UM-D COVID-19 OSHA Safety Plan
COVID-19 Preparedness and Response Plan for On-Site Essential Employees during the COVID-19 Pandemic
Coronavirus Disease 2019 (COVID-19) is a respiratory disease caused by the SARS-CoV-2 virus. This document will summarize the University of Michigan preparedness and response actions for COVID-19 based on traditional infection prevention and industrial hygiene practices. It focuses on the implementation of engineering, administrative, and work practice controls and personal protective equipment (PPE), in the effort to control employee exposures to the extent feasible.
This plan is intended to provide information on the risk levels in workplace settings and the appropriate control measures that should be implemented based on the risk present. This document will be adjusted as needed as COVID-19 outbreak conditions change, including new information about the virus, its transmission, and impacts, becomes available.
This document serves as the UM-Dearborn workplace expectations and guidelines for staff that are on-campus in regard to management of COVID-19 risk mitigation. All policies, protocols, and requirements are expected to be followed and failure to do so may result in corrective action. The information provided is based on current Center for Disease Control (CDC) guidelines, Federal OSHA COVID-19 Emergency Temporary Standard adopted by reference by MIOSHA, and the Federal OSHA Guidance: Protecting Workers: Guidance on Mitigating and Preventing the Spread of COVID-19 in the Workplace.. Employers must provide a place of employment that is free from recognized hazards that are causing, or are likely to cause, death or serious physical harm to an employee.
Guidance for academic areas is referenced in this document and those requirements are specific to those areas.
The U.S. Department of Health and Human Services’ Centers for Disease Control and Prevention (CDC) provides the latest information about COVID‐19 and the global outbreak: https://www.cdc.gov/coronavirus/2019-ncov/index.html
The MIOSHA home page also offers COVID‐19 information specifically for workers and employers in Michigan: https://www.michigan.gov/leo/0,5863,7-336-100207---,00.html
Additionally, the State of Michigan’s Coronavirus webpage is updated daily and provides current public health and safety resources for employers, employees, and the general public https://www.michigan.gov/coronavirus/
The University communicates frequently to our employees and students, providing health and safety guidance and direction while encouraging them to stay informed by checking the following university websites and resource pages “Go Safe – Go Blue – Go Dearborn!”
UM-Dearborn EHS COVID-19 webpage: https://umdearborn.edu/offices/environmental-health-and-safety/covid-19-safety-information
Note: These practices are intended to apply to on-campus employees only. The practices outlined in this document do not apply to employees who are working remotely although it would be prudent to follow the general guidance to minimize risk of exposure.
Symptoms of COVID-19
Infection with SARS-CoV-2, the virus that causes COVID-19, can cause illness ranging from mild to severe and, in some cases, can be fatal. Symptoms typically include cough, shortness of breath or difficulty breathing, fever or chills, repeated shaking with chills, muscle pain, headache, sore throat and new loss of taste or smell. Some people infected with the virus have reported experiencing other non-respiratory symptoms. Other people, referred to as asymptomatic cases, have experienced no symptoms at all.
According to the CDC, symptoms of COVID-19 may appear in as few as 2 days or as long as 14 days after exposure.
How COVID-19 Spreads
COVID-19 spreads when an infected person breathes out droplets and very small particles that contain the virus. These droplets and particles can be breathed in by other people or land on their eyes, noses, or mouth. In some circumstances, they may contaminate surfaces they touch. People who are closer than 6 feet from the infected person are most likely to get infected.
COVID-19 is spread in three main ways:
● Breathing in air when close to an infected person who is exhaling small droplets and particles that contain the virus.
● Having these small droplets and particles that contain virus land on the eyes, nose, or mouth, especially through splashes and sprays like a cough or sneeze.
● Touching eyes, nose, or mouth with hands that have the virus on them.
COVID-19 transmission: https://www.cdc.gov/coronavirus/2019-ncov/prevent-getting-sick/how-covid-spreads.html
The MIOSHA Emergency COVID-19 rules have been suspended as of June 22, 2021. The Federal OSHA COVID-19 Emergency Temporary Standard adopted by reference by MIOSHA is currently the only regulatory standard and it is applicable to healthcare settings/ healthcare industry. Additional worker safety information is based on current Center for Disease Control (CDC) guidelines, Department of Education guidance, MDHHS guidance, and the Federal OSHA Guidance: Protecting Workers: Guidance on Mitigating and Preventing the Spread of COVID-19 in the Workplace.
Each department, school or college needs to obtain permission to resume in-person work through the process developed by their reporting Executive Officer.
Department-specific COVID-19 Work Plan
Units are no longer required to keep department specific COVID-19 work plans.
