Jawonio Inc. Hero Act -COVID-19 Occupational Exposure Control Plan

5/3/ 2021 Attachments: A: COVID Task/ Site Assessment B: Respirator Requirement Assessment: C: Jawonio Respiratory Protection Program D: Jawonio Respiratory Protection Program Other Agency References: Jawonio COVID Safety Plan Jawonio COVID-19 Questionnaire (for staff COVID infections)

Introduction: Jawonio’s mission of service charges the organization, its employees and other agency stakeholders, with a responsibility to the people we serve and our community that can potentially involve COVID infection risk. The purpose of this plan is to empower agency workers with information on mitigation strategies and guidance on agency and individual accountability in ensuring the safest possible workplace. SARS-CoV-2 is the virus that causes Coronavirus Disease (COVID-19). A serious disease, it can be particularly deadly to people with underlying health conditions. COVID is transmitted primarily through respiratory droplets from infected persons. These droplets are often expelled by coughing, sneezing or any exhalation by infected persons. Droplets generally land within 2 meters (6 feet) from where they are expelled. COVID can also be transmitted as smaller atomized particles that can remain in the air and stay active in indoor spaces and in air handling systems for longer periods of time. Surfaces where infected particles land can be a route of transmission. As infected surfaces are touched and people touch their faces, they may become infected. Symptoms of COVID can include, but are not limited to, fever, chills, cough, shortness of breath or difficulty breathing, fatigue, muscle or body aches, headache, new loss of taste or smell, sore throat, congestion or runny nose, nausea or vomiting or diarrhea. People infected with COVID may not show symptoms but can, in many cases, infect others. Asymptomatic transmission of COVID is a pervasive hazard characteristic of the disease. Hazard Assessment: The level of risk to Jawonio workers is primarily a function of the known or suspected presence of the disease and whether the requirements of the job tasks the worker performs necessitate their coming in close contact with persons who are, or who may be, infected and thus expose the worker to infected respiratory particles. In addition to the airborne exposure risk, there is also an exposure risk where workers may come in contact with surfaces or touch points where these respiratory particles have landed. As a multifaceted human service organization providing services across a broad spectrum of need, Jawonio staff are exposed to varying levels of occupational infection risk from COVID-19. Those risk levels can and do change as conditions in the community change. The physical environment, the type of work performed, the individual health status of the worker and whether the job task the worker performs requires them to come in close contact with either service recipients or other staff, are all determining factors for the risk to the worker of contracting COVID and/or developing serious COVID disease. Close contact is defined by the CDC as: Someone who has been within 6 feet of an infected person for a cumulative total of 15 minutes or more over a 24-hour period (for example, three individual 5-minute exposures for a total of 15 minutes in one day). The prevalence of COVID in the community is the hazard condition that underlies all other risk factors in the workplace. Ongoing (weekly) tracking of the COVID community spread rates is an essential aspect of the agency’s comprehensive COVID safety plan. All Jawonio staff are trained on the agency COVID safety plan and receive additional training and information specific to their area of agency operations. For example, staff working in programs operating under the egis of the New York State Office for People With Developmental Disabilities (OPWDD) receive regular guidance updates from that office. The agency COVID safety plan is posted on the agency web site and is updated regularly as new information on COVID is made available which includes, but is not limited to, information on emerging hazards and evidence-based mitigation, vaccines, COVID variants and community spread. Given the threat of COVID spread from the community and the vulnerability of persons served and some staff who may have underlying health conditions, workers are charged with adhering to vigilant infection control practices both on and off the job. Classification of Workplace Exposure Risk: OSHA has divided job tasks into four potential risk exposure levels: very high, high, medium, and lower risk, as depicted in the occupational risk pyramid. Jawonio workers run the gamut of these risk categories and their classification can and has changed with the evolving conditions in the community and among the service population. OSHA defines Very High Exposure Risk as: “Jobs with a very high potential for exposure to known or suspected sources of SARS-CoV-2 during specific medical, postmortem, or laboratory procedures. At Jawonio, Very High Risk is defined as job tasks that require that workers are in contact with people who are known or suspected to be infected with COVID-19. Theses workers are subject to the agency Respiratory Protection Program. OSHA defines High Exposure Risk as: Jobs with a high potential for exposure to known or suspected sources of SARS-CoV-2. OSHA examples workers as transportation or other staff who, similarly are in enclosed spaces with either coworkers or service recipients and have frequent close contact. Jawonio defines High Risk as staff with contact with the public, service recipients or other workers in other than well-ventilated spaces or where individuals are either not able to wear masks properly or they cannot socially distance. Workers at Jawonio who must provide personal care tasks like bathing, dressing, changing or similar tasks (where COVID is not known to be present i.e. has not been detected by the health screening processes in place) are in this category. Medium Exposure Risk according to the OSHA, are jobs that may require either frequent close contact (within 6 feet for a total of 15 minutes or more over a 24-hour period) or sustained close contact with other people in areas with community transmission. OSHA examples Medium Exposure Risk as retail or grocery workers. Jawonio defines Medium Exposure Risk as workers who may have some close contact with visitors, service recipients or other workers but whose job task/ work situation mostly allow for some social distancing. A staff who may be in a public or program area with service recipients or other workers whose task does not require frequent direct contact, are in this category. Lower Exposure Risk (Caution) OSHA defines these jobs are jobs that do not require close contact (within 6 feet for a total of 15 minutes or more over a 24-hour period) with other people. Workers in this category have minimal occupational contact with the public and other coworkers. OSHA examples include: Workers whose jobs are primarily remote or which requires only minimum contact with other coworkers, service recipients or visitors. With all Jawonio workers, it is not the job title or classification but the task that the worker performs that determines their exposure risk. Given the potential for asymptomatic transmission of COVID and depending on the prevalence of COVID, any close contact must be considered a point of potential exposure risk. As all hazard categories are predicated on the potential presence of COVID infection, the probability, and thus overall exposure risk, is largely determined by the presence of the virus in the environment. COVID Hazard Assessment Agency procedure for assessing COVID risk:

