Returning to Work: Small Manufacturing, Repair and Maintenance Shops Guidance Document

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Photo courtesy of Getty Images Version 5 | December 8, 2020 Guidance Document Returning to Work: Small Manufacturing, Repair and Maintenance Shops

Overview that people can spread the virus while pre-symptomatic or asymptomatic. With stay at home and shelter-in-place restrictions beginning to lift, small manufacturing sites, repair Small manufacturing sites, maintenance and repair and maintenance shops, etc. are faced with difficult shops, etc. should continually monitor global World questions that must be addressed as they transition Health Organization [WHO]), federal (Centers for back to normal operations, such as: Disease Control [CDC] and Occupational Safety and Health Administration [OSHA]), state, and local • How can we protect our employees, third parties, guidelines for changes in recommendations, disin- and customers from the disease? fection strategies, worker protections and other best • How can we minimize the risk of disease transmis- management practices. sion if those that are ill or those who have had contact with positive COVID-19 in our workforce? Employers should consider the following strategies for reducing the risk of COVID-19 transmission in re- • What steps are needed if an employee had gards to physical distancing, ventilation, enhanced COVID-19 symptoms or a confirmed test for COVID-19? cleaning and disinfecting practices, restrooms, gathering areas and contact surfaces, personal hygiene, Common examples of small manufacturing sites and employee wellness, personal protective equipment maintenance shops include: (COVID-19 related protective equipment should in- • Plants that directly manufacture, package, and clude face coverings/masks and/or face shields for transport material and goods for market close contact activities, regular work gloves), training, waste and laundering, and communication. Em- • Plants that manufacture parts, materials, and ployers should consider forming a knowledgeable goods as parts that are sent to other manufactur- team to monitor, assess, and implement new strate- ers gies as they become available. • Welding shops, mechanical shops, small repair shops, etc. Tips to Consider to Return to Normal Business Operations: What should an Employer do to protect • Implement and inform employees of supportive themselves and their workers? workplace policies as applicable: – Flexible sick leave policies consistent with public SARS-CoV-2, the virus that causes COVID-19, is health guidance. Providing paid sick leave is an thought to be spread primarily through respiratory important way to encourage employees to stay droplets at close range. Airborne transmission from exposure to very small droplets over long distances home when sick. is unlikely. However, there is evidence that this mode – Consider not requiring a COVID-19 test result of transmission is possible, particularly in crowded, or a healthcare provider’s note for employees indoor spaces. People may also become infected by who are sick to validate their illness in order to touching contaminated surfaces. The virus has been qualify for sick leave. If you do require a doctor’s shown to survive in aerosols for hours and on surfac- note from your employees to verify that they are es for days. Infection can occur through eyes, nose, healthy and able to return to work, be aware that and mouth exposures. There is also strong evidence healthcare provider offices and medical facilities

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may be extremely busy and not able to provide tions on what to do if they develop symptoms. At such documentation in a timely manner. Get a minimum, any worker should immediately notify more information related to the Americans with their supervisor, their health care provider, and the Disabilities Act during the COVID-19 pandemic. local health department, who will provide guid- – Flexibility to stay home to care for a sick family ance on what actions need to be taken. member. • Ask employees to consider the following if they – Human resources policies consistent with pub- commute to work using public transportation: lic health guidance, and state and federal work- – Use other forms of transportation if possible. place laws. For more information on employer – If taking public transportation, maintain physical responsibilities, visit the Department of Labor’s distancing and wear a cloth or disposable face and the Equal Employment Opportunity Com- covering. mission’s websites. – Change commute time to less busy times if pos- – Employee assistance program and community sible. resources to help employees manage stress and receive support. – Wash hands before and as soon as possible af- – Encourage employees at increased risk for se- ter their trip. vere illness to request special accommodations Best Management Practices Protocols to allow them to perform their job duties safely • If possible, stagger shifts to isolate and compart- while also protecting sensitive employee health mentalize employees. This will allow protection of information. others if a breakout occurs and reduces/limits the • Post signs and reminders at entrances and in stra- number of people who are exposed at shift change. tegic places providing instruction on hand hygiene, Having the same teams work together can limit the respiratory hygiene, and cough etiquette. This reach of a potential outbreak. should include signs with images for non-English • Consider a 4-day work week, or other variation readers, as needed. where possible, to allow for 72 hours of downtime • Encourage those who are sick or at greater risk to at the facility. stay home. This includes: – This allows for limited exposure to 4 days instead – People with underlying medical conditions. of 5 days and; – People who live with elderly people or those who – The CDC and other recent studies have shown are at risk. COVID-19 can stay active up to 3 days on surfaces. – People with upper respiratory or flu-like symp- • Complete a task-based review/mapping of the toms or who live with someone with these clin- business work areas to determine best strategies ical symptoms. for physical distancing of at least 6 feet, and en- – People with COVID-19, people who live with sure employees have cloth or disposable face cov- someone with COVID-19, or who have been ex- erings as necessary. posed to someone with COVID-19. • Identify all high touch surfaces and ensure they are • Employers should educate employees to recognize cleaned and disinfected on a daily basis and be- the symptoms of COVID-19 and provide instruc- tween shifts.

