We’ll begin in just a minute…... Welcome! Thanks for Joining me Today!
THANKS FOR JOINING US! WE’LL GET STARTED PROMPTLY AT 10…
47
THANKS FOR JOINING US! WE’LL GET STARTED PROMPTLY AT 10:00 AM. OUR PREMIUM MEMBERS OUR SELECT MEMBERS
Transcript of THANKS FOR JOINING US! WE’LL GET STARTED PROMPTLY AT 10…
THANKS FOR JOINING US! WE’LL GET STARTED PROMPTLY AT 10:00 AM.
OUR PREMIUM MEMBERS
OUR SELECT MEMBERS
Shelley JurewiczExecutive director
Pat WernerDirector of food safety
OUR PREMIUM MEMBERS
OUR SELECT MEMBERS
Paul Bensonpartner
Chuck Palmerpartner
Dr. Mark RobertsPrincipal scientist
Brian HarmsOffice practice leader
OUR PREMIUM MEMBERS
OUR SELECT MEMBERS
Planning for the Near Future in the COVID-19 Era:A Workforce Protection Program for the
Food & Beverage Industry
May 21, 2020
Chuck Palmer Dr. Mark Roberts Brian Harms
What Are We Up Against?
6
The Cell
SARS CoV-2 Virus
Enveloped Virus – RNA is surrounded by a lipid bilayer, easiest to deactivate (and why soap and warm water is so effective)
What to Look at For Planning
• Transmission (OSHA Focus)• Primary means appears to be micro-
droplets emitted from the upper respiratory tract in infected
• Secondary surface contact not believed to be a primary means of infection – but possible
7
Farm to Fork---Anticipate and AdaptFarm Operations
• 6-foot rule
• Transportation issues
• Protective equipment
• Gloves, Masks and other equipment
• Personal Protective Equipment (PPE)????
• OSHA rules
• Varying State, County and City public health “recommendations”
• Screening – temperature and symptoms
• Who, What, Where, When and most importantly how
8
Processing Facilities—Anticipate and Adapt
• What we see in the food processing industry
• 6-foot rule,
• Masks, etc.
• Community spread vs. spread in the plant
• Screening – temperature and symptoms
• Why may be the route cause of the COVID-19 cases in the workplace
• Community spread that is spilling over
• Workplace noise???
9
Trucking & Transportation
• Driver with symptoms
• Drivers’ potential for exposure
• Screening drivers when they come on site
• Employees, Contractors and Non-employees
• HR issues
• Legal issues
10
Retail Establishments– Anticipate and Adapt
• No indications of transmission via food but potential transmission between customers
• Clean surfaces---disinfectants
• Dealing with the “New Normal”
• Community reaction
• Public Health “Recommendations”
• Public Relation issues
• 6 ft “recommendation”
11
Future
• Vaccine
• Testing
• When and how?
• Screening techniques
• Future is amazing
• Maintaining a healthy workforce
• Alignment between regulations, recommendations and social norms
12
Understand the Work Environment
14
People Places Processes
This is a Paradigm Shift – Typically we are controlling exposures from processes – now we need to evaluate our facility designs and policies to look at controlling exposures from co-workers and visitors. Working with OSHA and Public Health Officials on this change is crucial.
Transmission – Primary & Secondary
15
Primary - Aerosol Secondary? - Surfaces
SARS CoV-2 VirusPresence on Surfaces (imprecise science)
16
Cardboard 24 hours Wood & Metal 4 -5 daysPlastics 2-3 days
Stainless Steel 2-3 days Cups & Glasses 5 daysFabrics – Unknown Thought to be low
What is OSHA Looking For?