• Using the above criterion and the associated questions, managers/ department and/or division heads are responsible for a self-assessment of the occupational COVID risks in their respective work area. Managers should engage workers in this process. • The Agency COVID Risk Management Coordinator(s) will evaluate those assessment responses and work with the program to determine the risk profile for the work tasks and /or for the department based on the agency criterion and OSHA. • The COVID Risk Management Coordinator will then verify that the precautions/controls in place at the respective program including the PPE used by the workers in that section, conform to the risk level. • The program and/or the task risk level category is communicated to the workers in that section along with other worker’s rights information. • As the circumstances change, the managers/site supervisors/ division heads are responsible for keeping the staff in their department informed of any changing risk conditions. • Workers are tasked with doing their part to ensure a safe workplace through vigilant adherence to the mitigation strategies as outlined in the agency COVID safety plan. Controls : Consistent with OSHA’s principles of the hierarchy of controls, Jawonio’s COVID risk mitigation strategy includes a combination of measures including measures to eliminate hazards, engineering controls, workplace administrative policies and practices, personal protective equipment (PPE), and other measures, prioritizing controls from most to least effective, to protect workers from COVID-19.

According to the CDC, the goal of community mitigation efforts is to reduce the rate at which someone infected comes in contact with someone not infected, or to reduce the probability of infection if there is contact. The more a person interacts with different people, and the longer and closer the interaction, the higher the risk of COVID-19 spread.

As an essential service provider supporting people with a variety of needs, many of which necessitate close contact between workers and service recipients, it is essential that any and all effective mitigation strategies are employed with a priority for the most to least effective.

Hazard elimination measures: For all workers, regardless of specific exposure risks, according to OSHA, it is always a good practice to:

▪ Wear cloth face coverings, at a minimum, at all times when around coworkers or the general public. If a respirator, such as an N95 respirator or better, is needed for conducting work activities, then that respirator should be used, and the worker should use their cloth face covering when they are not using the respirator (such as during breaks or while commuting). Note that for workers to wear respirators, they must have a medical evaluation and must be fit tested consistent with the agency’s respiratory protection program. It is therefore essential that the potential need for respirator protection must be anticipated and the necessary planning and forethought applied by the program. ▪ Frequently wash your hands with soap and water for at least 20 seconds. When soap and running water are not immediately available, use an alcohol-based hand sanitizer with at least 60% ethanol or 70% isopropanol as active ingredients and rub hands together until they are dry. Always wash hands that are visibly soiled. ▪ Avoid touching your eyes, nose, or mouth with unwashed hands. ▪ Practice good respiratory etiquette, including covering coughs and sneezes or coughing/sneezing into your elbow/upper sleeve. ▪ Avoid close contact (within 6 feet for a total of 15 minutes or more over a 24-hour period) with people who are visibly sick and practice physical distancing with coworkers and the public. ▪ Stay home if sick. ▪ Recognize personal risk factors. According to the U.S. Centers for Disease Control and Prevention (CDC), certain people, including older adults and those with underlying conditions such as heart or lung disease, chronic kidney disease requiring dialysis, liver disease, diabetes, immune deficiencies, or obesity, are at higher risk for developing more serious complications from COVID-19. Note also that persons with Cerebral Palsy, Epilepsy, Intellectual and/or Developmental Delays are also at heightened risk. ▪ Get tested. Staff are strongly encouraged to get tested. Either after travel, after contact with others, or just on a regular basis. Testing is free and available through the Cornerstone Clinic or the worker can find testing through their primary health care provider. The agency can and will provide information on other testing resources as well at the request of the worker. ▪ Tracing: Workers are encouraged to maintain a log or mental note of where they have been and in whom you may have had close contact. All staff are required to participate in contact tracing efforts. ▪ Report: All exposures and/or positive tests must be reported to the agency. Note the agency health screening process and incident reporting requirements. ▪ Vaccination: All staff are encouraged to be vaccinated subject to New York State’s order of selection process. Arrangements for vaccine appointments can be made through the agency human resources department. Workers who have any uncertainty about getting vaccinated for COVID-19 are strongly encouraged to consult with their primary health care providers. Informational session are available to workers on vaccine safety. Additional vaccine safety data is available to workers upon request from the agency Human Resources Department.