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• For two person jobs, determine what additional • Employee teams or identified groups shall clean PPE may be required besides cloth or disposable and disinfect their shared workstations and equip- face coverings. ment after each use or shift. • Where individual workstations prevent 6-foot sepa- • Do not share tools if possible. When tools are ration, utilize plastic partitions between employees. shared, ensure they are cleaned and disinfected • Reduce the number of individuals on the site to before and after each use. essential employees to complete the work. Tem- • All large shared equipment and tools shall be porary spaces (site/job trailers) should be cleaned cleaned before and after use. and disinfected daily. • Ensure toolbox talks have adequate spacing and • Inform all customers, sales personnel and visitors only have one person note who is in attendance. to wear cloth or disposable face coverings and to abide by physical distancing requirements when • Encourage employees to raise other measures that on site. can be put into place to further reduce the potential spread of the virus. • No handshake greetings. • Modify break areas to allow for physical distanc- • Eliminate non-essential visits, such as job tours, ing. Stagger breaks to reduce people in break ar- vendor demos, etc. Essential visits should be done eas. in a dedicated, isolated space if available. • Do not share clipboards, but rather use a white • Dining tables should be marked with “X”s to dis- board to demonstrate the concept in the field. courage people from sitting closer than 6 feet away from each other. • If you are symptomatic – do not visit the site and stay home. • Breakrooms should have chairs removed to minimize any chance of gathering. • Establish an isolated area for all delivery compa- nies to drop off materials and supplies. Require • Janitorial employees should be disinfecting eating delivery and shipping personnel to wear cloth or areas hourly or as frequently as possible. disposable face coverings and gloves when arriv- • Reduce the number of people in company-owned ing at the site. vehicles or organized van pools. • Consider wiping down/disinfecting all items to be • Encourage employees to wash clothes and face shipped prior to pick up. coverings daily on the warmest setting possible. • Reduce tasks requiring a large number of people to • If a positive COVID-19 case amongst the work- be in one area. force is identified, quickly disinfect the employee’s • Weekly safety/toolbox talks should be virtual or workspace. in smaller groups. All hands meetings shall be re- • Maintain a daily approved visitor log. This log duced in frequency. Consider limiting meetings to should include the date, time, and contact informa- 10 people or less, depending on the size of the room tion of the visitor. where the meeting will be conducted. Employees should consider using virtual meeting tools, includ- • Stop employees from walking floors, between ing phone, TEAMS, VTC or WebEx, in lieu of in-per- floors, or buildings unnecessarily to reduce son meetings, whenever possible. cross-contamination.

