Construction Preparedness Plan Updates
Preparedness Plan Requirements Guidance –
Construction Updated June 25, 2020
Businesses engaged in construction and skilled trades include, but are not limited to, commercial construction, residential construction, highway, road, and bridge construction, utility construction, demolition-work, skilled trades (e.g. electricians, plumbers, HVAC, elevator), rehabilitation and remodeling. As required by executive orders issued by Gov. Tim Walz under the Peacetime Emergency, businesses in this sector must develop and implement COVID-19 Preparedness Plans that address the hazards of COVID-19 transmission at their worksites. Businesses must address all the guidance requirements applicable to their worksites in their COVID-19 Preparedness Plans and as set out in each of the components below. Unless clearly indicated that an action included in the guidance is recommended, businesses should understand that the action is required if applicable to their business. In instances where the guidance uses language “to the extent possible,” the action is required but only to the extent it is possible for the business to implement the requirement. Businesses must ensure the plan is evaluated, monitored, executed and updated under the supervision of a designated plan administrator. Businesses must ensure the plan is posted at all the business’s worksites in readily accessible locations (or is distributed to workers electronically) to allow for the plan to be readily reviewed by all workers, as required.
Worker protections and protocols for all workplaces
For the purposes of this guidance, a “worker” includes all workers engaged in work at a worksite.
All workers, including subcontractors, independent contractors, vendors, delivery personnel, contract, seasonal, part-time or temporary workers, however categorized, who are present at the worksite to perform work, are required to be covered by a COVID-19 Preparedness Plan.
All workers must be properly trained on and adhere to the worksite’s policies, protocols and practices as outlined within this guidance.
In addition, for purposes of this guidance, a “general contractor” includes entities that have overall authority, responsibility or control of a worksite, which may include, but is not limited to, general contractors, construction managers, prime contractors, developers, facility owners and/or operators, and public entities.
Responsibilities of general contractors on the worksite
1. General contractors must develop and implement a written COVID-19 Preparedness Plan that addresses the COVID-19 protocols and practices set out in this guidance that are applicable to the general contractor’s overall responsibility for work activities at the worksite and the work activities of its workers at the worksite. General contractors must ensure their plan is posted and readily available at the worksite.
2. General contractors must ensure all businesses that have workers performing work activities at the worksite, including employees, subcontractors and independent contractors, have a written COVID-19 Preparedness Plan that addresses the COVID-19 protocols and practices set out in this guidance that are applicable to the business’s work activities and workers who are performing work at the worksite.
3. General contractors must ensure COVID-19 Preparedness Plans prepared by each business at the worksite can be effectively implemented at the worksite, address any worksite-specific hazards for transmission of COVID-19 and are in alignment with the general contractor’s and other business’s COVID-19 Preparedness Plans.
4. General contractors must follow the guidance requirements for the component of the COVID-19 Preparedness Plan, “Ensure sick workers stay home,” and ensure all businesses at the worksite are immediately informed of the possible exposure of their workers to another worker who has COVID-19 symptoms or has tested positive for COVID-19 and are advised of actions they should take in response to that exposure.
5. General contractors must ensure diligent investigations are conducted at the worksite to evaluate and assess instances of exposure, whether actual or potential, involving workers who are confirmed COVID-19 positive, or where the general contractor and/or business have reason to believe a worker may be COVID19 positive, to ensure timely and appropriate action is taken to mitigate the potential spread of COVID-19 among other workers at the worksite or at other worksites where that worker is or was performing work.
Responsibilities of each business on the worksite
ENSURE SICK WORKERS STAY HOME
1. Maintain an attendance log to account for the business’s workers and visitors present at the worksite each day.
2. Establish a health screening protocol for the business’s workers (e.g. health screening survey, taking temperature). See the Minnesota Department of Health (MDH) Visitor and Employee Health Screening Checklist (www.health.state.mn.us/diseases/coronavirus/facilityhlthscreen.pdf). The checklist is also available in Hmong, Somali and Spanish (www.health.state.mn.us/diseases/coronavirus/businesses.html).