Jawonio hazard mitigation/ elimination measures: • Vaccination- the agency encourages service recipients and staff to be vaccinated for COVID- 19 and facilitates vaccination access. Vaccinations are voluntary, free and made available on a continuous basis so that workers can get vaccinated. Vaccination safety and efficacy testing has been shown to effectively mitigate the potential for contacting serious COVID disease with a minimum of harmful side-effects. Vaccine appointments may be limited because of the high demand in the community and are contingent on the worker meeting the vaccine eligibility criterion though any work at Jawonio at elevated risk for occupational exposure is in 1a vaccine priority category. The agency provides informational sessions with medical professionals through the agency’s FQHC partner. Workers with questions about their eligibility or concerning vaccine safety or availability can consult with the agency Human Resources Department. Jawonio does not discriminate against workers who are not vaccinated nor does it distinguish between vaccinated and unvaccinated workers. All workers, without regard to their vaccination status, are required to strictly adhere to all agency control measures including, but not limited to, wearing masks, abiding by occupancy restrictions, maintaining social distance and adhering to protocols for common touch points and spot cleaning. Workers are afforded 2hrs of paid time to get vaccinated or 4hrs today for a 2-shot vaccination. • Face coverings are required at all agency sites during COVID pandemic conditions. It is further required that they be worn properly (in a manner consistent with agency training) and that they be of a type either provided by the agency or which offers the same level of protection to the worker if the worker chooses to provide their own. Where feasible (as in private offices or in open outdoor spaces), workers can remove their masks at their desks or outside so long as contact with others is minimized and appropriate distancing is maintained. Workers are discouraged from eating together and should cooperate with other staff to stagger lunch breaks to avoid congregating at any time where people may need to remove their masks. Masks are among the most important safety tools in preventing COVID spread but alone they do not guarantee that a worker is safe from COVID exposure. Effective COVID mitigation requires that a combination of as many measures as possible are employed to avoid infection spread. • Health screenings are at all work and program sites- Please refer to the agency COVID Safety Plan for screening procedures. • Testing- Regular (voluntary) testing of service recipients and workers is available on a continuous basis through the agency’s FQHC partner, Cornerstone Family Health and informational resources for other community testing sites are also available. Testing is voluntary, however, testing is or may be, a determinate in the agency quarantining requirements. Note that a negative test is not a guarantee that someone is not capable of transmitting the disease and so agency COVID precautions are required whether the worker has been recently tested or not. • Cohorting- Where possible, strategies are employed to minimize the circle of contacts between persons. Example: Where possible service recipients in Day Habilitation are not intermingled but stay with their residence cohort. Staff similarly, when ever possible, work at one site with on group of service recipients. • Isolation -Infected or potentially infected workers are directed not to come to work and provided paid time off as appropriate. If a worker develops symptoms during the workday, they are required to isolate from other workers and are directed to leave work as directly as possible. • Isolation -Infected service recipients are sent home or, in the case of the Community Living Service, isolated from other residents with quarantine measures. • Quarantining for agency workers who have had COVID, had a positive test, had contact with a known of suspected case of COVID-19 or who have traveled, must adhere to the mandates of their respective area of agency operations. For example, staff working in Community Living Service programs must minimally quarantine in a manner consistent with OPWDD quarantining mandates. Workers in programs regulated by SED, OMH must similarly quarantine according to the respective mandates of the governmental agency under whose egis they operate. For the most part, overall agency quarantining policies are consistent with OPWDD mandates. Workers are provided with paid time off for isolating. • Day services (Day Habilitation, PROS, Pre-School, Early Intervention, Clinic, etc) and other in- person services are closed or limited in response to outbreaks as appropriate. Refer to departmental policies and procedures. • Occupancy reductions: Occupancy reductions to all but residential facilities, are put in place in response to COVID outbreaks consistent with the requirements of New York State Executive Orders and the mandated of New York Forward, to facilitate social distancing. • The COVID prevalence in the community is tracked on an ongoing basis through state, local and national dashboards. • Workers, service recipients and other stakeholders are provided regular communications from the agency CEO on outbreak conditions in the community and in the workplace. They are also provided timely information on COVID testing resources and on vaccination availability, safety and access.

Engineering Controls:

• Disinfecting:

• Cleaning and disinfecting regimens throughout the agency are as appropriate for that program/ worksite. In all cases, cleaning and disinfection will conform to the OSHA recommendations (reference OSHA 3990). On discovery of a COVID-19 positive case within our buildings, all areas will be disinfected by our cleaning company and/or maintenance department. Areas are sanitized as soon as feasibly possible. Disinfecting cleaning products are maintained at each location and will be readily available for use but are secured to prevent accidental contact. Most cleaning and disinfecting activities are carried out by maintenance workers and cleaning crews specifically trained in the use of these chemicals. In the cases where other workers use cleaning products to spot clean touch points and/or situationally clean up after service recipients, they are directed to refer to product labels and safety data sheets for safety information. Reviewing product labels and safe storage and use of cleaning material is part of on-site staff orientation training. Cleaning products used: Clorox 360 EPA # 67619-38, Ecolab A456 EPA# 6836-78-1677 , Free’N Clear EPA # 1839-83-4238 Ventilation: Where possible air handling systems are set to minimize air recirculation. Visitation in some programs is encouraged in either out-doors or in spaces that are open and well ventilated. Where feasible in agency residences, bedroom are aired out with windows openned when unoccupied. Air Filtration: According to the US Environmental Protection Agency (EPA)” When used properly, air cleaners and HVAC filters can help reduce airborne contaminants including viruses in a building or small spaces.” Facility air filtration systems:

• Administration building: GPS-IMOD system plus portable Bissell units 220/320/400 in EI class rooms • Katzen school uses the I-Waves system • ICF and IRA residences we are using I-waves and portable Bissell units 220/320/400 • Nyack studio arts : Bissell 400 units • The Yonkers facility has the Halo LED system

Barriers: Where appropriate and practical, Jawonio has placed partitions at reception and screening sites.

Hand sanitizing stations: Hand sanitizer stations are placed at locations convenient to workers at all Jawonio public facilities. At residences, depending on the size and number of residents and staff, hand sanitizer is available but in locations safe from accidental ingestion by service recipients.

Administration Controls:

Tracking the Community Spread Risk:

Jawonio tracks the community spread risk through the New York Forward dashboard, the Rockland County COVID dashboard, the Westchester County COVID dashboard and other trusted sources including the CDC web site and the John’s Hopkins COVID tracker. Weekly reports are generated which focus on zone restrictions, hot spots and trends which may impact the risk of COVID infection to workers.

Training: All Jawonio staff are trained on the agency COVID safety plan. Staff with higher exposure risk are provided more extensive training including the use of PPE. Note the agency respiratory protection program. Maintenance and cleaning staff are trained on safe work practices for COVID prevention and also in the safe handling of cleaning chemicals. Staff are also trained on the appropriate donning and doffing of PPE, on its safe storage, cleaning (as appropriate) and disposal. Social distancing: Jawonio staff are directed to maintain a minimum of a 6’ distance from other workers (or the distance currently recommended by the CDC and/or consistent with the distancing guidelines of the applicable regulatory agency for that area of agency operations) and/or service recipients or visitor when ever possible or practical. Hand washing/ respiratory etiquette- information on hand washing, respiratory etiquette and all other community COVID mitigation practices are provided to agency workers. Handwashing reminders and other communication measures are ever-present in the Jawonio workplace. Hazard signage: Covid hazard signage, access warnings and screening and safety positing are in every Jawonio facility. Sites with COVID present are marked at entryways.

Tracing:

Workers are encouraged to maintain a log or mental note of where they have been and in whom they may have had close contact. All staff are required to participate in Department of Health contact tracing efforts.