• OSHA
https://www.osha.gov/Publications/OSHA3990.pdf
• Develop an Infectious Disease Preparedness and Response Plan
• Prepare to Implement Basic Infection Prevention Measures
• Develop Policies and Procedures for Prompt Identification and Isolation of Sick People, if Appropriate
• Develop, Implement, and Communicate about Workplace Flexibilities and Protections
• Implement Workplace Controls• Engineering Controls• Administrative Controls• Safe Work Practices• Personal Protective Equipment (PPE) • Employee Training
• Follow Existing OSHA Standards
17
Existing OSHA Standards in Play for COVID
• OSHA's Personal Protective Equipment (PPE) standards (in general industry, 29 CFR 1910 Subpart I), which require using gloves, eye and face protection, and respiratory protection when job hazards warrant it.
• When respirators are necessary to protect workers, employers must implement a comprehensive respiratory protection program in accordance with the Respiratory Protection standard (29 CFR 1910.134).
• The General Duty Clause, Section 5(a)(1) of the Occupational Safety and Health (OSH) Act of 1970, 29 USC 654(a)(1), which requires employers to furnish to each worker "employment and a place of employment, which are free from recognized hazards that are causing or are likely to cause death or serious physical harm.“
• OSHA’s Bloodborne Pathogens standard (29 CFR 1910.1030) applies to occupational exposure to human blood … However, the provisions of the standard offer a framework that may help control some sources of the virus, including exposures to body fluids (e.g., respiratory secretions) not covered by the standard.
• Haz Com for Cleaning & Disinfectant Chemicals being used. 29 CFR 1910.1200
https://www.osha.gov/SLTC/covid-19/standards.html
18
Free From Recognized Hazards
19
Implementing Work Place Controls
• Following other OSHA Rules – Put it in a Plan and Implement- OSHA Hierarchy of Controls
1. Elimination
2. Engineering Controls
3. Administrative Controls
4. Personal Protective Equipment
20
Masks & Shields
Barriers
Distancing
Elimination
• What can we do to eliminate the risk?• Tough to do in this case – Vaccine or Shutdown
21
Engineering Controls
• Engineering Controls (Where Feasible)• Physical Barriers• Reconfigure Communal Work Areas• Ventilation
• Zone Balancing• Laminar Downward Flow• Filtration• Personalized Ventilation• HEPA Filters and/or UV-C Bulbs on Air Handlers• Personal Fans Blowing Sideways (Need to try and Avoid)
American Society of Heating, Refrigerating and Air-Conditioning Engineers
“ASHRAE Position Document on Infectious Aerosols”https://www.ashrae.org/file%20library/about/position%20documents/pd_infectiousaerosols_2020.pdf
Wisconsin and Michigan COVID-19 return to work response plans are incorporating this ASHRAE document. 22
Barriers
Administrative Controls• Employers should do the following to promote social distancing:
• Encourage single-file movement with a six-foot distance between each worker through the facility, where possible.
• Designate workers to monitor and facilitate distancing on processing floor lines.• Stagger break times or provide temporary break areas and restrooms to avoid groups of
workers during breaks. Workers should maintain at least six feet of distance from others at all times, including on breaks.
• Stagger workers’ arrival and departure times to avoid congregations of workers in parking areas, locker rooms, and near time clocks.
• Provide visual cues (e.g., floor markings, signs) as a reminder to workers to maintain social distancing.
23
Distancing
Mitigating Surface Transmission
24
Gloves
Washing Hands
Cleaning & Disinfecting Surfaces and Touch Points
Limit Workers Using Stations
Preferred Cleaning & Disinfecting Workflow
25
Confirm Proper Cleaning Protocol,
Develop ATP Threshold & Collect
Pre-clean ATP Samples
Proceed with Cleaning According
to Protocol
Post-Cleaning
Visual Inspection
Develop ATP Sampling Plan
Collect ATP Samples
Apply Disinfectant
Finish Field Documentation
Re-CleanArea
Below Threshold
Visibly Soiled
Visibly Clean
Above Threshold
Threshold Determination – ATP & RLU Units
26This does not test for Covid-19, which is not practical – but rather a test of biological activity/cleanness
Administrative Controls – Car Pooling
• Encourage workers to avoid carpooling to and from work, if possible • If carpooling or using company shuttle vehicles is a necessity for workers, the following
control practices should be used: • Limit the number of people per vehicle as much as possible. This may mean using more vehicles.• Encourage employees to maintain social distancing as much as possible.• Encourage employees to use hand hygiene before entering the vehicle and when arriving at the
destination.• Encourage employees in a shared van or car space to wear cloth masks.• Clean and disinfect commonly touched surfaces after each carpool or shuttle trip (e.g., door
handles, handrails, seatbelt buckles).• Encourage employees to follow coughing and sneezing etiquette when in the vehicle.