3. A health screening must be conducted for each business’s workers upon arrival and check-in at the worksite. The health screening must be conducted by an appropriate business representative or safety professional for the workers performing work at the worksite.
4. Workers must be stopped from entering the worksite if their responses to the health screening indicates they are experiencing symptoms of COVID-19 or have tested positive for COVID-19 and they should be sent home immediately. If workers begin experiencing symptoms of COVID-19 while at work, they must also be sent home immediately. If workers cannot be sent home immediately, they must be isolated in a closed room or remote area of the worksite until they can be sent home.
5. Establish a protocol for workers to report when they are experiencing COVID-19 symptoms, have tested positive for COVID-19 or have been in close contact with a person with COVID-19 symptoms or who has tested positive for COVID-19 and a return-to-work protocol for workers who are required to isolate or quarantine, following MDH guidance (www.health.state.mn.us/diseases/coronavirus/returntowork.pdf).
- If a worker is confirmed to have COVID-19, the protocol must include informing the business’s other workers who have been in close contact with the infected worker, as well as the general contractor(s) at the worksite, of the possible exposure to COVID-19 at the worksite. An individual must be designated to gather information from workers who may be sick with COVID-19 and to engage in needed communications, while ensuring the privacy of infected workers is maintained in accordance with Equal Employment Opportunity Commission (EEOC) guidance (www.eeoc.gov/transcriptmarch-27-2020-outreach-webinar).
8. Provide for accommodations for “high risk” workers who are vulnerable to serious complications if they were to contract COVID-19. See CDC’s People Who are at Higher Risk for Severe Illness (www.cdc.gov/coronavirus/2019-ncov/need-extra-precautions/people-at-higher-risk.html). Vulnerable workers should be encouraged to self-identify; businesses should avoid making unnecessary medical inquiries. Businesses must take particular care to reduce these workers’ risk of exposure.
SOCIAL DISTANCING – WORKERS MUST BE AT LEAST SIX FEET APART
1. Maximize remote working – workers who are able to work from home must work from home.
2. Hold virtual or online meetings, when possible (e.g. design meetings, project planning meetings, foremen meetings).
3. Ensure the worksite is supervised to oversee social distancing and assignment of work crews to maintain social distancing.
4. Ensure social distancing is maintained between workers at the worksite, including entering and exiting the worksite, navigating throughout the worksite and working within their assigned areas.
- Provide for six feet of physical distancing in work areas, staging areas, storage areas, hoist areas, break areas, locker and changing areas, meeting areas, office trailers, parking areas, etc.
- Evaluate and manage the traffic flow, patterns and “bottlenecks” for workers at the worksite to provide for one-way movement, to reduce crowding and to allow for social distancing at entrances and exits, in stairways, ladderways, hallways, elevators, waiting areas and access points on the worksite.
- Limit the number of people in restrooms.
- Provide for separation between individual portable toilets and handwashing/sanitizing stations, including staggering the location and positioning of individual portable toilets and handwashing stations to minimize congregation and traffic (e.g. positioned back to back with doors facing away from each other, mark off six feet of separation between persons waiting in line).
6. Implement static assignment of work crews for each worksite or work area to the extent possible. For example, Bob, Julie and Indigo always work together and are assigned to the same worksite every day, rather than reporting to different worksites throughout the week or being reassigned with different workcrew members.
7. Incorporate barriers, partitions, screens or curtains to maintain barrier protection between workers, to the extent possible, where social distancing cannot be maintained (e.g. curtains at planning tables, partitions on elevated work platforms, tarps over floor trusses, etc.). If use of barriers, partitions, screens or curtains is not possible, see below requirement that cloth face covering and face shields be used where social distancing cannot be maintained.
8. Use arrows and other signage to mark one-way traffic flows in hallways, stairways and corridors.
9. Mark access points, staging areas, loading areas and other areas of congestion to provide for social distancing of at least six feet, including floor markers for distance, lane lines and marking of adjacent areas where workers may be congregating or waiting.