Reporting:

All Jawonio agency staff COVID infections/ positive tests are reported and tracked through the Human Resources Department.

All exposures and/or positive tests are reported to the agency. Infections of service recipients are reported through the respective regulatory agencies governing that area of agency operations.

Personal Protective Equipment: PPE-All Jawonio staff who work in areas where there is an exposure risk from COVID-19 are provided with Personal Protective Equipment (PPE) appropriate to the risk and job task. Staff working with active COVID or with persons who have tested positive for COVID are designated as being at Very High exposure risk. These staff are trained and outfitted consistent with the agency’s respiratory protection program. Respirators, coverings, face shields and gloves are provided and worn by staff qualified by the respiratory program. Workers at High or Medium COVID exposure risk are provided with PPE including gloves and facemasks, typically, surgical or KN95 type and non-latex examination gloves. All staff including workers designated at Low risk for COVID exposure are provided with PPE if they work on site. “Community Protective Equipment”: All Jawonio staff are provided training on the agency COVID safety plan and required to wear provided face coverings in any all Jawonio facilities. Jawonio staff who work in individual offices are permitted to remove their facemasks at their desks but are encouraged to keep their doors either closed or left only slightly ajar. Staff working in common spaces are encouraged to keep their face coverings on as much as is tolerable. Face covering protect others and may also provide some protection to the wearer. They are especially important in any situation where persons cannot maintain a 6’ distance.

Worker’s Protection Policies:

1. Workers at higher risk for severe illness : As a 24/7 provider of essential supports to vulnerable persons, the duty to care for the people entrusted to the agency requires that staff provide the essential services that service recipients need when they need it. This includes the provision of service under a state of emergency. Such that accommodations can be made to workers at higher risk from COVID due to underlying health conditions, however, the agency provides those accomodations in the form of alternate duty whenever possible. 2. Workers are offered training, safety and any other important agency information, in languages other than English (including, but not limited to, Spanish, Haitian Creole, American Sign Language and any other as requested) and are encouraged to avail themselves of these resources to ensure their safety, productivity and full inclusion in the workplace. 3. All workers are mandated to self-report if they are sick, if they have been exposed to COVID or if they have reason to believe that they may have been exposed to COVID. Note the agency procedures for reporting COVID. 4. Jawonio workers are trained on their rights as agency employees during their orientation training. Updates on policies and procedure as they pertain to an evolving state of emergency, as with the COVID-19 pandemic, workers receive on an ongoing basis. Information on worker’s rights are also included as part of these COVID trainings. Jawonio managers are trained on workplace flexibility policies related to COVID safety, the agency non-retaliation policies and worker’s rights with respect to reporting COVID infection, testing or vaccination. 5. Workers who are infected or potentially infected with COVID-19 are required to stay home and isolate or quarantine to prevent or reduce the risk of transmission of the virus. Jawonio’s work absence policies are non-punitive. Workers are strongly encouraged to stay home when sick or when they have been exposed to COVID-19.

6. Where feasible, workers who may be exposed to COVID can telework or work in an area isolated from others. If that option is not possible, workers can use paid sick leave.

7. Isolating workers who show symptoms at work. Workers, service recipients or visitors who appear to have symptoms upon arrival at a Jawonio site or who develop symptoms during their time at a Jawonio site are immediately separated from others and either sent home (example: pre-school) or isolated in an area designated as Very High Risk.

8. Providing guidance on screening and testing: All persons entering a Jawonio site and all residents every day are screened according to state and local Department of Health guidelines and/or screened according to the regulatory requirements for the programmatic area under whose egis that area of agency operations operates. Testing is available on site at the agency’s administrative building through our partnering FQHC Cornerstone Family Health. Information on other testing sites is available through the agency Human Resources Department or through the Site Director. Note: Performing screening or health checks is not a replacement for other protective measures such as face coverings and physical distancing. Asymptomatic individuals or individuals with mild non-specific symptoms may not realize they are infected and may not be detected during through screening. 9. Recording and reporting COVID-19 infections and deaths: All COVID-19 illness Must be reported to the Jawonio Human Resource Department. Note the required: Form 300 logs if the following requirements are met: (1) the case is a confirmed case of COVID-19; (2) the case is work-related (as defined by 29 CFR 1904.5); and (3) the case involves one or more relevant recording criteria (set forth in 29 CFR 1904.7) (e.g., medical treatment, days away from work). The agency must follow the requirements in 29 CFR 1904 when reporting COVID-19 fatalities and hospitalizations to OSHA. Note the OSHA website: on OSHA's website. Jawonio must also report outbreaks to local health department as required and support their contact tracing efforts. Note also the additional departmental reporting requirements through the respective governing agencies: OMH, SED, OPWDD. In addition note that: OSHA Section 11(c) of the Act and, 29 CFR 1904.35(b) prohibits discrimination against an employee for reporting a work-related illness. 10. Implementing protections from retaliation and setting up an anonymous process for workers to voice concerns about COVID-19-related hazards: Jawonio has a non- retaliation policy for COVID reporting. Note that Section 11(c) of the OSH Act prohibits discharging or in any other way discriminating against an employee for engaging in various occupational safety and health activities. Under the OSHA standard for example, employers may not discriminate against employees for raising a reasonable concern about infection control related to COVID-19 to the employer, the employer's agent, other employees, a government agency, or to the public, such as through print, online, social, or any other media; or against an employee for voluntarily providing and wearing their own personal protective equipment, such as a respirator, face shield, gloves, or surgical mask.

Jawonio workers are afforded a right to a safe and healthful work environment as a matter of OSHA regulation and agency policy. Workers who have questions or concerns about workplace safety and health or about their right against retaliation for raising workplace safety and health concerns or engaging in other protected occupational safety and health activities, can contact their supervisor, division head or the Compliance Department.

