COVID-19 Plan

COVID-19 Exposure Reduction, Preparedness, and Response Plan for the School of Skilled Trades

The purpose of this plan is to outline the steps that the School of Skilled Trades and its stakeholders can take to reduce the risk of COVID-19 exposure to students, administrators, instructors and others visiting the School. This plan describes how to reduce exposure to coronavirus, protective measures to be taken at the School, personal protective equipment and controls to be used, cleaning and disinfecting procedures, and what to do if a School employee or student becomes sick.

The School of Skilled Trades takes the health and safety of our employees and students very seriously. With the spread of the coronavirus or “COVID-19,” a respiratory disease caused by the SARS-CoV-2 virus, we all must remain vigilant in mitigating the outbreak. In order to be safe and maintain operations, we have developed this COVID-19 Exposure Reduction, Preparedness, and Response Plan to be implemented throughout the School. We are also trying hard to monitor available U.S. Center for Disease Control and Prevention (“CDC”) and Occupational Safety and Health Administration (“OSHA”) guidance on the virus.

This Plan is based on currently available information from the CDC and OSHA, and is subject to change based on further information provided by the CDC, OSHA, and other public officials. The School may also amend this Plan at any time without notice based on operational needs.

I. Responsibilities of School Leadership

All members of School leadership must be familiar with this Plan and be ready to answer questions from employees and students. Leaders must set a good example by following this Plan at all times. This involves practicing good personal hygiene and safety practices to reduce the spread of the virus. Managers and supervisors must encourage this same behavior from all employees.

II. Responsibilities of Employees and Students

We are asking every one of our employees and students to help with our prevention efforts while at work. In order to minimize the spread of COVID-19, we all must play our part. As set forth below, the School has instituted various housekeeping, social distancing, and other best practices at the campus. All employees and students are strongly encouraged to follow this Plan for their own safety, those of their co-workers and for all of the School’s students. In addition, employees are expected to report to their supervisors and students are expected to notify School administrators and/or instructors, if they are experiencing signs or symptoms of COVID-19, as described below. If you have a specific question about this Plan or COVID-19, please ask your supervisor or instructor.

OSHA and the CDC have provided the following control and preventative guidance to all workers and students, regardless of exposure risk:

Frequently wash your hands with soap and water for at least 20 seconds. When soap and running water are unavailable, use an alcohol-based hand rub with at least 60% alcohol. The School has stocked bathrooms with soap and made hand sanitizer available to all on the campus;

Avoid touching your eyes, nose, or mouth with unwashed hands;

Follow appropriate respiratory etiquette, which includes covering for coughs and sneezes;

Wear a mask if you are a member of a vulnerable population or interact with a member of a vulnerable population (such as those over 60 years of age or those with underlying health conditions); and

Avoid close contact with people who are sick.

In addition, employees and students must familiarize themselves with the symptoms of COVID-19:



Loss of sense of taste or smell;

Shortness of breath, difficulty breathing; and

Early possible symptoms such as chills, body aches, sore throat, headache, diarrhea, nausea/vomiting, and runny nose.

If you develop a fever and symptoms of respiratory illness, such as cough or shortness of breath, DO NOT COME TO CAMPUS and call your healthcare provider right away. Likewise, if you come into close contact with someone showing these symptoms, call your healthcare provider right away and notify your supervisor or instructor.

III. Campus Protective Measures

The School has instituted the following protective measures at the campus.

A. General Safety Policies and Rules

Any employee/student/visitor showing symptoms of COVID-19 will be asked to leave the campus and return home.

If safety meetings are conducted in-person, attendance will be collected orally and someone will sign-in each attendee. Attendance will not be tracked through passed-around sign-in sheets or mobile devices. During any in-person safety meetings, avoid gathering in groups of more than 15 people and participants must remain at least six (6) feet apart.

Employees and students must avoid physical contact with others and politely direct employees, students and visitors to increase personal space to at least six (6) feet, where possible.

Employees and students should limit the use of sharing tools and equipment. To the extent tools must be shared, the School will provide alcohol-based wipes to clean tools before and after use. When cleaning tools and equipment, consult manufacturing recommendations for proper cleaning techniques and restrictions.

Employees and students are encouraged to minimize ride-sharing.

In lieu of using a common source of drinking water, such as a cooler, employees and students should use individual water bottles.

The School has posted several documents suggesting wise virus-mitigation practices. Employees are strongly encouraged to follow the practices found in those documents.

B. Visitors Entering Campus

When visitors visit the campus, they present unique hazards with regards to COVID-19 exposure. All employees and students should evaluate the specific hazards when determining best practices related to COVID-19 and visitors.