10. Use staggered shifts, extended work hours and added shifts to reduce the number of workers on the worksite.
WORKER HYGIENE AND SOURCE CONTROLS
1. Instruct workers to regularly wash and/or sanitize their hands, in particular when entering and exiting the worksite, and before and after eating or drinking, using tobacco products, using restroom facilities, and using devices, tools and equipment used by other workers. Instruct workers to avoid touching their face with unwashed or unsanitized hands. Ensure handwashing and/or hand-sanitizer facilities are readily available at the worksite and allow workers sufficient time to engage in handwashing/sanitizing.
- Post “handwashing” and “cover your cough”signs.
3. When not required by this guidance, see below “Additional protocols for face coverings.” strongly encourage the use of non-medical source-control face coverings (e.g. cloth face coverings) at all times. Instruct workers to:
- launder reusable face coverings before each daily use according to CDC guidelines at www.cdc.gov/coronavirus/2019-ncov/prevent-getting-sick/diy-cloth-face-coverings.html.
7. Provide tissues or towels for proper cough and sneeze etiquette and provide no-touch trash bins.
8. Instruct workers to launder their clothing, uniforms, apparel and personal protective equipment (PPE) daily according to clothing or detergent instructions. Encourage workers to maintain additional apparel at worksites (e.g. shirts, sweatshirts) to minimize cross-exposure between work areas or worksites.
9. Ensure proper respiratory protection is still provided, used and maintained to protect workers from other recognized health hazards as required (e.g. respirable silica, lead, asbestos).
10. Encourage supplementing handwashing and hand-sanitizing facilities with the use of self-provided, individualized, water bottles or containers filled with soap and water, and potable water for immediate handwashing at worksites
WORKSITE VENTILATION PROTOCOL S FOR WORK WITHIN STRUCTURES
Evaluate the operational capacity and increase, improve and maintain ventilation provided.
1. Increase the outdoor air-percentage to increase dilution of contaminants, and eliminate recirculating, whenever possible, while maintaining indoor-air conditions. Recommendations 2. Run systems on full economizer as outside-air conditions allow. Day to day operations: For work activities not occurring outdoors, particularly within enclosed areas and structures, ensure the following practices and protocols are maintained. Requirements 1. Continuously maximize fresh air into work areas and eliminate air recirculation.
2. Supplement the ventilation system with the use of portable HEPA-filter units whenever possible.
3. Keep systems running longer hours (24/7 if possible) to enhance the ability to filter contaminants out of the air.
4. Minimize air-flow blowing across people. Recommendations
5. Consult an HVAC professional or the American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE) to ensure proper ventilation, particularly air flow and air exchange, is provided, and ventilation systems are properly maintained. See ASHRAE’s COVID-19 Preparedness Resources (www.ashrae.org/technical-resources/resources).
WORKSITE CLEANING AND DISINFECTION PROTOCOLS
1. Establish a documented sanitization schedule and checklist, identifying surfaces and equipment to be sanitized, the agent to be used and the frequency at which sanitization occurs.
2. Frequently clean and disinfect all areas, such as jobsite offices, office trailers, restrooms and portable toilets, locker and changing areas, common areas and break areas.
3. Clean and disinfect work vehicles between the use of each worker or work crew.
4. Frequently clean and disinfect all high-touch items, such as doorknobs, countertops, barriers, railings, handles and other surfaces.
5. Avoid passing and using community materials, sign-in sheets and writing utensils.
6. Electronic devices (e.g. light switches, circuit breakers) should not be sanitized with a liquid agent. Consider covering switches and devices with a poly-covering that allows the user to manipulate the device without touching the switch and change out the poly-covering frequently. Electronic devices must be sanitized only when disconnected from the power source, and cleaned and disinfected in accordance with the listing or labeling requirements.
7. Workers, including those in the field, should avoid sharing phones, devices, materials, tools and equipment and, if shared, they should be disinfected between users.
8. Implement immediate cleaning and disinfecting of areas at the worksite where a worker, official or visitor was present and who has become ill with COVID-19. See CDC’s Cleaning and Disinfecting Your Facility (www.cdc.gov/coronavirus/2019-ncov/community/disinfecting-building-facility.html).
