be transported home, or to a health care facility if needed.

Appropriate controls to permit entry, such as putting on masks, face shields, or goggles, and instructions on how to proceed after entering should be provided after screening and prior to entry.

Return to Work (RTW) A qualified health care professional, such as the employee’s primary-care physician or an occupational-health provider, should make the decision to discontinue isolation after a COVID-19 infection.

If an employee returning after illness has a change in their work capabilities and requires accommodations to enable them to work, an assessment performed by a qualified physician can help determine the employee’s ability to perform specific tasks and essential job functions.

See below for more information on requests for accommodation under the Americans with Disabilities Act. As SARS-CoV-2 activity varies, local, state, and federal guidance may change. Check your local health department website or CDC recommendations for return-to-work criteria.

Employee Education and Training Exposure to COVID-19 is not limited to the workplace. COVID-19 employee education should include a review of symptoms, discussion of primary (respiratory) and secondary (contact with contaminated surfaces) routes of transmission, and the importance of vaccination, distancing, disinfection, masking, and other practices outside the workplace.

Encourage vigilance and continued safe practices.

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Testing

For more information on COVID-19 testing please visit Mount Sinai’s Testing and Treatment website.

COVID-19 Rapid or Antigen Test An antigen is a substance that induces an immune response. These tests have the advantage of rapidly detecting viral particles from samples collected by nasal swabs. These tests are authorized for point-of-care testing and for rapid home testing. Positive results from antigen tests are highly accurate, especially when the test is administered to an individual with COVID symptoms. There is a higher chance of a false negative result, so negative results do not rule out infection and should be confirmed by molecular testing.

COVID-19 PCR or Molecular Test Molecular tests or PCR tests detect the presence of COVID-19 virus genetic material (viral RNA). These tests are believed to be highly accurate, and both positive and negative tests are reliable. These tests offer the advantage of accurate determination of infected versus non-infected people but have limitations in turnaround time for the test results, as well as regional variation in test availability.

Antibody or Serological Test These tests detect antibody presence in people who mounted an immune response to an infection or vaccination. These tests can help assess whether a previously infected individual has some degree of protection against reinfection with the same virus, might have had an unrecognized infection or one with minimal symptoms, or might still be at risk despite vaccination, such as immunocompromised individuals. Most useful in convalescent plasma donation for potential treatment of severely ill COVID-19 patients.1-2

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Long COVID and the Workplace Please Scan the QR code or visit https://www.cdc.gov/ coronavirus

Many workers returning to the workplace following COVID-19 infection may have Long COVID and require job modification. CDC defines Long COVID or Post-COVID Conditions as: “an umbrella term for the wide range of health consequences that are present more than four weeks after infection with SARS-CoV-2.”

These ongoing symptoms may present in the form of:        

• • • • • • •

Fatigue Brain fog Headaches Loss of smell or taste Dizziness with standing Palpitations Chest pain

     

• • • • • •

Shortness of breath Cough Joint or muscle pain Depression or anxiety Fever Symptoms that get worse after physical or mental activities

Some of the most prevalent symptoms like fatigue, respiratory symptoms, cardiac symptoms, and neuropsychiatric symptoms (i.e., brain fog, difficulty concentrating) may present significant barriers as well as safety concerns to employees returning to work.

Therefore, some employees with Long COVID may have to return to work with accommodations. These accommodations may include modified work assignment, changes to the work environment, and/or adjustments to schedules and responsibilities. You can work with an occupational health physician to determine the level of accommodations that should be made to enable workers to return to work while experiencing Long COVID symptoms.

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Wellness and Mental Health

The outbreak of COVID-19 has brought about a considerable degree of fear, stress, and anxiety across society. The emotional toll will have a lasting effect on many individuals and their families in the years to come.

Employers have an opportunity to support their workforce by including wellness and confidential mental health programs as a component of their COVID-19 safety program.

Programs may include: • I ndividual, group, and family counseling • S tress management, stress reduction, and mindfulness programs • Grief and loss counseling • I njury prevention and ergonomic essentials • Remote work healthy habits • C hild care and elder care assistance • Peer-to-peer support groups 14

Commuting and Travel

Depending on the duration of a commute, you and your employees should assess the safest method of travel and its feasibility. Protective measures should be taken for all means of transportation, including the use of masks; avoiding high-frequency-touch surfaces; frequent hand sanitizing; disposable glove use; avoiding touching the mouth, nose, or eyes; and social distancing. See the CDC guidelines for various transportation precautions.

Personal and Work-Related Travel As COVID-19 has spread both internationally and nationally, travel advisories are frequently changing. Refer to your city, state, and federal websites for national and international travel updates. If you are not sick, have not been exposed to anyone sick with COVID-19, and must travel during the pandemic, please refer to the general CDC travel advisory which provides guidance on all known current and past outbreaks.