Current university policy is that all campus employees working from home will continue to do so through at least mid-summer. Employees will begin a gradual return to more on-site work in the coming months at the direction of their unit’s leaders. Continuing all work that can be done remotely will reduce the total number of individuals coming to campus which lowers the risk of infection overall. This will also allow for density reductions within the workplace to allow for proper social distancing of the on-site personnel. There are no specific density requirements in place.
Consideration for employees’ needs for computers and other items, ensuring access to departmental shared drives and programs, and ensuring that workers' new workspace will not contribute to ergonomic discomfort must be in place.
Refer to UM-Dearborn ITS Resources for Working Remotely to aid students, staff and faculty to work or learn remotely. Refer to an EHS document regarding considerations for Ergonomics of working from home.
In accordance with UM-Dearborn Face Covering Policy, there are provisions to allow exceptions to certain workplace controls regarding distancing and masking in the workplace for those individuals who are fully vaccinated. Fully vaccinated means that at least two weeks have passed after receiving the final dose of an FDA-approved or authorized COVID-19 vaccine. As of March 21, 2021 (the start of the biweekly pay period), employees on the Ann Arbor, Dearborn and Flint campuses are eligible to use up to two hours of paid release time per vaccine dose. Bargained-for staff and staff who are funded by research grants may use paid release time for vaccination.
Effective June 21, 2021, individuals who are fully vaccinated and self-report their status to the university are generally exempt from the indoor masking and social distancing requirements. Until further notice, face coverings are still required - regardless of vaccination status - in classrooms, on UM-Dearborn transportation and in health care areas where patients may be present.
Employees may voluntarily submit their COVID-19 vaccine information through Wolverine Access COVID-19 Tile that contains the link to “Report your COVID-19 vaccination”. After submittal, allow 5 business days for processing and the employee will receive an email that your vaccination data is verified if information is acceptable. For now, this verification email can be forwarded to a supervisor and then the employee will no longer be required to mask or distance unless otherwise required as stated in the UM-Dearborn Face Covering policy.
Supervisors can encourage employees to self-report vaccine status voluntarily through the university process. Supervisors have the authority to validate that their employee has self-reported their status but are not responsible for monitoring.
UM-Dearborn Exposure Determination
According to the most recent MIOSHA COVID-19 Emergency Rules, which went into effect June 22, 2021, workplace settings, outside of the healthcare industry, are no longer required to conduct exposure determinations
COVID-19 Daily Self- Screening Protocols
All employees should be reminded that they are required to stay home if they are feeling sick or if at work, they should leave immediately if they begin to feel unwell. If they need to remain at work for a period of time before going home, an area with closable doors should be dedicated to isolate the ill individual from other co-workers. Sick leaves policies have been updated to ensure they are flexible and consistent with public health guidelines and posted on the University Human Resources COVID-19 website. The university is prohibited from discharging, disciplining or otherwise retaliating against employees who stay home or who leave work when they are at particular risk of infecting others with COVID-19.
Each day, all employees or contractors of our campus community who will enter campus buildings will be required to check themselves for COVID-19 symptoms by answering a brief set of questions. The ResponsiBLUE, our daily symptom checker tool, should be used to meet this required surveillance and it can also be completed on a desktop computer. For more information on ResponsiBLUE, click here. Other means of obtaining this information such as through us of time clocks, paper methods, etc. are also allowable if the questions are consistent and records are able to be maintained. Alternatively, this form can be used. – see attached word doc to link
University of Michigan Occupational Health Services (OHS) has established a COVID-19 hotline at 734-764-8021 (select prompt 1) to manage and triage employees for testing and tracking as required. The current hours (subject to change) are every day from 7:00 AM to 5:00 PM. After regular hours, employees are instructed to leave a message for a return call within 24 hours.
All university employees are encouraged to report symptoms through this mechanism and all employees are required to report if they have been tested positive for COVID-19 if they seek testing through another source. Students, faculty and staff on the Dearborn campus, who have tested positive for COVID-19 within the past 90 days outside of UM-Dearborn – that is, outside University Health Service (UHS), Occupational Health Services (OHS), or the Community Sampling and Tracking Program (CSTP) – are asked to report their positive test result here.
COVID-19 Positive Cases, Contact Tracing and Employee Notification
Employees working on campus should consult OHS for testing options when symptomatic or notified of a workplace close contact exposure. Employees that test positive for COVID-19 will be notified by OHS and provided guidance for self-isolation. Contact tracing and Employee Notification will be coordinated between OHS, University Health Service (UHS) and the Office of Emergency Management (OEM). When an employee is identified with a confirmed case of COVID-19, the local health department and any co-workers, contractors or suppliers whom may have come in contact with the individual will be notified within 24 hours.