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– Consider wearable technology such as proximi- after touching any common contact surfaces, ty devices worn on hard hats or wrist bands to and before eating. Avoid touching eyes, nose, or monitor employee physical distancing and trac- mouth with unwashed hands. ing of contacts. • Employees should wash hands with clean, running – For close contact activities that cannot be ad- water, apply soap, lather and scrub for at least 20 justed for physical distancing, consider providing seconds, then rinse. Dry hands using a clean pa- enhanced PPE or a face shield with a face cover- per towel or air dry. When soap and water can’t ing while fully considering all the potential OSHA be used, use an alcohol-based hand sanitizer that requirements. contains at least 60% ethanol or 70% isopropyl • Health checks and reporting requirements of in- alcohol. Any use of alcohol-based hand sanitizers dividuals infected with COVID-19 should be ex- should follow local and State guidelines. plained to employees prior to reopening and again Screening and Temperature Check once operations have resumed. • Conduct employee temperature screening and well- • Communicate to employees the importance of be- ness checks before each shift. (NOTE: be sure to ing vigilant when monitoring symptoms and stay- comply with OSHA’s Access to Employee Exposure ing in touch with their employer or manager if or Medical Records standard for confidentiality.) when they start to feel sick. – Temperature screening methods can include • Provide for additional hand washing stations with manual (use non-contact infrared thermometers) soap and water in common areas and throughout or thermal camera meeting FDA recommenda- the site. tions. Additional screening information/guidance • Make hand sanitizer stations available throughout can be found on the CDC website. work and public places. Stations should also be – Assign an employee to manage and conduct the placed in convenient locations, such as at entranc- temperature screenings while following CDC es, exits, near elevators, and restrooms. Touch- guidelines in the above link. If this is not possible, free hand sanitizer dispensers should be installed employees can self-check their own temperature. where possible. – Screening should be done in a manner such that – Also provide hand sanitizer in vehicles such as the privacy of employees is respected. forklifts and workstations. – Perform a visual inspection for other signs of • Employees should cover their mouths and noses illness (e.g., flushed cheeks, rapid or difficulty with a tissue when they cough or sneeze and throw breathing without recent physical activity, fa- used tissues in the trash. If employees don’t have tigue, extreme fussiness, cough). a tissue, cough or sneeze into your elbow, not your hands. Immediately wash your hands after blow- – Employees who have a fever of 100.4˚ F (38˚C) ing your nose, coughing, or sneezing. Learn more or above, or other signs of illness should not be about coughing and sneezing etiquette. admitted to the facility. • At minimum, employees should wash their hands • Employers can consider incorporating a wellness after they have been in a public place, after touch- questionnaire with questions such as: ing their face covering, after blowing their nose, – Have you, or a person you have been in close coughing, or sneezing, after using the restroom, contact with, been diagnosed with COVID-19

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within the last 14 days? (close contact is 6 feet or – Engage HR immediately and enforce all applica- less for more than 10 minutes.) ble HR rules and regulations. – Have you experienced any cold or flu-like symp- – The employee shall be isolated to the area they toms in the last 72 hours (to include fever, short- are in currently and removed from the work site ness of breath, cough, sore throat, difficulty for a minimum of 14 days. breathing, nausea, vomiting, and diarrhea)? – Any individuals having “close contact” (with- – Have you traveled to an international or domes- in approximately 6 feet) with the sick employee tic “hot” spot in the last 14 days? should also be isolated from the work site for 14 – There are a number of examples available for days; and all other employees should continue to wellness questionnaires (see Resources below). follow physical distancing rules. Communicate • Require employees who have symptoms or signs and reinforce with employees, while maintaining (i.e., fever, cough, or shortness of breath) or who PII and HIPAA requirements, that they may have have a sick family member at home with COVID-19 been exposed and to closely monitor their health, to notify their supervisor and stay home. temperature, and current symptoms as identified by the CDC. Contact tracing and sharing of • Sick employees should follow the CDC-recom- employee information should be done under the mended steps. Employees should not return to guidance of Human Resources due to privacy re- work until the criteria to discontinue home isolation quirements of HIPAA, ADA, and EEOC. See the are met in consultation with healthcare providers CDC’s “Coronavirus Disease 2019 (COVID-19) and state and local health departments. Consider General Business Frequently Asked Questions”. waiving requirements for medical documentation during the pandemic, as CDC has advised people – Enhanced cleaning and disinfecting should be with mild illness NOT to go to the doctor’s office or done immediately by trained personnel, who emergency room. should wear face coverings and gloves, dis- • If employee is sick or receives positive COVID-19 pose of gloves after use, and wash hands and test results, results should be reported to employer. face when complete. Visibly dirty surfaces shall In the case of a positive COVID-19 test result, the be cleaned using a detergent or soap and water employee must stay home until cleared for physical PRIOR to disinfection. return to the workplace by their medical provider, – For disinfection, use only EPA-registered disin- following the CDC’s Discontinuation of Isolation for fectants on List-N. Persons with COVID -19 Not in Healthcare Settings. • For transparency, each contractor should notify the • If an employee tests positive: client of the situation (involving your HR profes- – Follow federal, state, and local recommenda- sional to ensure privacy requirements are followed tions for reporting and communicating cases, and maintained). while remaining compliant with regulations and • Employer Human Resources engages to provide guidelines pertaining to protecting private health supportive care to worker and family. information such as confidentiality required by the Americans with Disabilities Act (ADA). See • Follow CDC guideline and exposure protocol for OSHA for guidance on reporting workplace ex- Critical Infrastructure Workers. posures to COVID-19. – CDC interim guidance