Visitors must follow the guidelines outlined above for employees and students.

Visitors should maintain social distancing and wash or sanitize hands immediately before entering the campus.

Visitors should refrain from shaking hands and other personal greetings involving touching with employees and students.

Visitors may be asked the following questions in order for the campus to feel more comfortable with the visit, the visitor’s as well as each employee’s and student’s own health and safety and to make wise decisions. A “yes” answer may result in denied access to the campus:

Have you been confirmed positive for COVID-19?

Are you currently experiencing, or recently experienced, any acute respiratory illness symptoms such as fever, cough, or shortness of breath?

Have you been in close contact with any persons who has been confirmed positive for COVID-19?

Have you been in close contact with any persons who have traveled and are also exhibiting acute respiratory illness symptoms?

Should questions or concerns arrive as a result of any answers to these questions, the employee or student should notify campus leadership or an instructor to discuss a proper response that balances everyone’s health and safety with the School-related purpose of the visit (such as delivering supplies, or a potential student visit of the campus). Employees and students will not be disciplined for taking reasonable action to protect their own health and safety.

C. Personal Protective Equipment and Campus Practice Controls

In addition to regular personal protective equipment (“PPE”) for workers engaged in various tasks, the School will also provide the following when reasonably requested by an employee or student:

Gloves: Gloves are strongly encouraged to be worn at all times, especially while in the wet lab. The type of glove worn should be appropriate to the task. If gloves are not typically required for the task, then any type of glove is acceptable, including latex gloves. Employees and students should avoid sharing gloves.

Eye protection: Eye protection is strongly encouraged to be worn at all times while in the wet lab.

NOTE: The CDC is currently not recommending that healthy people wear N95 respirators to prevent the spread of COVID-19. Employees and students should wear N95 respirators if they believe it necessary and if the masks are readily available.

Due to the current shortage of N95 respirators, the following Work Practice Controls should be followed:

Two fabric masks may be provided to each School employee and student. When one mask is not being worn, it should be washed or disinfected to keep it as clean and sanitary as possible.

Limit exposure time to the extent practicable.

Isolate employees and students in lab operations by using a containment structure or social distancing to limit exposure.

School employees and students are encouraged to engage in regular housekeeping efforts to reduce contamination and spread on the campus, such as regular sweeping and mopping, disinfacting and general cleanup.

IV. Cleaning and Disinfecting

The School has instituted regular housekeeping practices, which include cleaning and disinfecting frequently used tools and equipment, and other elements of the work environment, where possible. Employees should regularly do the same in their assigned work areas.

School bathrooms and common areas will be cleaned at least once per day. Employees and students performing cleaning will be issued proper personal protective equipment, such as nitrile, latex, or vinyl gloves, and masks, as recommended by the CDC.

Any trash collected from the campus be disposed of quickly and all trash bags and liners must be changed frequently by someone who is encouraged to wear nitrile, latex, or vinyl gloves.

The School will work to keep hand sanitizer and soap dispensers filled. Frequently touched items (i.e. door pulls and toilet seats) will be disinfected frequently with the disinfectant wipes.

Equipment/tools should be cleaned regularly and before change in operator.

If an employee or student has tested positive for COVID-19, OSHA and the Department of Education have indicated that there is typically no need to perform special cleaning or decontamination of work environments, unless those environments are visibly contaminated with blood or other bodily fluids. Notwithstanding this, the School will clean those areas of the campus that a confirmed-positive individual may have come into contact with before employees or students can access that work space again.

The School will ensure that any disinfection shall be conducted using one of the following:

Common EPA-registered household disinfectant;

Alcohol solution with at least 60% alcohol; or

Clorox wipes or diluted household bleach solutions (these can be used if appropriate for the surface).

V. Campus Exposure Situations

Employee or Student Exhibiting COVID-19 Symptoms

If an employee or student exhibits COVID-19 symptoms, the employee or student must remain at home until he or she is symptom free for 72 hours (3 full days) without the use of fever-reducing or other symptom-altering medicines (e.g., ibuprofen, cough suppressants and the like). The School will similarly require an employee or student that reports to work with symptoms to return home until they are symptom free for 72 hours (3 full days). To the extent practical, employees and students are required to obtain a doctor’s note clearing them to return to work.