Contact Tracing is a public health tool that has been used for decades to identify people who have come in contact with an SARS-CoV-2 positive individual in an attempt to reduce the spread of a disease. It will be used at Um-Dearborn to:
● Alert coworkers who may have been in close contact of the potential exposure;
● Identify localized outbreaks and ultimately control the spread of illness across campus.
Medical confidentiality and privacy will be maintained. Contacts will only be told they have been exposed to a positive case, but the identity of that case will NOT be directly revealed. Sensitivity to individual situations will be maintained.
Employees with a confirmed or suspected case of COVID-19 can return to the workplace only after they are no longer infectious according to the latest guidelines from the Centers for Disease Control and Prevention (“CDC”). The local health department and OHS will provide guidance about returning to work.
Employees that are fully vaccinated, do not need to quarantine after an exposure to a COVID-19 case unless directed to do so by a public health agency.
Refer to the Contract Tracing Protocol for Employee Positive COVID-19 Cases on the UM-Dearborn COVID-19 (Coronavirus) webpage for more information on the process. Also, refer to the COVID-19 Reporting Process for UM-Dearborn for further information on the response plan for confirmed cases in the workplace.
Vendors, Contractors and Visitors
All Vendors, contractors or visitors must use the guest version of ResponsiBLUE (guest.responsiblue.umich.edu) whenever they come to campus and be prepared to show verification if requested. Contractors working on UM-Dearborn/ AEC construction projects will have their own screening protocols which are verified internally through EHS. Contractors or vendors coming into units to conduct work on equipment under the direction of a department or unit should be screened.
Vendors, suppliers, contractors, etc. must follow the UM-Dearborn Face Covering policy. Contact Facilities Operations for more information on vendors, contractors and visitors on campus access policies.
Any outside entity must notify their university contact if they or a member of their team has a confirmed COVID-19 cases that occurs within 14 days of their last day on campus. If a confirmed case occurs in a building or a worksite, EHS will conduct contact tracing and notify medium and high risk exposure individuals, including contractors within 24 hours of notification.
All employees on-site are no longer required to take SARS-Cov2 and COVID-19 Training, however it is recommended. The training covers the following:
● Workplace infection-control practices, including information on vaccinations available for COVID-19.
● The proper use of personal protective equipment.
● Steps the employee must take to notify the university of any symptoms of COVID-19 or a suspected or confirmed diagnosis of COVID-19.
● How to report unsafe working conditions.
Below is the training module available in My LINC:
To view COVID-19 training completions for your area using our interactive dashboard, please contact “SafetyTraining@umich.edu” to request access.
COVID-19 Safety Coordinator
The COVID-19 Safety Coordinator is no longer required for worksites.
More details about UM-Dearborn travel restrictions and guidance can be found on the Global Michigan website, which will be updated to reflect changes. Information for students traveling back to campus in the fall will be posted in the near future.
Persons not on University business traveling internationally by air must meet CDC requirements before returning to the United States.
Before returning to the United States, passengers, including US citizens and fully vaccinated people, returning from international air travel are required to:
● Provide proof of a negative COVID-19 test no more than 3 days before returning by air to the United States or
● Documentation of having recovered from COVID-19
After returning to the United States from International travel the CDC recommends:
● Fully Vaccinated Travelers:
○ Get tested 3-5 days after travel AND self monitor for symptoms
● Not Vaccinated Travelers:
○ Stay home to self-quarantine for 7 days after travel.
○ Even if you test negative, stay home to self-quarantine for the full 7 days.
○ If you don’t get tested, it’s safest to stay home to self-quarantine for 10 days after travel.
Always follow state and local recommendations or requirements related to travel.
● U.S. Department of State (DOS) travel advisories: travel.state.gov
Health & Safety Measures
Protecting workers from exposure to SARS-CoV-2 is dependent on requiring basic infection prevention measures to be in place. The following are required practices that must be part of all workplace plans and enforced as standard practices for workplace health and safety.
Guidance for Specific Situations
Many workers rely on city or university bus travel for their commute as well as their daily travel across campus. Per the State of Michigan Safe Start guidance for K-12, CDC guidance and internal recommendations, UM-Dearborn Transportation and Parking has implemented the following recommendations:
● Placement of hand sanitizer where feasible for riders upon entering the bus.
● Requirement to wear face coverings while on the bus and signage posted.
● Daily cleaning and disinfection of busses
● Weather permitting, keeping windows open while the vehicle to increase air circulation
● Limit trip duration to 15 minutes or less, if possible.
Individuals should social distance at bus stops and as soon as possible after-disembarking, wash their hands or use alcohol-based hand sanitizer with greater than 60% alcohol.
