RIT Airborne Infectious Disease Exposure Prevention Plan For Employees
This Infectious Disease Exposure Prevention Plan (the “Plan”) shall apply to employees. It shall only apply when the New York State Commissioner of Health (the “Commissioner”) designates a highly contagious communicable disease (“Highly Contagious Disease”) that presents a serious risk of harm to the public health. It shall not apply to any seasonal or endemic infectious disease, such as the seasonal flu, that has not been designated by the Commissioner as a Highly Contagious Disease that presents a serious risk of harm to the public health.
The following employee(s) are designated to enforce compliance with the Plan:
- Associate Vice President and Chief Human Resources Officer
- Associate Vice President for Global Risk Management Services
- Deputy General Counsel and Compliance Officer
- Director of Environmental Health and Safety
- Vice President and General Counsel
Exposure Controls During a Designated Outbreak
Minimum Controls During an Outbreak
During a Highly Contagious Disease outbreak, employees shall be required to use the following minimum controls:
- Maintain physical distancing;
- Exercise coughing/sneezing etiquette;
- Wear face coverings, gloves, and personal protective equipment, as appropriate;
- Individuals limit what they touch;
- Stop certain social etiquette behaviors that involve physical contact such as hugging and hand shaking;
- Wash hands properly and often; and
- Other controls put in place by the university.
If an employee develops symptoms of the infectious disease, that individual should not be on campus. That employee should inform the designated contact and follow New York State Department of Health (the “NYSDOH”) and Centers for Disease Control and Prevention (the “CDC”) guidance regarding obtaining medical care and isolation.
Employees will be screened for symptoms of the infectious disease prior to coming onto campus. They are to self-monitor throughout their time on the RIT campus and report any new or emerging signs or symptoms of the infectious disease to the designated contact. Any employee showing signs or symptoms of the infectious disease should be removed from campus and should contact a healthcare professional for instructions. The health screening elements will follow guidance from NYSDOH and CDC guidance, if available.
All employees shall wear face coverings throughout the workday to the greatest extent possible. Face coverings and physical distancing should be used together whenever possible. The face covering must cover the nose and mouth, and fit snugly, but comfortably, against the face. The face covering itself must not create a hazard, e.g. have features that could get caught in machinery or cause severe fogging of eyewear. The face coverings must be kept clean and sanitary and changed when soiled, contaminated, or damaged.
Physical distancing will be followed as much as feasible. RIT Community members will avoid unnecessary gatherings and maintain a distance of at least six feet (or as recommended by the NYSDOH/CDC for the infectious agent) from each other. Face coverings will be used when physical distance cannot be maintained.
To prevent the spread of infection, employees should wash hands with soap and water for at least 20 seconds or use a hand sanitizer with at least 60% alcohol to clean hands BEFORE and AFTER:
- Touching your eyes, nose, and mouth;
- Touching your mask;
- Entering and leaving a public place; and
- Touching an item or surface that may be frequently touched by other people, such as door handles, tables, gas pumps, shopping carts, or electronic cashier registers/screens
Please refer to the section on Housekeeping During a Designated Outbreak.
Because certain infectious diseases can be spread by droplets expelled from the mouth and nose, all employees should exercise appropriate respiratory etiquette by covering nose and mouth when sneezing, coughing, or yawning.
Some employees, due to age, underlying health condition, or other factors, may be at increased risk of severe illness if infected. Please inform your supervisor or the HR department if you fall within this group and seek an accommodation.
Advanced Controls During an Outbreak
For activities where the Minimum Controls alone will not provide sufficient protection for employees, additional controls from the following hierarchy may be necessary. RIT should determine if the following are necessary:
RIT should consider the temporary suspension or elimination of risky activities where minimum controls could not provide sufficient protection for employees.
RIT should consider appropriate controls to contain and/or remove the infectious agent, prevent the agent from being spread, or isolate the member of the RIT Community from the infectious agent. Examples of engineering controls include:
- Mechanical Ventilation includes, for example:
- Local exhaust ventilation;
- Ventilated booths (lab hoods);
- Kitchen vents; and
- Vented biosafety cabinets.
- General Ventilation, includes, for example:
- Dedicated ventilation systems for cooking areas, malls, atriums, surgical suites, manufacturing, welding, indoor painting, laboratories, negative pressure isolation rooms;
- Increasing the percentage of fresh air introduced into air handling systems;
- Avoiding air recirculation;
- Using higher-efficiency air filters in the air handling system; and
- If fans are used in the facility, arrange them so that air does not blow directly from one worker to another.
- Natural Ventilation.
- Opening outside windows and doors to create natural ventilation; and
- Opening windows on one side of the room to let fresh air in and installing window exhaust fans on the opposite side of the room so that they exhaust air outdoors. (Note: This method is appropriate only if air will not blow from one person to another.)
- Install automatic disinfection systems (e.g., ultraviolet light disinfection systems).
- Install cleanable barriers such as partitions and/or clear plastic sneeze/cough guards.
- Change layout to avoid points or areas where employees may congregate (e.g., install additional time clocks).