Employee or Student Tests Positive for COVID-19

An employee or student that tests positive for COVID-19 must notify the School of the test results and will be directed to self-quarantine away from the campus. Reasonable efforts will be made to maintain confidentiality of medical information. Employees or students that test positive and are symptom free may return to work when at least seven (7) days have passed since the date of his or her first positive test, if they have not had a subsequent illness. Employees or students that test positive and are directed to care for themselves at home may return to work when: (1) at least 72 hours (3 full days) have passed since recovery; and (2) at least seven (7) days have passed since symptoms first appeared. Employees and students that test positive and have been hospitalized may return to work when directed to do so by their medical care provider. The School will require an employee to provide medical documentation clearing their return to work.

Employee or Student Has Close Contact with a Tested-Positive COVID-19 Individual

Employees and students that have come into close contact with a confirmed-positive COVID-19 individual (co-worker, student or otherwise), will be directed to self-quarantine for 10 days from the last date of close contact with the carrier. Close contact is defined as six (6) feet for a prolonged period of time.

If the School learns that an employee or student has tested positive, the School will conduct an investigation into co-workers and students that may have had close contact with the confirmed-positive employee or student in the prior 14 days and, at its sole discretion following consultation with the impacted and potentially impacted employees and students, likely direct those individuals that have had close contact with the confirmed-positive employee to self-quarantine for 10 days from the last date of close contact with the carrier. The School may, if the risks are considered reasonable in its sole discretion and in light of the entirety of the situation does not put any employee or student at undue risk, permit employees or students potentially impacted to continue to attend campus. If an employee or student learns that he or she has come into close contact with a confirmed-positive individual outside of the campus, he/she must alert a manager or supervisor of the close contact and also self-quarantine for 10 days from the last date of close contact with the carrier.

VI. OSHA Recordkeeping and Department of Education Reporting

If a confirmed case of COVID-19 is reported, the School will determine if it meets the criteria for recordability and reportability under OSHA’s and the Department of Education’s (“ED”) recordkeeping rule. OSHA requires construction employers to record work-related injuries and illnesses that meet certain severity criteria on the OSHA 300 Log, as well as complete the OSHA Form 301 (or equivalent) upon the occurrence of these injuries. For purposes of COVID-19, OSHA also requires employers to report to OSHA any work-related illness that (1) results in a fatality, or (2) results in the in-patient hospitalization of one or more employees. “In-patient” hospitalization is defined as a formal admission to the in-patient service of a hospital or clinic for care or treatment. Similar requirements may be imposed on the School by ED and the School will comply with all applicable regulations and reporting requirements.

OSHA has made a determination that COVID-19 should not be excluded from coverage of the rule – like the common cold or the seasonal flu – and, thus, OSHA is considering it an “illness.” However, OSHA has stated that only confirmed cases of COVID-19 should be considered an illness under the rule. Thus, if an employee simply comes to work with symptoms consistent with COVID-19 (but not a confirmed diagnosis), the recordability analysis would not necessarily be triggered at that time. Similar requirements may be imposed on the School by ED and the School will comply with all applicable regulations and reporting requirements.

If an employee or student has a confirmed case of COVID-19, the School will conduct an assessment of any campus exposures to determine if the case is work-related. Campus-relatedness is presumed for illnesses that result from events or exposures in the campus environment, unless it meets certain exceptions. One of those exceptions is that the illness involves signs or symptoms that surface at the campus but result solely from a non-campus-related event or exposure that occurs outside of the campus environment. Thus, if an employee or student develops COVID-19 solely from an exposure outside of the campus environment, it would not be campus-related, and thus not recordable.

The School’s assessment will consider the campus environment itself, the type of instruction or work performed, risk of person-to-person transmission given the campus environment, and other factors such as community spread. Further, if an employee has a confirmed case of COVID-19 that is considered work-related, the School will report the case to OSHA if it results in a fatality within 30 days or an in-patient hospitalization within 24-hours of the exposure incident occurring. Similar requirements may be imposed on the School by ED and the School will comply with all applicable regulations and reporting requirements.

VII. Confidentiality/Privacy

Except for circumstances in which the School is legally required to report campus occurrences of communicable disease, the confidentiality of all medical conditions will be maintained in accordance with applicable law and to the extent practical under the circumstances. When it is required, the number of persons who will be informed of an employee’s or student’s condition will be kept at the minimum needed not only to comply with legally-required reporting, but also to assure proper care of the employee or student and to detect situations where the potential for transmission may increase. A sample notice to employees and students is attached to this Plan. The School reserves the right to inform other stakeholders that an employee or student has been diagnosed with COVID-19 if the other stakeholders might have been exposed to the disease so the stakeholders may take measures to protect their own health.

VIII. General Questions

Given the fast-developing and evolving nature of the COVID-19 outbreak, the School may modify this Plan on a case-by-case basis. If you have any questions concerning this Plan, please contact School leadership.