CDC Meat-Poultry-Processing Guidancehttps://www.cdc.gov/coronavirus/2019-ncov/community/organizations/meat-poultry-processing-workers-employers.html
27
PPE
• PPE• Face coverings*• Respirators• Face Shields
*Cloth face coverings are not PPE. They are not appropriate substitutes for PPE such as respirators (like N95 respirators) or medical facemasks (like surgical masks) in workplaces where respirators or facemasks are recommended or required to protect the wearer. - CDC
28
Masks & Shields
OSHA Respirator Citation Guidance
1910.134 Citation guidance:
• OSHA will, on a case-by-case basis, exercise enforcement discretion when considering issuing citations under 29 CFR § 1910.134(d) and/or the equivalent respiratory protection provisions of other health standards in cases where:
• The employer has made a good faith effort to obtain other alternative filtering facepiece respirators, reusable elastomeric respirators, or PAPRs appropriate to protect workers;
• The employer has monitored their supply of N95s and prioritized their use according to CDC guidance (www.cdc.gov/coronavirus/2019-ncov/release-stockpiled-N95.html; www.cdc.gov/coronavirus/2019-ncov/hcp/respirators-strategy/index.html);
• Surgical masks and eye protection (e.g., face shields, goggles) were provided as an interim measure to protect against splashes and large droplets (note: surgical masks are not respirators and do not provide protection against aerosol-generating procedures); and
• Other feasible measures, such as using partitions, restricting access, cohorting patients (healthcare), or using other engineering controls, work practices, or administrative controls that reduce the need for respiratory protection, were implemented to protect employees.
https://www.osha.gov/memos/2020-04-03/enforcement-guidance-respiratory-protection-and-n95-shortage-due-coronavirus
29
More on Cloth Face Coverings• A cloth face covering may reduce the amount of large respiratory droplets that
a person spreads when talking, sneezing, or coughing. Employers who determine that cloth face coverings should be worn in the workplace, including to comply with state or local requirements for their use, should ensure the cloth face coverings:• fit over the nose and mouth and fit snugly but comfortably against the side of the face;• are secured with ties or ear loops;• include multiple layers of fabric;• allow for breathing without restriction;• can be laundered using the warmest appropriate water setting and machine dried daily
after the shift, without damage or change to shape (a clean cloth face covering should be used each day);
• are not used if they become wet or contaminated;• are replaced with clean replacements, provided by employer, as needed.• are handled as little as possible to prevent transferring infectious materials to the cloth;
and• are not worn with or instead of respiratory protection when respirators are needed.
30
Charles B. Palmer, Esq.Partner | Sub-Practice Leader, Workplace Safety & Health
262.956.6518
32
33
34
35
36
37
38
County and City Orders Post Supreme Court Ruling
• Brown County – adopted State Rules with penalty for violation
• Dane County & City of Madison – adopted State Rules with 2 exceptions; Dane County also under state of emergency until July 15th
• Kenosha County – adopted State Rules with penalty for violation (withdrawn)
• Milwaukee County Municipalities (Cudahy, Franklin, Greendale, Greenfield, Hales Corners, North Shore, Oak Creek, South Milwaukee, Wauwatosa, West Allis) – Adopted own set of rules
• City of Milwaukee – Adopted own set of rules
• City of Racine - adopted State Rules with 2 exceptions
• Rock County – adopted State Rules
39
40
41
42
43
44
45
46
Thank you!
OUR PREMIUM MEMBERS
OUR SELECT MEMBERS