Administrative Controls are policies and work rules used to prevent exposure. Examples include:
- Increasing the space between employees;
- Slowing production speed to accommodate fewer employees at a time;
- Disinfecting procedures for specific operations;
- Not shaking out soiled laundry;
- Faculty and staff training;
- Identifying and prioritizing the job functions that are essential for continuous operations;
- Cross-training employees to ensure critical operations can continue during worker absence;
- Limiting the use of shared workstations;
- Post signs reminding employees of respiratory etiquette, masks, handwashing;
- Rearranging traffic flow to allow for one-way walking paths;
- Providing clearly designated entrance and exits;
- Providing additional short breaks for handwashing and cleaning; and
- Establishing pods or cohorts working on same shift.
Personal Protective Equipment (“PPE”) are devices like eye protection, face shields, respirators, and gloves that protect the wearer from infection. PPE will be provided, used, and maintained in a sanitary and reliable condition at no cost to the employee. The PPE provided to an employee will be based on a hazard assessment for the workplace.
Exposure Control Readiness, Maintenance, and Storage
The controls we have selected will be obtained, properly stored, and maintained so that they are ready for immediate use in the event of an infectious disease outbreak, and any applicable expiration dates will be properly considered.
Housekeeping During a Designated Outbreak
- Objects that are touched repeatedly by multiple individuals, such as door handles, light switches, control buttons/levers, dials, levers, water faucet handles, computers, phones, or handrails must be cleaned frequently with an appropriate disinfectant. Surfaces that are handled less often, or by fewer individuals, may require less frequent disinfection.
- The disinfection methods and schedules selected are based on specific workplace conditions.
- The New York State Department of Environmental Conservation (“NYSDEC”) and the Environmental Protection Agency (“EPA”) have compiled lists of approved disinfectants that are effective against many infectious agents. Select disinfectants based on NYSDOH and CDC guidance and follow manufacturer guidance for methods, dilution, use, and contact time.
- Normal housekeeping duties and schedules should continue to be followed during an infectious disease outbreak, to the extent practicable and appropriate consistent with NYSDOH and/or CDC guidance in effect at the time. However, routine procedures may need to be adjusted and additional cleaning and disinfecting may be required.
- Housekeeping staff may be at increased risk because they may be cleaning potentially contaminated surfaces. Some housekeeping activities, like dry sweeping, vacuuming, and dusting, can re-suspend into the air particles that are contaminated with the infectious agent. For that reason, alternative methods and/or increased levels of protection may be needed.
- Rather than dusting, for example, the CDC recommends cleaning surfaces with soap and water before disinfecting them. Conducting housekeeping during “off” hours may also reduce other workers’ exposures to the infectious agent. Best practice dictates that housekeepers should wear respiratory protection.
If an employee develops symptoms of the infectious disease while on campus, it is ideal to isolate the area in accordance with guidance issued by NYSDOH or the CDC, before cleaning and disinfecting the exposed area. This delay will allow contaminated droplets to settle out of the air and the space to be ventilated.
As feasible, liners should be used in trash containers. Empty the containers often enough to prevent overfilling. Do not forcefully squeeze the air out of the trash bags before tying them closed. Trash containers may contain soiled tissue or face coverings.
Infection Response During a Designated Outbreak
If an actual, or suspected, infectious disease case occurs at work, take the following actions:
- Instruct the sick individual to wear a face covering and leave campus and follow NYSDOH/CDC guidance.
- Follow local and state authority guidance to inform impacted individuals.
Training and Information During a Designated Outbreak
RIT will verbally inform all employees of the existence and location of this Plan, the circumstances under which it can be activated, the infectious disease standard, RIT policies, and employee rights under the HERO Act.
When this Plan is activated, all employees will receive training which will cover all elements of this Plan and the following topics:
- The infectious agent and the disease(s) it can cause;
- The signs and symptoms of the disease;
- How the disease can be spread;
- An explanation of this Exposure Prevention Plan;
- The activities and locations on campus that may involve exposure to the infectious agent;
- The use and limitations of exposure controls; and
- A review of the standard, including employee rights provided under Labor Law, Section 218-B.
The training will be:
- Provided at no cost to employees and take place during working hours. If training during normal work hours is not possible, employees will be compensated for the training time (with pay or time off);
- Appropriate in content and vocabulary to your educational level, literacy, and preferred language; and
- Verbally provided in person or through telephonic, electronic, or other means.
Retaliation Protections and Reporting of Any Violations
RIT, nor its agent(s) or any person acting as or on behalf of RIT, shall not discriminate, threaten, retaliate against, or take adverse action against any employee for exercising their rights under this Plan, including reporting conduct reasonably believed in good faith to violate this Plan or airborne infectious disease concerns, or for refusing to work where an employee reasonably believes in good faith that such work exposes them, other workers, or the public to an unreasonable risk of exposure, provided the employee, another employee, or representative has notified the employer verbally or in writing, including electronic communication, of the inconsistent working conditions and RIT’s failure to cure or if RIT knew or should have known of the inconsistent working conditions. Notification of a violation by an employee may be made verbally or in writing, and without limitation to format including electronic communications.
To the extent that communications between RIT and an employee regarding a potential risk of exposure are in writing, they shall be maintained by RIT for two (2) years after the conclusion of the designation of a Highly Contagious Disease from the Commissioner of Health, or two (2) years after the conclusion of the Governor’s emergency declaration of a Highly Contagious Disease. RIT should include contact information to report violations of this Plan and retaliation during regular business hours and for weekends/other non-regular business hours when employees may be working.