11. The COVID vaccine is available to all Jawonio workers and all workers are encouraged to get vaccinated (service recipients are also encouraged to be vaccinated). Vaccination information is provided through agency sponsored informational sessions. Vaccine appointments can be made through the agency Human Resources Department and other vaccine resources including neighborhood pop up clinics and other vaccination sites that may be convenient to workers, are communicated by the agency. 12. Jawonio does not discriminate against workers who are not vaccinated: Workers who are vaccinated must continue to follow the same protective measures, such as wearing a face covering and remaining physically distant because at this time, there is not substantive evidence that COVID-19 vaccines prevent transmission of the virus from person-to-person. Jawonio’s COVID restriction for vaccinated persons will follow the latest CDC guidelines. 13. Anonymous reporting process for workers to voice concerns about COVID-19-related hazards: Staff can report COVID or other concerns anonymously through the agency Corporate Compliance/ Incident reporting hotline.

14. Other applicable OSHA Standards: All of OSHA's standards that apply to protecting workers from infection remain in place. These standards include: requirements for PPE (29 CFR 1910, Subpart I (e.g., 1910.132 and 133)), respiratory protection (29 CFR 1910.134), sanitation (29 CFR 1910.141), protection from bloodborne pathogens: (29 CFR 1910.1030), and OSHA's requirements for employee access to medical and exposure records (29 CFR 1910.1020). There is no OSHA standard specific to COVID-19; however, employers still are required under the General Duty Clause, Section 5(a)(1) of the OSH Act, to provide a safe and healthful workplace that is free from recognized hazards that can cause serious physical harm or death.

Attachments:

Attachment A: COVID Task/ Site Assessment: 1. Is COVID actively present or reasonably suspected to be present in the workplace? Y/N 2. Has COVID been present in the workplace in past 30 days? Y/N 3. Are all service recipients, staff and visitors screened before entry? Y/N 4. Have employees been informed about the workplace policy and procedures related to reporting COVID-19 signs and symptoms? 5. Is there anyone quarantining in the workplace? Y/N 6. Is there anyone in the workplace who cannot tolerate a mask or effectively social distance? Y/N 7. Is the anticipated working distance between employees and other individuals modified to accommodate social distancing when possible? 8. Has the workspace been adapted to lower occupancy? Y/N a. Can it be? Y/N b. What percentage of workers work remotely? 9. Do the work tasks require close contact with other people? Transportation work tasks for example involve close contact in an enclosed space. Y/N 10. Are employees and other individuals at the workplace notified when a higher level of protective equipment must be used? (N95 respirator) 11. How are they notified? ______12. Is this policy enforced and clearly communicated to employees and other individuals? 13. Engineering Control: How often is the workplace thoroughly cleaned and disinfected? 14. Have all employees been made aware of the procedure for reporting workplace hazards. 15. Please note here or attach any other pertinent information that would impact the COVID hazard in this area:

Attachment B: Respirator Requirement Assessment:

JAWONIO, INC.

HAZARD IDENTIFICATION AND RESPIRATOR REQUIREMENT ASSESSMENT NOTE: COMPLETE THIS FORM FOR EACH HAZARD IDENTIFIED WHERE RESPIRATORS ARE REQUIRED. PROVIDE A COPY OF THIS FORM TO THE PROFESSIONAL LICENCED HEALTHCARE PROVIDER (PLHCP).

The Program Administrator will select respirators to be used on site, based on the hazards to which workers are exposed and in accordance with the OSHA Respiratory Protection Standard. The Program Administrator will conduct a hazard evaluation for each operation, process, or work area to determine which tasks may expose staff to airborne infectious agents. Facility: ______Location: ______Title/Job Description: ______Prepared by: Date: ______

PART ONE: TASK ANALYSIS Describe task: ______Duration and frequency of respirator use: ______Expected physical work effort: ______Additional protective clothing and equipment to be worn: ______

______Temperature and humidity extremes: ______

PART TWO: HAZARD ASSESSMENT -- Indicate the type of hazard.

□ None. No chemicals used or no □ Voluntary use. Sampling confirms airborne hazards released (dusts, no overexposure, but employees fumes, vapors, gases, mists). voluntarily use respirators for the task. Fit testing recommended, but □ Potential. Chemicals used and not required. airborne hazards released with potential exposures. Respirators may □ Confirmed. Documented be required until monitoring is overexposure to airborne hazards. completed and/or controls installed. Respirators required. Fit testing Fit testing is required if respirators required. are worn.

List Chemicals, documented exposure levels and their permissible exposure limits: ______

PART THREE: RESPIRATOR SELECTED

Indicate respirator □ Chemical gas type, model and brand. Face piece type: □ Other: ______□ Filtering Face piece ______Cartridge type (for Change out Schedule □ Half face vapors): (note: change at (Elastomeric) end of shift unless □ Organic vapor otherwise noted): □ Other: □ Airborne ______Transmitted Infections ______Filter type: Ammonia □ N=Not Oil Resistant: □ N95 □ N99 □ N100 R=Oil Resistant: □ R95 □ R99 □ R100 P=Oil Proof: □ P95 □ P99 □ P100 PART FOUR: MAINTENANCE

Maintenance: Clean daily unless otherwise noted.

Disposal of Respirator: □ Daily □ Weekly □ Other

Disposal of Cartridges/Filters: □ End of Shift □ Weekly Other

Attachment C: Jawonio Respiratory Protection Program

JAWONIO INC.

Respiratory Protection Program

For N95 Respirators used for airborne infectious agents.

Policy: The Jawonio, Inc. Respiratory Protection Program is designed to protect employees by establishing accepted practices for respirator use, providing guidelines for training and respirator selection, and explaining proper storage, use and care of respirators. This program also serves to help the employer and its employees comply with Occupational Safety and Health Administration (OSHA) respiratory protection requirements as found in 29 CFR 1910.134.

Purpose and Applicability: The purpose of this respiratory protection program (RPP) is to maximize the protection afforded by respirators when they must be used. It establishes the procedures necessary to meet the regulatory requirements described in OSHA’s Respiratory Protection standard (29 CFR 1910.134) It is the policy of Jawonio, Inc. to protect the health and safety of its employees by

(1) eliminating hazardous exposures where feasible.

