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Managing EHS Issues and COVID-19

Disclaimer

Because guidance on this topic is continually changing, the content for this presentation is current. If watching a recorded version of the presentation, be aware guidance may have changed.

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Matt Schroeder –Environmental Division ManagerOfficesIllinois – Champaign, Freeport, Rochelle, Rockford, SpringfieldWisconsin – Monroe, SheboyganIowa – Cedar Rapids, Manchester, West Union

ContactMatt SchroederEnvironmental Division Managermschroeder@fehr-graham.com920.838.6373 (cell)920.453.0700 (office) fehr-graham.com

Agenda

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Preventing disease transmission in the workplace

Housekeeping and Hygiene

Disinfection

CDC, OSHA, EPA, IEPA Guidance

Keeping your workplace safe

Respiratory Protection

Safety Training and Certifications

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Preventing Disease Transmission in the Workplace

Good housekeeping has never been more important or received a higher priority.

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Disinfecting a workspace

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CDC –Instructions and Guidance for Cleaning

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CDC Cleaning Guidance – 4/1/2020

8cdc.gov/coronavirus/2019-ncov/community/organizations/cleaning-disinfection.html

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EPA - Disinfectants for Use Against SARS-CoV-2

9epa.gov/pesticide-registration/list-n-disinfectants-use-against-sars-cov-2

A couple additional consideration …

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Be aware of potential impacts of cleaning chemicals to onsite wastewater treatment systems.

Managing waste from disinfection processes.

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A Worker Tests Positive• Have a plan in place for

decontamination• Large scale cleaning beyond

capability of your organization

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What to do to keep your workplace safe

• Communicate!!!!!• Task Safety Team or Human Resources to monitor updates• Administrative Controls – have a written plan, Crisis Committee• Changes to teams and workgroups – evaluate options for high

risk groups• PPE – mandatory mask, face shields, gloves, suits• Employee/visitor temperature checks/survey• In plant laundry• Reduce paper processes/handling – look for automation• Process observation/coordinator• Now is a great time to look for opportunities to reduce

respiratory risks - engineering controls• Mandatory cleaning/checklist at end of shift

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Retaliation GuidelinesWhat if a worker complains that you are not doing enough to provide a safe and healthy work environment?

Anti-Retaliation

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OSHA Guidance

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osha.gov/SLTC/covid-19/

What to do if a worker becomes ill

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Have you developed guidelines for what your company will do following a report of a worker testing positive?

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OSHA Enforcement Flexibilities

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Mandatory Use of Respirators

• Medically evaluated• Fit Tested• Trained

Voluntary Use of Respirators

• Medical evaluation • Training • NO Fit Test Requirement

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OSHA Memorandums• Reassess engineering controls

and work practices in light of N95 shortages

• Alternative respirators• Extended use/Reuse of masks

under certain conditions• Use of expired masks• Go to the website for

additional info:

https://www.osha.gov/SLTC/covid-19/standards.html#directives

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Managing Safety Training and Certifications

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OSHA Recordable

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Under OSHA’s recordkeeping requirements, COVID-19 is a recordable illness, and employers are responsible for recording cases of COVID-19, if:

1. the case is a confirmed case of COVID-19, as defined by Centers for Disease Control and Prevention (CDC)

2. the case is work-related as defined by 29 CFR § 1904.5

3. the case involves one or more of the general recording criteria set forth in 29 CFR § 1904.7

U.S. Department of Labor

Enforcement Guidance for Recording Cases of Coronavirus Disease 2019 (COVID-19)

As of April 10, 2020, OSHA will not enforce 29 CFR §1904 to require other employers to make the same work-relatedness determinations, except where:

• There is objective evidence that a COVID-19 case may be work-related. This could include, for example, many cases developing among people who work closely together without an alternative explanation

The evidence was reasonably available to the employer. • Information given to the employer by employees• Information that an employer learns regarding its employees’

health and safety in the ordinary course of managing its business and employees.

• No exception to healthcare, EMS and correctional facilities

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CDC Guidance

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Environmental Agency Enforcement

• EPA guidance on enforcement discretion.• States are also applying judgement to enforcement.• Be aware for the potential for enforcement by citizens.• Importance of communication and planning.• Be aware that EPA or state policy does not relieve

regulated entities from compliance obligations. • Make every effort to stay in compliance.• Act responsibly!• Identify and document the specific nature and

causes of any non-compliance.• Identify how COVID-19 was the cause.• Use existing procedures to report noncompliance.

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Reporting Deadlines

• May 1 – Annual Emissions Reports• July 1 – Toxic Release Inventory• Site Specific Reporting Obligations

• Discharge Monitoring Reports • Semi-Annual and Annual Compliance Reports• Air and Water Testing

• TSCA – Chemical Data Report –• Deadline Extended June 1 – November 30

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This is an emerging, rapidly evolving situation and the Centers for Disease Control and Prevention will provide updated information as it becomes available, in addition to updated guidance. This website provides key EPA resources on the coronavirus disease (COVID-19).https://www.epa.gov/coronavirus

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Links for additional information:

• CDC: Guidance for reducing health risks to workers handling human waste or sewage

• CDC: Healthcare professionals: Frequently asked questions and answers

• CDC: Healthy Water• Occupational Safety and Health Administration:

COVID-19 Control and Prevention: Solid waste and wastewater management workers and employers

• World Health Organization: Water, sanitation, hygiene and waste management for COVID-19

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Additional Links

• Illinois Department of Labor: www2.illinois.gov/idol/Pages/default.aspx

• www.epa.gov/coronavirus• www2.illinois.gov/epa/topics/Pages/covid19.aspx• www.fehr-graham.com

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Matt Schroeder –Environmental Division ManagerOfficesIllinois – Champaign, Freeport, Rochelle, Rockford, SpringfieldWisconsin – Monroe, SheboyganIowa – Cedar Rapids, Manchester, West Union

Fehr Graham IMECMatt Schroeder Emily LeeEnvironmental Division Manager Program & Partner Relations Coordinatormschroeder@fehr-graham.com elee@imec.org920.838.6373 (cell) 608-445-4905 (cell)920.453.0700 (office) fehr-graham.com www.IMEC.org

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