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Accommodation When planning a return to work, employers must meet all public safety codes, building codes, applicable laws, and security requirements. Specifically, as it relates to the public and employees, ADA requirements must not be compromised.

Lactation Accommodation in the Workplace Update and share guidelines for lactation room usage to support nursing mothers in the workplace. Address issues related to access to the space, utilization of supplies, and cleaning and disinfection practices. Post signage to encourage proper hand hygiene and masking. For more information on lactation accommodation in the workplace, please review the following: CDC COVID-19 Pregnancy & Breastfeeding CDC Proper Storage & Prep of Human Milk & Safe Cleaning Practices The World Alliance for Breastfeeding Action (WABA)

ADA Compliance and Families First Coronavirus Response Act The U.S. Equal Employment Opportunity Commission (EEOC) enforces workplace anti-discrimination laws including the Americans with Disabilities Act (ADA) and the Rehabilitation Act, including the requirement for reasonable accommodation for those with disabilities and rules about medical examinations and inquiries. Updated guidance was issued in fall 2021 stating that the EEOC recognizes that “long COVID” may be a disability under the Americans with Disabilities Act (ADA) and Section 501 of the Rehabilitation Act in certain circumstances. The EEOC agrees with the analysis of “long COVID” by the Departments of Health and Human Services and of Justice in their “Guidance on ‘Long COVID’ as a Disability under the ADA, Section 504, and Section 1557.” Please reference the EEOC website for the most up-to-date information.

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ADA Qualifying Conditions: Concerns most often are centered on individuals who may be at higher risk for developing complications related to the coronavirus.

This may also include older adults as identified by the Centers for Disease Control and Prevention (CDC). Employers must address these concerns, which could encompass but are not limited to individuals with chronic medical conditions such as diabetes or lung or heart disease, and those who are immunocompromised or workers with residual symptoms as a result of having the virus. If a medical provider’s recommendation is preventive in nature, a relationship between the disabling condition and the accommodation request should be provided by the employee (or their physician) to demonstrate that if infected by the coronavirus the employee could experience medical complications.

Consideration must be given to measures that reduce employee exposure to the virus as these requests are categorized as ADArelated. An employer must consider these types of requests and must engage in a dialogue with the employee to identify reasonable accommodations barring undue hardship to the employers.

OSHA’S Recordkeeping Rule OSHA’s COVID-19 recordkeeping rule is applicable to all employers. The interim guidance states that COVID-19 is a recordable illness that is time-limited to the current COVID-19 public health crisis. All employers are responsible for recording COVID-19 cases.

COVID-19 is a respiratory illness and should be coded as such on the OSHA Form 300.

Criteria to be followed:

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An individual with at least one positive respiratory test for SARS-CoV-2.

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The case is work-related as defined by 29 CFR § 1904.5.

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The case involves one or more of the following criteria set forth under general recording 29 CFR § 1904.7: o Death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, loss of consciousness, or involves significant injury or illness diagnosed by a physician or health provider even if it does not result in the above mentioned (3a-3e).

OSHA Compliance Safety and Health Officers (CSHO) will exercise discretion on enforcement if the employer has complied with this obligation and has made reasonable determination of work-relatedness including:

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The reasonableness of the employer’s investigation into work-relatedness.

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The evidence available to the employer.

• T he evidence that a COVID-19 illness was contracted at work, i.e., development of illness in clusters of workers who work together, or close exposure to public in areas of high community transmission. If the employer cannot determine if exposure was likely in the workplace, the employer does not need to record that COVID-19 illness.

https://www.mountsinai.org/care/occupational-health

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Checklists and Guidance Documents Hearing Impaired COVID-19 Symptom Check

General Resources New York State (NYS) Department of Health – COVID-19 NYS Workers’ Compensation Paid Leave Law NYC Community Resources OSHA Guidance on Preparing Workplaces for COVID-19 OSHA COVID-19 NIOSH Coronavirus Disease 2019 CDC Reopening Guidance for Cleaning and Disinfecting Public Spaces, Workplaces, Businesses, Schools, and Homes WHO Coronavirus disease (COVID-19) technical guidance: Guidance for schools, workplaces & institutions National COSH Coronavirus Resources for Workers ACOEM COVID Resources Infectious Diseases Society of America

Lactation Resources CDC COVID-19 Pregnancy & Breastfeeding CDC Proper Storage & Prep of Human Milk & Safe Cleaning Practices The World Alliance for Breastfeeding Action (WABA)

Wellness & Mental Health Resources NYC Well NYS Office of Mental Health Crisis Text Line CDC Managing Stress

1 https://www.fda.gov/news-events/press-announcements/coronavirus-covid-19-update-fda-authorizes-firstantigen-test-help-rapid-detection-virus-causes 2 https://www.fda.gov/medical-devices/emergency-situations-medical-devices/faqs-testing-sars-cov-2

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