9. Select appropriate disinfectants and ensure the needed supply is available – consider effectiveness and safety.The U.S. Environmental Protection Agency’s (EPA’s) List N has identified products that meet EPA’s criteria for use against SARS-CoV-2. See EPA’s List N: Disinfectants for Use Against SARSCoV-2 (www.epa.gov/pesticide-registration/list-n-disinfectants-use-against-sars-cov-2)..
10. Review product labels and safety data sheets, follow manufacturer specifications and use required personal protective equipment for the product.
11. Ensure portable toilets are emptied regularly.
12. Ensure all trash, refuse and debris is regularly disposed of and not allowed to accumulate, to minimize the number of workers involved in the handling and disposal of materials. Provide covered trash receptacles throughout the worksite.
13. When possible, assign a designated operator for each piece of equipment (e.g. forklift operator, skid-steer operator) as opposed to allowing several operators to access a single piece of equipment. If equipment is shared, disinfect between users. Recommendations
14. Encourage workers to sanitize high-touch points within their personal vehicle (e.g. handles, locks, steering-wheels, instrument controls, switches, seatbelt) upon entering
DROP - OFF, PICK- UP AN D DELIVERY PRACTICES AND PROTOCOL
1. Workers must maintain a distance of six feet during drop-offs, pick-ups and deliveries.
2. Workers must minimize the unnecessary exchanging or sharing of scanners, pens or other tools with delivery personnel.
3. Receive deliveries via a contactless method, when possible, including delivery at the gate or location where persons can maintain a distance of at least six feet from each other. When possible, conduct communications and transactions electronically to eliminate the need for close contact between workers and delivery personnel.
4. To facilitate social distancing, equipment, materials, products and items being delivered should be dropped off or picked up, when possible, at prescheduled times and coordinated with other deliveries. Perform deliveries, drop-offs or pick-ups in one load, carrier or vehicle at a time, and avoid, where possible, multiple deliveries, drop-offs or pick-ups at one time. Have delivery personnel wait in their vehicles if another delivery, drop-off or pick-up is being performed.
5. Consider providing locations outside of the worksite to accommodate drop-offs, pickups and deliveries, and delivery workers, and minimize the need for delivery workers to enter the worksite (e.g. portable toilets, drop-off areas, staging areas).
COMMUNICATIONS AND TRAINING PRACTICES AN D PROTOCOL
1. All workers and members of management must be trained regarding COVID-19 exposure, as well as applicable policies, procedures, practices and protocols. The training must be provided by the business for their respective workers on work time. The training must be provided in a manner and language that each worker can understand and must be adjusted to reasonably accommodate all limiting factors present. See OSHA's Resource for Development and Delivery of Training to Workers STATE OF MINNESOTA 9 (www.osha.gov/Publications/osha3824.pdf). See also Minnesota's Small Assemblies for Testing and Training for guidance with facilitating training for employees while addressing COVID-19 implications (dli.mn.gov/sites/default/files/pdf/COVID-19_training_facilities.pdf).
2. Ensure their respective COVID-19 Preparedness Plans are posted at all worksites where workers are present, in readily accessible locations, and are shared with and reviewed by all workers. Posting may be accomplished through electronic dissemination of the plan to all workers as long as workers have access means to review electronic posting.
3. Ensure the required rules, protocols and practices are communicated to their workers and adequately enforce their provisions.
4. Ensure the required rules, protocols and practices are required by businesses providing temporary, part-time, seasonal and contract workers to the business.
5. Ensure their workers are provided with and use personal protective equipment necessary to perform their work.
6. Workers must ensure they comply with and follow established rules, protocols and practices.
7. Use signage as reminders for workers, delivery workers, officials and visitors of rules, protocols and practices, including not to enter the worksite if they have COVID-19 symptoms, social distancing, handwashing, use of source control face coverings and respiratory etiquette.
Additional protections and protocol for managing access and occupancy on construction worksites
1. Control access to the worksite to required contractors and their workers, delivery workers and government officials, and to visitors who have appointments.
- Ensure perimeters for worksites are established by means that will allow for the ingress into the worksite to be effectively monitored and controlled.
- Ensure all worksites maintain established and well-defined boundaries to promote well-controlled access, ingress and occupancy.