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Enhanced Cleaning and Disinfecting Practices • Any reused cloth materials should be washed and • Select appropriate disinfectants – consider effec- dried on the highest temperature setting allowable tiveness and safety. for the fabric. • Deeper cleaning and disinfecting protocols should – The U.S. Environmental Protection Agency (EPA) be developed and implemented in cases where has developed a list of products that meet EPA’s confirmed cases of COVID-19 are discovered. Re- criteria for use against SARS-CoV-2. fer to AIHA’s Workplace Cleaning for COVID-19. – Do not mix different EPA registered chemicals • Provide Safety Data Sheets (SDS) for cleaning and together. The combination could be toxic by in- disinfection products and ensure employees are halation. Be particularly careful when using any aware of the hazards of use. Incorporate new haz- products containing ammonia, sodium hypochlo- ards into existing OSHA Hazard Communications rite (bleach), or hydrogen peroxide. Program. – Review product labels and Safety Data Sheets • Employees should receive, at minimum, awareness (SDS) and follow manufacturer specifications for training on cleaning and disinfection products used cleaning/disinfecting. in the workplace following OSHA Hazard Commu- – Consider consulting an Occupational and En- nication Standards. For employees who will use vironmental Health and Safety (OEHS) Science cleaning and disinfecting products, training should Professional or Industrial Hygiene expert if addi- also include proper use, PPE, disposal, and all pre- tional advice is needed. AIHA has a consultants cautionary measures. list of such qualified professionals. Ventilation • Establish a disinfection routine. • Provide natural ventilation by opening windows – Ensure disinfection protocols follow product in- and doors whenever possible to increase air flow. structions for application and contact time. All If windows and doors cannot remain open, provide items should be allowed to dry thoroughly after good indoor air quality by: cleaning and disinfecting. – Keeping HVAC system operational to maintain – Use disposable wipes or rags when available. If thermal comfort and maximize outdoor air based not available, ensure rags are maintained, han- on system design. dled, and cleaned per product instructions. – Maintaining the relative humidity at 40-60%. • Consider developing a standard operating proce- – Limiting the use of portable pedestal or overhead dure, a checklist, or audit system to consistently ceiling fans. train employees on enhanced cleaning and disin- • If you need assistance on HVAC issues, ask an HVAC fecting practices or to track when and how clean- professional and see the American Society of Heat- ing and disinfecting is conducted. Note that this ing, Refrigerating, and Air-Conditioning Engineers’ may be a requirement in some states or local juris- (ASHRAE) COVID-19 (Coronavirus) Preparedness dictions. Resources updates for more information. • Single-use items and used disinfection materials – AIHA Occupational and Environmental Health can be treated as regular waste, following regular and Safety (OEHS) Science Professionals and in- safety guidelines. dustrial hygienists are also well versed in general