(2) using engineering and administrative controls to minimize hazardous exposures that cannot be eliminated.

(3) using respiratory protection and other personal protective equipment when the frequency and duration of exposures cannot be substantially reduced or eliminated.

I. ASSIGNMENT OF RESPONSIBILITY

A. Employer: Jawonio is responsible for providing respirators to employees when they are necessary for health protection. Jawonio will provide respirators that are applicable and suitable for the intended purpose at no charge to affected employees. Approved expenses associated with training, medical evaluations and respiratory protection equipment will be the responsibility of the Agency.

B. Respiratory Program Administrator and Program Committee: The Program Administrator for Jawonio is Tim Cleary and he is responsible for administering the respiratory protection program in conjunction with the Respiratory Program Committee.

The Respirator Program Administrator and Committee has received appropriate training and is knowledgeable about the requirements of the OSHA Respiratory Protection standard and all elements of the respiratory protection program that need to be implemented to be effective. Jawonio administration has the ultimate responsibility for all aspects of this program and the Respiratory Program Administrator has been given full authority to make the necessary decisions to ensure its success.

Duties of the program administrator and committee include: 1. Identifying work areas, process or tasks that require workers to wear respirators. 2. Evaluating hazards. conducting hazard assessments for selecting appropriate respiratory protection 3. Selecting respiratory protection options. 4. Monitoring respirator use to ensure that respirators are used in accordance with their specifications. 5. Arranging for and/or conducting training. 6. Ensuring proper storage and maintenance of respiratory protection equipment. 7. Conducting qualitative fit testing. 8. Administering the medical surveillance program (medical screening performed by Cornerstone Family Health Centers 9. Maintaining records required by the program. 10. Evaluating the program. 11. Updating written program, as needed.

C. Management: Management is responsible for ensuring that the Respiratory Protection Program is implemented in their assigned work locations. In addition to being knowledgeable about the program requirements for their own protection, supervisors must also ensure that the program is understood and followed by the employees under their charge.

Duties of the supervisor include: 1. Ensuring that employees under their supervision (including new hires) receive appropriate training, fit testing, and annual medical evaluation. 2. Ensuring the availability of appropriate respirators by informing Jawonio Purchasing if supplies are needed.. 3. Being aware of tasks requiring the use of respiratory protection. 4. Enforcing the proper use of respiratory protection when necessary. 5. Ensuring that respirators are properly cleaned, maintained, and stored according to this program. 6. Ensuring that respirators fit well and do not cause discomfort. 7. Continually monitoring work areas /operations to identify respiratory hazards. Once a hazard is identified (TB Positive, COVID 19 Positive / Presumed Positive) implement the program 8. Coordinating with the Program Administrator on how to address respiratory hazards or other concerns regarding this program.

D. Employees

Each employee is responsible for wearing his or her respirator when and where required and in the way they are trained. Employees must also: 1. Care for and maintain their respirators as instructed, guard them against damage, and store them in a clean, sanitary location. 2. Inform their supervisor if their respirator no longer fits well and request a new one that fits properly. 3. Inform their supervisor or the Program Administrator of any respiratory hazards that they feel are not adequately addressed in the workplace and of any other concerns that they have regarding this program. 4. Use the respiratory protection in accordance with the manufacturer’s instructions and the training received.

II. PROGRAM A. Hazard Assessment and Respirator Selection The Program Administrator will select respirators to be used on site, based on the hazards to which workers are exposed and in accordance with the OSHA Respiratory Protection Standard and Centers for Disease Control and Prevention (CDC), Healthcare Infection Control Practices Advisory Committee (HICPAC), and other public health guidelines, to include input from the respirator user, the RPA and supervisor will conduct a hazard assessment for each task, procedure, or work area with the potential for airborne contaminants. The hazard assessment will include the following as needed: • Identification of potential exposures. The most common potential exposure for employees involved in patient care will be pathogens associated with Aerosol Transmissible Diseases ATDs such as tuberculosis. Maintenance, housekeeping, or other staff may have the potential to be exposed to hazardous gases, vapors, or dusts in addition to ATD pathogens. • A review of work processes to determine levels of potential exposure for all tasks and locations.

B. NIOSH-Certified Equipment All respiratory protective equipment shall be approved by the National Institute for Occupational Safety and Health (NIOSH) for the configuration and environment in which it is going to be used. The NIOSH Certified Equipment List is found at the following Internet address: www.cdc.gov/niosh/npptl/topics/respirators/cel.

The following definitions apply to equipment that may be issued to employees under this program: • N95 respirator is a generally used term for a half mask negative pressure air-purifying respirator with NIOSH-approved N95 filters or filter material (i.e., includes N95 filtering facepiece respirator or equivalent protection).

C. Updating the Hazard Assessment The Program Administrator and Committee must revise and update the hazard assessment as needed. If an employee feels that respiratory protection is needed during a particular activity, he/she is to contact his/her supervisor or the Program Administrator. The Program Administrator will evaluate the potential hazard and arrange for outside assistance as necessary. The Program Administrator will then communicate the results of that assessment to the employees. If it is determined that respiratory protection is necessary, all other elements of the respiratory protection program will be in effect for those tasks, and the respiratory program will be updated accordingly.

D. Voluntary Respirator Use The Program Administrator shall authorize voluntary use of respiratory protective equipment as requested by all other workers on a case-by-case basis, depending on specific workplace conditions and the results of medical evaluations.

The Program Administrator will provide all employees who voluntarily choose to wear the above respirators with a copy of Appendix D of the OSHA Respiratory Protection Standard. (Appendix D details the requirements for voluntary use of respirators by employees.) Employees who choose to wear a half face piece APR must comply with the procedures for Medical Evaluation, Respirator Use, Cleaning, Maintenance and Storage portions of this program.

III. Medical Evaluation

Employees who wear respirators must be medically evaluated before being permitted to wear a respirator on the job. Employees are not permitted to wear respirators until a healthcare provider has determined that they are medically able to do so.

