COVID-19 Exposure Control

1) Objective 

a) The purpose of this Exposure Control Plan for COVID-19 is to provide an appropriate mitigation plan to reduce or eliminate COVID-19 exposure potential to employees, subcontractor employees, vendor employees, and guests. As a company, ESCO Group is committed to ensuring the health and safety of all employees, subcontractor employees, vendor employees, and guests.

2) Scope

a) The scope of this Exposure Control Plan for COVID-19 is to use the hierarchy of risk controls to eliminate hazards created by COVID-19 first and foremost, then protect people through the use of administrative controls and personal protective equipment as a last barrier of prevention. 

b) This Exposure Control Plan for COVID-19 will be implemented in conjunction with ESCO Group’s Pandemic Response Program for COVID-19.

3) ESCO Group Management Expectations 

a) Provide a work environment free from all known recognized hazards, COVID-19 specifically for this Exposure Control Plan.

b) Provide the appropriate guidance in respects to this plan to all employees, subcontractor employees, vendor employees, and guests.

c) Provide adequate hand washing facilities to all employees.

i. This may include hand sanitizer when hand washing stations are not present.

ii. Monitor and enforce hand washing expectations set forth by ESCO Group’s COVID-19 safety policy and Centers for Disease Control and Prevention hand washing requirements. 

d) Provide all required or recommended personal protective equipment.  The personal protective equipment may be the following but is not limited to:

i. Safety glasses

ii. Face covering or face masks

iii. Protective face shield

iv. Nitrile or vinyl protective disposable gloves

v. Disposable coveralls 

vi. Kits containing: face covering, disinfecting wipes, disposable gloves, and hand sanitizer will be made available for traveling employees. 

e) Provide a phased return to facilities approach.

i. Employees with essential facility access needs will be allowed to return to the facility provided they adhere to the Employee Expectations listed within this plan. 

ii. Only essential visitors approved by management will be allowed scheduled visits to ESCO Group facilities.

iii. Fitness centers shall remain closed until further notice. 

f) Establish Social Distancing requirements for employees and facilities. 

i. Employees shall maintain a minimum of 6ft Social Distancing practice for all activities.

ii. Employees shall conduct meetings (internal or external) via telecommunication applications rather than in person.

iii. No hand shaking or physical contact for greeting each other or clients. 

iv. Face coverings shall be worn when Social Distancing is not achievable, i.e. traveling in the same vehicle or meeting in person.

v. Common areas (cafeteria, breakrooms, conference rooms, etc.) will be configured to achieve Social Distancing requirements.  Tables will be limited to one person. 

g) Exposure Tracking (Contact Tracing)

i. Provide an exposure tracking program that allows for the proper notification for all affected personnel if a person does have a confirmed positive COVID-19 diagnosis. 

h) Review this plan frequently and provide updated guidance to all applicable personnel. 

4) Employee Expectations

a) Perform a Personal Exposure Assessment in accordance to ESCO Group’s Pandemic Response Program for COVID-19, i.e. employee shall not report to work with any illness, whether COVID-19 related or not. 

b) Symptomatic employee shall follow ESCO Group’s Pandemic Response Program for COVID-19 for returning to work. 

c) Follow ESCO Group’s Pandemic Response Program for COVID-19 in response to Personal Contact with Pandemic Infected Person.

d) Remote working will be encouraged for employees that are able to do so and meet client and job requirement needs.  See direct manager for appropriate approval to continue working remotely. 

e) Sanitation and Personal Hygiene 

i. Hand Washing and Sanitizing Process 

• Wash hands in accordance to ESCO Group’s Pandemic Response Program for COVID-19.

a. Employees will be required to wash hands thoroughly (minimum of 20 sec) frequently to reduce personal exposure to pandemic disease.

 Adequate and appropriate hand sanitizing stations will be made available at all work locations where access to hand washing (soap and water) is limited or not accessible.

a. Employees will be encouraged to sanitize hands thoroughly (when hand washing with soap and water not available or easily accessible) frequently to reduce personal exposure to pandemic disease.

 Adequate and appropriate cleaning/sanitizing supplies (as recommended by the CDC) will be made available to assist in frequent cleaning of communicable surfaces (i.e. door handles, conference tables, lunch/break tables) 

f) Social Distancing

• Employees shall maintain a minimum of 6ft Social Distancing practice for all activities.