- For worksites that are within the confines of an existing occupancy (e.g. expansion project, remodeling project), ensure access into the worksite is controlled to prevent unauthorized persons from entering the worksite. Examples include permanent or temporary walls, security doors, partitions, fencing or gates. See below guidance about provision of “in-home” services.
3. Request that all visitors wear face coverings and conduct a health assessment and self-check of their body temperature prior to visiting the worksite. Recommendations
4. Consider the use of business websites, social media, text messages, phone calls and other means to educate persons who may enter the worksite on the actions being taken for their protection and the protection of all persons at the worksite.
5. Encourage all visitors at “high risk” if they were to contract COVID-19 not to enter the worksite and to use other means to conduct their activities. (See www.cdc.gov/coronavirus/2019-ncov/need-extraprecautions/people-at-higher-risk.html.)
6. Post instructions at entrances advising persons:
- not to enter if they are experiencing symptoms of COVID-19;
- they are required to adhere to hygiene and social-distancing instructions, signage and markings; and
- they should wear source-control face-coverings, whenever possible, in addition to the standard personal protective equipment that is required.
Additional protections and protocol to maintain social distancing on construction worksites
1. Discourage congregating and encourage social distancing outside of the worksite during meal breaks and other work breaks.
2. Prohibit car-pooling or vehicle-sharing if the number and arrangement of occupants within a single vehicle does not allow for proper social-distancing.
3. Restrict access into the job office or office trailer to a limited number and allow for social distancing (e.g. general contractor only). Do not allow persons to enter the job office or office trailer unannounced. Implement “walk-up” protocol to speak through windows of the office trailer as opposed to allowing workers or delivery personnel to enter the trailer. Cordon off or demarcate an area near the doorway to limit persons entering into the job office or office trailer further than the doorway. Recommendations
4. Schedule work crews and coordinate work activities to minimize the number of work crews and workers at the worksite at the same time (e.g. schedule separate work crews in the morning and afternoon, schedule separate work crews for various days of the week or over separate weeks). Provide for assignment of work crews to buildings, floors, sections, work zones or work areas.
5. Conduct a higher number of meetings consisting of fewer number of persons as opposed to a fewer number of meetings involving larger gatherings (e.g. meeting with each work crew separately).
6. Conduct meetings or conversations outside or in large areas or spaces as opposed to in job offices or office trailers.
7. Designate separate facilities, machinery or equipment throughout the worksite to minimize the common use throughout the worksite. Examples include providing:
- additional access points, stairways and ladderways, and assigning specific work crews to use designated access points, as opposed to every work crew using all points of access;
- additional sanitation facilities and assigning specific work crews to use designated facilities (e.g. portable toilets, handwashing stations), as opposed to every work crew using all facilities; and
- multiple pieces of equipment (e.g. forklifts, mobile elevated work-platforms, skidsteers) and assigning specific work crews to use designated pieces of equipment.
Additional protocols for use of face coverings where social distancing cannot be consistently maintained
1. Evaluate work activities that involve a breach of social distancing to determine if they can be done in an alternative way. Work activities should not be performed if adequate protective measures cannot be implemented. See above recommendations on the use of barriers, partitions, screens and curtains to provide for separation between workers and work crews.
2. Workers must always use a face covering when social distancing cannot be maintained. See CDC Use of Cloth Face Coverings to Help Slow the Spread of COVID-19 (www.cdc.gov/coronavirus/2019- ncov/prevent-getting-sick/diy-cloth-face coverings.html). If workers are unable to use a face covering due to health or physical ability reasons, then the worker must use a face shield.
- Instruct workers to launder reusable face coverings after each daily use.
- CDC also has additional information about the use of face coverings at www.cdc.gov/coronavirus/2019-ncov/prevent-getting-sick/diy-cloth-face-coverings.html, including washing instructions.
3. Encourage all persons, including workers and visitors, to bring their own face coverings, or offer face coverings for their use.
Additional protections and protocol for in-home services
1. Have all occupants present within the residence respond to the screening survey questions upon arrival and verify they have read the screening survey and can respond “no” to all questions. Decline to enter the residence and proceed with the services if there is any suspicion that occupants are sick or symptomatic and leave the worksite.