A licensed health care professional at Cornerstone Family Health Centers will provide the medical evaluation to employees. Medical evaluation procedures are as follows:

The medical evaluation should not be conducted by the employee’s immediate supervisor and others in the employee’s direct line of authority. The medical evaluation questionnaire will be completed by all affected staff. Medical evaluations will be performed by a physician or other licensed health care professional (PLHCP). • Medical evaluations will be kept on file in Human Resources as part of your personnel file. All examinations and questionnaires are to remain confidential. • To the extent feasible, the company will assist employees who are unable to read the questionnaire. When this is not possible the employee will be sent directly to the health care professional for assistance and medical evaluation. • All affected employees will be given a copy of the medical questionnaire to fill out. Employees will be permitted to fill out the questionnaire on company time. • Follow up medical exams will be provided to employees as required by the OSHA standard, and/or as deemed necessary by the health care professional. • All employees will be allowed the opportunity to speak with the health care professional about their medical evaluation if they so request. • The PLHCP will be provided with a copy of information to the type of respiratory protection to be used by employees, duration and frequency of respirator use, expected physical effort, other protective equipment worn, and any expected extremes of temperature or humidity. • After an employee has received clearance to wear a respirator, additional medical evaluations will be provided under any of the following circumstances: o The employee reports signs and/or symptoms related to their ability to use a respirator, such as shortness of breath, dizziness, chest pains, or wheezing. o The health care professional or supervisor informs the Program Administrator that the employees needs to be reevaluated. o Information from this program, including observations made during fit testing and program evaluation, indicates a need for reevaluation. o A change occurs in workplace conditions that may result in an increased physiological burden on the employee. IV. Fit Testing

Fit Testing Procedures

An assigned Jawonio Registered Nurse at the work location will ensure that fit-test will be administered using an OSHA-accepted qualitative fit test (QLFT) protocol. The OSHA-accepted QLFT protocols are contained in Appendix A of the Respiratory Standard (1910.134).

Jawonio requires employees to be fit tested at the following times and with the same make, model, style, and size of respirator that they will be using.

• Before being allowed to wear any respirator with a tight-fitting facepiece and at least annually thereafter. • Whenever a different respirator facepiece (size, style, model, or make) is used. • Whenever visual observations of changes in the employee’s physical condition that could affect respirator fit. Such conditions include, but are not limited to, facial scarring, dental changes, cosmetic surgery, or an obvious change in body weight. • Upon employee notification that the fit of the respirator is unacceptable. • The company has established a record of the fit tests administered to employees including: o The name or identification of the employee tested o Type of fit test performed o Specific make, model, style, and size of respirator tested o Date of test o The pass/fail results

Use of Respirators

General Use Procedures

Employees will use their respirators under conditions specified by this program, and in accordance with the training they receive on the use of each particular model. In addition, the respirator shall not be used in a manner for which it is not certified by NIOSH or its manufacturer.

All employees shall conduct user seal checks each time that they wear their respirator. Employees shall use either the positive or negative pressure check (depending on which test works best for them) specified in Appendix B-1 of the Respiratory Protection Standard. Facepiece Positive and/or Negative Pressure Checks A. Positive pressure check. Close off the exhalation valve and exhale gently into the facepiece. The face fit is considered satisfactory if a slight positive pressure can be built up inside the facepiece without any evidence of outward leakage of air at the seal. For most respirators this method of leak testing requires the wearer to first remove the exhalation valve cover before closing off the exhalation valve and then carefully replacing it after the test. B. Negative pressure check. Close off the inlet opening of the canister or cartridge(s) by covering with the palm of the hand(s) or by replacing the filter seal(s), inhale gently so that the facepiece collapses slightly, and hold the breath for ten seconds. The design of the inlet opening of some cartridges cannot be effectively covered with the palm of the hand. The test can be performed by covering the inlet opening of the cartridge with a thin latex or nitrile glove. If the facepiece remains in its slightly collapsed condition and no inward leakage of air is detected, the tightness of the respirator is considered satisfactory.

All employees shall be permitted to leave the work area to maintain their respirator for the following reasons: if the respirator is impeding their ability to work, becomes difficult to breathe through, or to inspect respirator if it stops functioning as intended. Employees should notify their supervisor before leaving the area.

Employees are not permitted to wear tight fitting respirators if they have any condition, such as facial hair, facial scars, or missing dentures that prevents them from achieving a good seal. Employees are not permitted to wear headphones, jewelry, or other articles that may interfere with the facepiece to face seal.

N95 Respirators will be disposed of after use if worn in the presence of an individual who has a disease that could be transmitted person to person via an airborne route of exposure. Staff will re-use N95 masks (if site is COVID free) for 5 days. Stored at the site in a labeled brown paper bag and discarded at the site after 5 days.

N95s will be replaced daily when there is a known COVID positive or presumed positive case. Staff will discard their masks daily at the site.

The Program Administrator in conjunction with the worksite supervisor will ensure an adequate supply of respirators are available. If supplies are low, employees should notify their supervisor, who will requisition additional supplies from central distribution.

Training

Respirator training will be provided to respirator users on the contents of the Respiratory Protection Program and their responsibilities under it, and on the OSHA Respiratory Protection Standard (29 CFR 1910.134). Workers will be trained prior to using a respirator in the workplace. Supervisors will also be trained prior to using a respirator in the workplace or prior to supervision of employees that must wear respirators.

The training will cover the following topics:

• The Jawonio Respiratory Protection Program • The OSHA Respiratory Protection Standard (29 CFR 1910.134) • Why the respirator is necessary and how proper fit, usage, and maintenance can ensure the protective effect of the respirator as well as how improper fit, usage or maintenance can compromise the protective effect of the respirator. • Respiratory hazards encountered and their health effects • Proper selection and use of respirators. How to inspect, put on, remove, use, and check the seals of the respirator (for tight-fitting respirators such as N95 filtering facepiece respirators). • Limitations of respirators • Respirator donning and user seal (fit) checks • Fit testing • Emergency use procedures • Maintenance and storage • Medical signs and symptoms limiting the effective use of respirators

Training shall be provided at the time of initial assignment to respirator use, before actual use, and annually thereafter or as needed (e.g., if they need to use a different respirator). Employees must demonstrate, and acknowledge, their understanding of the topics covered. Respirator training will be documented by the Program Administrator and the documentation will include the type, model, and size of respirator for which each employee has been trained and fit tested.