 Employees shall conduct meetings (internal or external) via telecommunication applications rather than in person.

 No hand shaking or physical contact for greeting each other or clients. 

 Face coverings shall be worn when Social Distancing is not achievable, i.e. traveling in the same vehicle or meeting in person is required.

 Common areas (cafeteria, breakrooms, conference rooms, etc.) will be configured to achieve Social Distancing requirements.  Tables will be limited to one person. Employees shall not move tables and chairs.  

g) Clients and Visitors require management approval prior to reporting to ESCO Group facilities. 

h) Travel Guidelines 

 Employees are permitted work-related travel to designated working locations unless otherwise instructed by the Pandemic Response (COVID-19) Coordinator or a Pandemic Response (COVID-19) Supervisor.  

• Non-essential travel remains halted during the time of pandemic.  This includes all conferences, continuing education, and non-essential job meetings. 

 The appropriate “Essential Services” paperwork shall be acquired from the appropriate authority or client for all travel within states, regions, etc. that have adopted a “Shelter in Place” requirement. See ESCO Group’s Pandemic Response Program for COVID-19 for this documentation if client cannot furnish a copy. 

• Employees will reduce, if possible, the number of travelers per vehicle in effort to ensure appropriate personal/social distancing. All passengers (including driver) shall wear a face covering when more than one person is in a vehicle. 

i) Personal Protective Equipment (PPE)

• Employees will have PPE made available for their use.  PPE supplies will be maintained by ESCO Group to the best of their ability based on availability. 

• The following PPE will be made available to employees: 

1. Safety glasses

2. Face covering or face masks

3. Protective face shield

4. Nitrile or vinyl protective disposable gloves

5. Disposable coveralls 

6. Kits containing: face covering, disinfecting wipes, disposable gloves, and hand sanitizer will be made available for traveling employees. 

 Face Covering Expectations:

1. ESCO employees shall follow the guidelines set forth by the Centers for Disease Control and Prevention for cloth face coverings, see this link: 
https://www.cdc.gov/coronavirus/2019-ncov/prevent-getting-sick/diy-cloth-face-coverings.html

2. ESCO will furnish face masks and face coverings as requested and required by employees and clients.

3. Before donning a face mask or face covering hands shall be washed in accordance to ESCO’s written program.

4. Face masks and face coverings shall be clean prior to donning and cleaned after use.  This may mean cleaning multiple times per shift but at a minimum before the shift begins. 

5. Face masks and face coverings shall be secured to prevent displacement or product contamination. 

6. Face masks and face coverings shall be made of materials that do not contain frays, easily removable pieces, buttons, glue, sequins, other decorations, etc. 

7. Face masks and face coverings shall not create an entanglement hazard.

8. Face masks and face coverings shall be made of materials that are socially acceptable, i.e. free of offensive prints or wording.  Management reserves the rights to deny the use of what they deem inappropriate materials. 

9. Face masks and face coverings shall only be used by one person, i.e. no sharing of face masks or face coverings.  

10. Unattended or unaccounted face masks and face coverings shall be immediately disposed of with a gloved hand.

11. N95 and KN95 respirators are approved face coverings, however, employees shall see the ESCO Safety Department for the proper instruction/procedure prior to donning for work purposes. 

12. No sharing of PPE of any kind will be allowed without appropriate sanitation process. 

5) Pandemic Office/Facilities Phase Guidance:

a) Phase 0:

i. Complete office/facility closure- NO ADMITTANCE- NO DELIVERIES

ii. Facilities doors will remain locked.

iii. Employees are permitted to report to client sites as “Essential Service Provider” so long as the client allows. 

b) Phase 1:

i. Office/Facility open to an employee on a “Need Basis”.

ii. Facilities doors will remain locked, employees shall badge in with each entry. 

iii. Electronic Passive Assessment shall be completed before facility access is granted.

iv. Clients and Visitors require management approval prior to reporting to ESCO Group facilities.  Non-Client visitors (family/friends) not allowed in the facilities. 

v. Deliveries allowed to designated area.  

vi. Conference and fitness rooms closed. Cafeteria tables will allow one person per table (sanitize after use).

vii. No outside or non-work related usage of the building allowed, i.e. reserving the common area for gatherings for non-work related events. 

viii. Criteria to be met by employee: 

• Employee cannot perform essential job duties from their home or remote work location.