2. Encourage that services be postponed for residences where “high risk” and vulnerable populations are residing. See CDC’s People Who are at Higher Risk for Severe Illness (www.cdc.gov/coronavirus/2019- ncov/need-extra-precautions/people-at-higher-risk.html).
3. Encourage occupants to minimize the number of persons present while workers are entering and working inside the residence.
4. Ensure proper social distancing is maintained between all workers and occupants of the residence at the worksite. Physical contact between workers and occupants must be avoided at all times (e.g. handshakes).
5. Workers must always use a face covering when social distancing cannot be maintained. See CDC Use of Cloth Face Coverings to Help Slow the Spread of COVID-19 (www.cdc.gov/coronavirus/2019- ncov/prevent-getting-sick/diy-cloth-face coverings.html).
6. Strongly encourage occupants of the residence, who are present while workers are inside of the home, to wear face coverings unless not recommended for health or physical ability reasons.
7. Ensure workers regularly wash and/or sanitize their hands. Workers should wash their hands upon entering the worksite, before and after eating and meal periods, before and after restroom breaks, upon exiting the worksite and prior to entering their vehicle.
8. Frequently clean and disinfect all high-touch items, such as doorknobs, countertops, railings, handles and other surfaces. Recommendations
9. Communication to educate landlords, homeowners, tenants and occupants about the steps being taken for their protection while providing in-home services to mitigate the spread of COVID-19 is encouraged. Communicate protective measures to homeowners, tenants and occupants prior to entering the residence to both educate the occupants and inform them of their role in protecting the workers.
Guidance for developing an COVID-19 Preparedness Plan
Centers for Disease Control and Prevention (CDC): Coronavirus (COVID-19) – www.cdc.gov/coronavirus/2019-nCoV
Minnesota Department of Health (MDH): Coronavirus – www.health.state.mn.us/diseases/coronavirus
State of Minnesota: COVID-19 response – mn.gov/covid19
CDC: Resources for businesses and employers –www.cdc.gov/coronavirus/2019- ncov/community/organizations/businesses-employers.html
CDC: General business frequently asked questions – www.cdc.gov/coronavirus/2019- ncov/community/general-business-faq.html
CDC: Building/business ventilation – www.cdc.gov/coronavirus/2019-ncov/community/guidance-businessresponse.html
MDH: Businesses and employers: COVID-19 – www.health.state.mn.us/diseases/coronavirus/businesses.html
MDH: Health screening checklist – www.health.state.mn.us/diseases/coronavirus/facilityhlthscreen.pdf
MDH: Materials for businesses and employers –www.health.state.mn.us/diseases/coronavirus/materials
Minnesota Department of Employment and Economic Development (DEED): COVID-19 information and resources – mn.gov/deed/newscenter/covid/
Minnesota Department of Labor and Industry (DLI): Updates related to COVID-19 – www.dli.mn.gov/updates
Federal OSHA – www.osha.gov
AIHA Back to Work Safely – www.backtoworksafely.org/
MDH: Handwashing video translated into multiple languages – www.youtube.com/watch?v=LdQuPGVcceg
Cover your cough or sneeze CDC: www.cdc.gov/coronavirus/2019-ncov/prevent-getting-sick/prevention.html
CDC: www.cdc.gov/healthywater/hygiene/etiquette/coughing_sneezing.html MDH: www.health.state.mn.us/diseases/coronavirus/prevention.html
Environmental Protection Agency (EPA): www.epa.gov/pesticide-registration/list-n-disinfectants-useagainst-sars-cov-2-covid-19
Employees exhibiting signs and symptoms of COVID-19
MDH: www.health.state.mn.us/diseases/coronavirus/basics.html MDH: www.health.state.mn.us/diseases/coronavirus/facilityhlthscreen.pdf
MDH: www.health.state.mn.us/diseases/coronavirus/returntowork.pdf State of Minnesota – mn.gov/covid19/for-minnesotans/if-sick/get-tested/index.jsp
Federal OSHA: www.osha.gov/Publications/OSHA3990.pdf
MDH: www.health.state.mn.us/diseases/coronavirus/about.pdf 06/25/2020