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dilution ventilation. AIHA has a consultants list of • Businesses and employers should work with HVAC such qualified professionals. professionals to ensure that bathrooms are well Restrooms (NOTE: See Supplement guidance on ventilated, and if filtration is used, that proper fil- use of air dryers) tration practices are being followed. • Post signage limiting restroom occupancy to allow • Increase frequency and efforts to keep bathrooms for proper physical distancing and to remind em- clean and properly disinfected and maintain a re- ployees and visitors to wash hands before and af- cord of sanitary work practices. ter using the restroom. • Minimize touchpoints entering and existing re- What should an Employee do to strooms, if possible. protect themselves? • If the door cannot be opened without touching • Employees should evaluate their health continu- the handle, provide paper towels and a trash can ously; if they are sick, have a fever or symptoms, by the door so a paper towel can be used when or someone at home is sick, then they should re- touching the handle and then discarded. main home. NOTE: Employer HR Policies, HIPAA guidelines and other laws should be followed at – Consider controlling access to bathrooms with a all times. key so disinfection measures can be better man- aged. If a key is used, consider disinfecting it af- • If an employee tests positive for COVID-19: ter each use. – Stay home and isolate until cleared for physical • Doors to multi-stall restrooms should be able to return to the workplace by your medical provider, be opened and closed without touching handles if following the CDC’s Discontinuation of Isolation possible. for Persons with COVID -19 Not in Healthcare Settings. • Place signs indicating that toilet lids (if present) should be closed before and after flushing. – Contact your supervisor and report your results as soon as possible. • Use no-touch faucets, towel dispensers, soap dispensers, and waste receptacles when possible. – Notify your supervisor about others in the workplace with whom you came into contact. • Hand soap should be readily available for use by occupants. • Depending on local requirements, in alignment with CDC recommendations, wear a cloth or dis- • Provide paper towels and air dryers in restrooms.1 posable face covering whenever physical distanc- – The WHO and CDC currently state that hands ing cannot be maintained (indoors or outdoors). can be dried using a paper towel or hand dryer. Ensure the face covering is properly maintained – Due to current uncertainties surrounding the and cleaned. Additional information on cloth face transmission of SARS-CoV-2, care should be coverings can be found on CDC’s website. (NOTE: taken when using a hand dryer or paper towel. Cloth or disposable face coverings primarily protect other people. A cloth or disposable face cov- – The use of touch or push hand dryers is discour- ering is not a substitute for physical distancing.) aged due to possible surface contamination. If hand dryers are used, consider touchless devices. 1NOTE VERSION CHANGE: In version 1 of this guidance document, in the section titled “Restrooms” it stated to disconnect or tape off the hand dryer. NOTE: See Supplement guidance on use of air dryers.

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• Maintain cloth or disposable (or better if you have and before eating. Avoid touching eyes, nose, or it) face covering, clean or replace frequently, and mouth with unwashed hands. use at minimum when unable to maintain physical • Maintain good hygiene practices (washing hands distancing of 6-feet. with soap and water for 20 seconds or a hand • With the exception of children less than two, and in- sanitizer with at least 60% ethanol or 70% isopro- dividuals who have difficulty breathing, are uncon- pyl alcohol). For more information, refer to CDC‘s scious, or otherwise unable to remove a face cov- handwashing guidelines. ering without assistance, CDC recommends that all • If an employee tests positive for COVID-19: people wear a cloth or disposable face covering in public settings and when around people who don’t – Stay home and isolate until cleared for physical live in their household, especially when other physi- return to the workplace by your medical provider, cal distancing measures are difficult to maintain. following the CDC’s Discontinuation of Isolation for Persons with COVID -19 Not in Healthcare • Non-medical cloth or disposable face coverings Settings. or masks are NOT Personal Protective Equipment (PPE), but they do offer some protection to oth- – Contact your supervisor and report your results ers and should be worn while near other people in as soon as possible. common spaces or shared workspaces. They are – Notify your supervisor about others in the work- not a substitute for physical distancing, engineer- place with whom you came into contact. ing controls, cleaning and disinfecting, proper hy- • Let your employer know if you have concerns about giene, or staying home while sick. personal protective equipment (PPE) that may be • Remove cloth or disposable face coverings correct- provided to you and that you are properly instruct- ly and wash hands after handling or touching a ed on how to use it. The CDC has recommended used face covering. sequences for donning and doffing PPE. • Wash cloth face coverings after each use. Cloth Worker Rights face coverings can be included with regular laun- AIHA believes that basic protections are worker dry. Use regular laundry detergent and the warm- rights, as well as an essential ingredient of occupa- est appropriate water setting for the cloth used to tional health and safety systems, and that employers make the face covering. Use the highest heat set- must provide a safe and healthful work environment. ting and leave in the dryer until completely dry. If air drying, lay flat and allow to completely dry. If possible, place in direct sunlight. Resources NOTE: If an employer chooses to provide or the em- • AGC: The Construction Association – Pro- active ployee supplies their own N95 respirator, please Measures for Addressing COVID-19 / Pre-Screen- fully consider all the potential OSHA requirements. ing Questionnaire