Employee to complete ESCO “COVID-19 Passive Screening Questionnaire” before going to a facility.  This shall be completed each day that access is needed to a facility. 

Employees are required to badge into the facility each time that they enter.

Approval received from business unit director.

Complete ESCO’s “Employee Expectations” Training from ESCO’s “Exposure Control Plan”. 

Strictly follows above “Employee Expectations”. Employee’s access WILL be revoked if observed not complying with expectations. 

c) Phase 2:

i. Office/Facility open to an employee on a “Want Basis”.  

ii. Clients and Visitors require management approval prior to reporting to ESCO Group facilities.  

iii. Facilities doors will remain locked, employees shall badge in with each entry. 

iv. Electronic Passive Assessment shall be completed before facility access is granted.

v. Clients and Visitors require management approval prior to reporting to ESCO Group facilities.  Non-Client visitors (family/friends) not allowed in the facilities. 

vi. Deliveries allowed to designated area. 

vii. Conference and fitness rooms open with social distancing precautions and sanitation requirements to be followed. Cafeteria tables will allow one person per table (sanitize after use).

viii. No outside or non-work related usage of the building allowed, i.e. reserving the common area for gatherings for non-work related events.

ix. Criteria to be met by employee:

• Employee to complete ESCO “COVID-19 Passive Screening Questionnaire” before going to a facility.  This shall be completed each day that access is needed to a facility. 

Employees are required to badge into the facility each time that they enter.

Complete ESCO’s “Employee Expectations” Training from ESCO’s “Exposure Control Plan”

Strictly follows above “Employee Expectations”. Employee’s access WILL be revoked if observed not complying with expectations.

d) Phase 3:

i. Office/Facility open to an employee on a “Required to Report Basis”. 

ii. Clients and Visitors require management approval prior to reporting to ESCO Group facilities.  

iii. Facilities doors will remain locked, employees shall badge in with each entry. 

iv. Electronic Passive Assessment shall be completed before facility access is granted.

v. Clients and Visitors require management approval prior to reporting to ESCO Group facilities.  Non-Client visitors (family/friends) not allowed in the facilities. 

vi. Deliveries allowed to designated area. 

vii. Conference and fitness rooms open with social distancing precautions and sanitation requirements to be followed. Cafeteria tables will allow one person per table (sanitize after use).

viii. No outside or non-work related usage of the building allowed, i.e. reserving the common area for gatherings for non-work related events.

ix. Criteria to be met by employee:

 Employee to complete ESCO “COVID-19 Passive Screening Questionnaire” before going to a facility.  This shall be completed each day that access is needed to a facility.

Employees are required to badge into the facility each time that they enter. 

Employee business unit director suspends the work from home or remote work location allowance.
 
Complete ESCO’s “Employee Expectations” Training from ESCO’s “Exposure Control Plan”

Strictly follows above “Employee Expectations”. Employee’s access WILL be revoked if observed not complying with expectations.

e) Phase 4: Office facilities open without restrictions - Pandemic Response lifted.

The goal of the “Phased” approach system is to control the amount of exposure to potentially COVID-19 and other illness infected people for all employees.  The “Phased” system may change as treatment, vaccination, and CDC recommendations are either modified or introduced.

Employees that are classified by the CDC to be “High Risk” will be granted an extended work from home or remote location status as long as recommended by the CDC. 

Employees that are encountering dependent care conflicts may request a further work from home or remote location status from their business unit director.   

6) Client Site Expectations:

a) All “Employee Expectations” listed above apply for all ESCO Group employees working on a client’s site.

b) Client expectations shall be adhered to while on a client’s site.  This may include: active screening processes or passive screening process; additional personal protection requirements; and additional sanitation processes. 

c) Break areas and office trailer areas shall be designed to achieve appropriate social distancing guidelines set forth by the CDC. 

d) Project meetings, safety meetings and team meetings shall be conducted only if social distancing can be achieved or telecommunication can be utilized. 

e) Common areas shall be sanitized frequently (before and after use).

f) Additional hand washing and sanitation access and supplies shall be permitted in the field as long as the client allows.