The employee will also receive training during the fit testing procedure that will provide an opportunity to handle the respirator, have it fitted properly, test its facepiece-to-face seal, wear it in normal air to familiarize themselves with the respirator, and finally to wear it in a test atmosphere. Every respirator wearer will receive fitting instructions, including demonstrations and practice in how the respirator should be worn, how to adjust it, and how to perform a user seal check according to the manufacturer’s instructions.

Maintenance and Care Procedures

Respirators are to be properly maintained at all times in order to ensure that they function properly and protect employees adequately. Maintenance involves a thorough visual inspection for cleanliness and defects. Worn or deteriorated parts will be replaced prior to use. No components will be replaced, or repairs made beyond those recommended by the manufacturer. All respirators shall be inspected routinely before and after each use.

Storage

Storage of respirators must be done properly to ensure that the equipment is protected and not subject to environmental conditions that may cause deterioration. We ensure that respirators are stored to protect them from damage, contamination, dust, sunlight, extreme temperatures, excessive moisture, and damaging chemicals. They are packed and stored in a paper bag, in accordance with any applicable manufacturer’s instructions.

Emergency respirators are stored:

• To be accessible to the work area. • In compartments marked as such. • In accordance with manufacturer’s recommendations.

Respirator Inspection

Employees must inspect their respirators before each use. Respirators that are defective or have defective parts shall be taken out of service immediately. Damaged respirators will be replaced. All respirators maintained for use in emergency situations shall be inspected at least monthly and in accordance with manufacturer’s recommendations and shall be checked for proper function before use.

Program Evaluation

The Jawonio Quality Assurance will conduct periodic evaluations of the workplace to ensure that the provisions of this program are being implemented. The evaluation will include regular consultations with employees who use respirators and their supervisors, site inspections, air monitoring and review of records.

Identified problems will be noted and addressed by the Program Administrator. These findings will be reported to management, and the report will list plans to correct deficiencies in the respirator program and target dates for the implementations of those corrections.

Documentation and Recordkeeping

A written copy of this program and the OSHA standard is kept in the Program Administrator’s office, as part of the Policy and Procedure Manual at the worksite and is available to all employees who wish to review it.

• Personnel medical records such as medical clearance to wear a respirator shall be retained by Human Resources as part of a confidential medical record. Medical clearance records must be made available in accord with the OSHA Access to Employee Exposure and Medical Records standard (29 CFR 1910.1020) and maintained for a minimum of thirty (30) years after an employee’s separation or termination. • Documentation of training and fit testing will be kept by Human Resources and on file at the worksite until the next training or fit test. • A copy of this RPP and records of program evaluations and revisions shall be kept by Human Resources and on file at the worksite and made available to all affected employees, their representatives, and representatives of OSHA upon request.

Jawonio

Personnel in Respiratory Protection Program

Date

Respiratory protection is required for and has been issued to the following personnel:

Name Medical Clearance Training Date Respirator Model Date Respirator Fit Test and Size Date

Information for Voluntary Users

Appendix D to Sec. 1910.134: (Mandatory) Information for Employees

Using Respirators When Not Required Under the Standard

Respirators are an effective method of protection against designated hazards when properly selected and worn. Respirator use is encouraged even when exposures are below the exposure limit, to provide an additional level of comfort and protection for workers. However, if a respirator is used improperly or not kept clean, the respirator itself can become a hazard to the worker. Sometimes, workers may wear respirators to avoid exposures to hazards, even if the amount of hazardous substance does not exceed the limits set by OSHA standards. If your employer provides respirators for your voluntary use, or if you provide your own respirator, you need to take certain precautions to be sure that the respirator itself does not present a hazard.

You should do the following:

1. Read and heed all instructions provided by the manufacturer on use, maintenance, cleaning and care, and warnings regarding the respirator’s limitations.

2. Choose respirators certified for use to protect against the contaminant of concern. NIOSH, the National Institute for Occupational Safety and Health of the U.S. Department of Health and Human Services, certifies respirators. A label or statement of certification should appear on the respirator or respirator packaging. It will tell you what the respirator is designed for and how much it will protect you.

3. Do not wear your respirator into atmospheres containing contaminants for which your respirator is not designated to protect against. For example, a respirator designed to filter dust particles will not protect you against gases, vapors or very small solid particles of fumes or smoke.

4. Keep track of your respirator so that you do not mistakenly use someone else's respirator.

______

Name of Employee Signature Date

Attachment D: Human Resources Protocol for COVID Positive Staff

Protocol: COVID positive/presumed positive staff

• Manager/RN Supervisor emails the team (Manager, RN Supervisor, Coordinator, LPN staff, Division Director, Residential Director, Director of Nursing, Director of Day Habilitation; cc HR),

• Manager notifies HR (if you are aware, tell HR the last date the staff worked at the site and the names of the other staff that worked on the same shift)

• Manager notifies advocates/family of the individuals that a staff member tested positive. (no names)

• RN Supervisor ensures required follow up action is taken with individuals (testing and quarantine). RN arranges for Consumers to be tested. Individuals to Quarantine until negative results are received.

• HR completes contact tracing. Notifies staff potentially exposed (within 6 feet and longer than 10 minutes). Keeps Manager up to date regarding staff that were potentially exposed.

• Potentially Exposed staff (as determined by HR’s contact tracing) are advised to be tested and need to Quarantine until they receive a negative test result &/or asymptomatic for 10 days.

• Staff/Supervisor sends COVID test results to HR.

• HR notifies QA.

• QA notifies the Justice Center. • QA & DON have separate reporting requirements.

• HR notifies Manager when staff is cleared to return to work.

Staff exposed to a positive family member, are advised to get tested and must quarantine for 10 days (using their own PTO time) or work remotely if possible.