• At minimum, employees should wash their hands • AGC: The Construction Association - COVID-19 after they have been in a public place, after touch- Recommended Practices for Construction Job- ing their face covering, after blowing their nose, sites coughing, or sneezing, after using the restroom, • Cybersecurity and Infrastructure Security Agency after touching any common contact surfaces, CISA resource on Critical Infrastructure Workers

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• CDC Health Screening “Should we be screening to COVID-19: Recovering from COVID-19 Building employees for COVID-19 symptoms?” section of Closures and Workplace Cleaning for COVID-19. General Business Frequently Asked Questions • American Cleaning Institute’s COVID-19 Resources • Numerous wellness questionnaire examples are • AIHA’s Considerations on the Safe Use of UVC Ra- available online (e.g., South Dakota Department diation of Health’s COVID-19: Employee Screening Ques- tions and Guidelines) • AIHA’s Focus on Construction Health: COVID-19 • The EPA has developed a list of disinfectants for • AIHA’s Effective and Safe Practices: Guidance for use against SARS-CoV-2. Custodians, Cleaning and Maintenance Staff • American Society of Heating, Refrigeration, • AIHA’s Employers Guide to COVID-19 Cleaning & Air-conditioning Engineers ASHRAE COVID 19 re- Disinfection in Non-Healthcare Workplaces source for ventilation • AIHA’s Reducing Risk of COVID-19 Using Engi- • CDC Interim Critical Infrastructure Guidelines neering Controls • Foundation for Manufacturing Excellence’s • AIHA’s PPE for SARS-CoV-2 COVID-19 Guidance & Resources for Small and • AIHA’s Use of Real Time Detection Systems Medium Manufacturers • AIHA’s Proper Use of Respirators for Healthcare • AIHA’s Indoor Environmental Quality Committee Workers & First Responders developed these guidance documents about re- • AIHA’s Workers Rights White Paper opening and cleaning buildings after closures due

Disclaimer

AIHA is not legally responsible and shall be held harmless from all claims, causes of action, and demands, whatsoever, any third party may incur on account of damage, loss or injury resulting from adhering to these guidelines.

These guidance documents were primarily developed for those smaller business that don’t have readily available occupational health and safety resources, and designed to help business owners, employers, employees and consumers implement science-backed procedures for limiting the spread of the coronavirus. They are subject to any local, state, or federal directives, laws, or orders about operating a business and should only be used if they do not conflict with any such orders. These documents are subject to revision and shall be updated accordingly.

AIHA makes no representations or warranties of any kind concerning its Copyrighted Material, either express or implied, including without limitation any implied warranties of merchantability, title, infringement or fitness for a particular purpose. AIHA shall be indemnified, defended and held harmless by all third parties and their directors, officers, agents, employees and assigns, and anyone authorized by any of them, from and against any and all claims, liabilities, losses and damages, including reasonable attorneys’ fees, caused by or arising wholly or in part from the use of the Copyrighted Material.

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AIHA® About Occupational and Environmental AIHA is the association for scientists and profession- Health and Safety Professionals als committed to preserving and ensuring occupa- Occupational and environmental health and safety tional and environmental health and safety (OEHS) (OEHS) professionals (also known as industrial hy- in the workplace and community. Founded in 1939 gienists) practice the science of anticipating, recog- ® as the American Industrial Hygiene Association nizing, evaluating, controlling and confirming work- ® (AIHA ), we support our members with our expertise, place conditions that may cause workers’ injury or networks, comprehensive education programs and illness. Through a continuous improvement cycle of other products and services that help them maintain planning, doing, checking and acting, OEHS profes- the highest professional and competency standards. sionals make sure workplaces are healthy and safe. More than half of AIHA’s nearly 8,500 members are Certified Industrial Hygienists (CIH), and many hold • Get additional resources at AIHA’s Coronavirus other professional designations. AIHA serves as a re- Outbreak Resource Center. source for those employed across the public and pri- • Find a qualified industrial hygiene and OEHS pro- vate sectors, as well as to the communities in which fessionals near you in our Consultants Listing. they work. For more information, visit AIHA.org.

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Guidance Document Returning to Work: Small Manufacturing, Repair and Maintenance Shops

CommunicationCommunication

PostersPosters that that are visibleare visible through throughthe workspace the for workspace general public for and general employees public or as a quick and take employees‐away or as a quick take-away.

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