Increasing ventilation can help minimize exposures in workspaces. Although the SARS-CoV-2 virus is thought to primarily be spread through person-to-person contact, increasing ventilation within a system’s operating parameters can be part of a strategy for workplaces. Refer to the COVID-19 HVAC Guidelines for UM-Dearborn Facilities.
Building Water Management
As many buildings on campus were at reduced building occupancy, a potential exists for stagnant water due to lowered or no use. Stagnant water can result in iron deposit, sediment formation, bacterial growth, heavy metal contamination, and aesthetic concerns such as discolored water with objectionable tastes and smells. Frequent flushing of building water lines can reduce these issues. Therefore a routine flushing program is recommended to prevent building water problems. Facilities Operations is managing this for the campus buildings that they serve following an established protocol. Other areas should consider flushing in the building by running all sources of water for several minutes before use.
Appendix A: Workplace control examples
Occupational safety and health professionals use a framework called the “hierarchy of controls” to select ways of controlling workplace hazards. In other words, the best way to control a hazard is to systematically remove it from the workplace, rather than relying on workers to reduce their exposure.
During a COVID-19 outbreak, when it may not be possible to eliminate the hazard, the most effective protection measures are (listed from most effective to least effective): engineering controls, administrative controls, safe work practices (a type of administrative control), and PPE. There are advantages and disadvantages to each type of control measure when considering the ease of implementation, effectiveness, and cost. In most cases, a combination of control measures will be necessary to protect workers from exposure to SARS-CoV-2.
Engineering controls involve isolating employees from work- related hazards. In workplaces where they are appropriate, these types of controls reduce exposure to hazards without relying on worker behavior and can be the most cost-effective solution to implement. Engineering controls for SARS-CoV-2 may include:
● Increasing ventilation rates in the work environment.
● Installing physical barriers, such as clear plastic sneeze guards. Note: Physical distancing is preferred over Plexiglass barriers, except in circumstances where close contact is unavoidable (such as checkout registers or reception desks)
Examples of engineering controls implemented on campus may include the following:
● Bus Partitions to create a physical barrier of separation of 6 feet between the bus driver and passengers
Administrative controls require action by the worker or employer. Typically, administrative controls are changes in work policy or procedures to reduce or minimize exposure to a hazard. Administrative controls for SARS-CoV-2 may include:
● Minimizing contact among workers by replacing face-to-face meetings with virtual communications and implementing telework, if feasible.
● Establishing alternating days or extra shifts that reduce the total number of employees in a facility at a given time, allowing them to maintain distance from one another while maintaining a full onsite work week.
● Developing emergency communications plans, including a forum for answering workers’ concerns and internet-based communications, if feasible.
● Providing workers with up-to-date education and training on COVID-19 risk factors and protective behaviors (e.g., cough etiquette and care of PPE).
● Training workers who need to use protecting clothing and equipment how to put it on, use/wear it, and take it off correctly, including in the context of their current and potential duties.
Safe Work Practices
Safe work practices are types of administrative controls that include procedures for safe and proper work used to reduce the duration, frequency, or intensity of exposure to a hazard. Safe work practices for SARS-CoV-2 include:
● Providing resources and a work environment that promotes personal hygiene. For example, provide tissues, no-touch trash cans, hand soap, alcohol-based hand rubs containing at least 60 percent alcohol, disinfectants, and disposable towels for workers to clean their work surfaces.
● Requiring regular hand washing or using of alcohol-based hand rubs. Workers should always wash hands when they are visibly soiled and after removing any PPE.
● Post handwashing signs in restrooms.
● Practicing social distancing.
Personal Protective Equipment (PPE)
While engineering and administrative controls are considered more effective in minimizing exposure to SARS-CoV-2, PPE may also be needed to prevent certain exposures. While correctly using PPE can help prevent some exposures, it should not take the place of other prevention strategies.
Examples of PPE include: gloves, goggles, face shields, face masks, and respiratory protection, when appropriate. During an outbreak of an infectious disease, such as COVID-19, recommendations for PPE specific to occupations or job tasks may change depending on geographic location, updated risk assessments for workers, and information on PPE effectiveness in preventing the spread of COVID-19.
UM-Dearborn EHS can provide additional detail regarding hazard assessment, selection, maintenance and use of required PPE.
Employers are obligated to provide their workers with PPE needed to keep them safe while performing their jobs. The types of PPE required during a COVID-19 outbreak will be based on the risk of being infected with SARS-CoV-2 while working and job tasks that may lead to exposure.
Current required respirator usage for COVID-19 protection on Campus:
- N95 respirators are used by DPS for transport of suspected COVID-19 individuals.
- N95 respirators are worn by our custodial staff during expanded cleaning of the area(s) occupied by a COVID-19 positive faculty staff or student
- Face shields may also be worn on top of a respirator to prevent bulk contamination of the respirator.