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COVID-19 Preparedness and Response Plan

LMC Revised Date

Office of Origin: Human Resources
Responsibility: Executive Director, Human Resources
Original Date Adopted: 5/18/2020    
Dates Revised: 06/10/20, 06/30/20, 07/25/20, 12/03/20, 08/25/21


Lake Michigan College (LMC or “the College”) takes the health and safety of its employees, students, and visitors seriously. LMC is committed to ongoing efforts to provide a safe workplace and learning environment by reducing the risk of exposure to COVID-19 on campus.

This Plan is based on information and guidance from local, state, and federal entities available at the time of its development, and is subject to change as further guidance is released. The College may amend this Plan from time to time based on operational needs. Organizations relied upon for guidance include Centers for Disease Control (CDC), Occupational Safety and Health Agency (OSHA), Michigan Occupational Safety and Health Administration (MIOSHA), Berrien County Health Department, and other public agencies.

In conjunction with the organizations above, the College has identified areas to address to mitigate the threat of transmission of COVID-19 in the workplace. This Plan outlines those efforts, and is broken out as follows:

  • COVID-19 Safety Taskforce
  • Level of Community Transmission
  • Requirements to Enter Campus
    • COVID-19 Trainings
    • Daily Screenings
    • Outside Contractors and Vendor Controls
  • Responsibilities of Those on Campus
    • Familiarization with Symptoms & Exposure Risks of COVID-19
    • Control & Preventative Protocols for All Workers
    • Expectations of Employees
    • Expectations of Supervisors and Managers
  • Employees Who May Not Report to Work
    • Return to In-Person Work Requirements
  • College Response to COVID-19 Diagnoses or Symptoms
  • College Practices to Minimize Exposure to COVID-19
    • In-Person Work Determination
    • Worker Exposure Classification
    • Worksite Preventative Measures & Controls for Limiting Exposure
    • Worksite Cleanliness Measures
  • Assistance for Employees Affected by COVID-19
    • Federal Programs
    • College Programs

COVID-19 Safety Taskforce

The development of this Plan was led by the COVID-19 Safety Taskforce (the Taskforce.) The Taskforce is responsible for staying abreast of federal, state, and local guidance and incorporating those requirements and recommendations into the Plan. The Taskforce is also responsible for reviewing Human Resources (HR) and other College policies and procedures to make sure they are consistent with this Plan and existing federal, state, and local requirements. The Taskforce Co-Chairs may be reached as follows:

Potential transmission sources of COVID-19 in the workplace:  

  1. The general public/visitors
  2. Customers/students
  3. Residents (guidance to be developed prior to residents returning to campus)
  4. Co-workers
  5. Construction contractors/vendors

Level of Community Transmission

College administrators, working with local public health officials and using the CDC Indicators and Thresholds for Community Transmission of COVID-19, will assess the level of community transmission, including variants, to understand the burden of disease in the community. The higher the level of community transmission, the more likely that it will be introduced into the college from the community.

Table 1. CDC Indicators and Thresholds for Community Transmission of COVID-19

 

 

Indicator

Low Transmission

Blue

Moderate Transmission

Yellow

Substantial Transmission

Orange

High

Transmission

Red

Total new cases per 100,000 persons in the past 7 days2

0-9

10-49

50-99

≥100

Percentage of NAATs that are positive during the past 7 days3

<5.0%

5.0%-7.9%

8.0%-9.9%

≥10.0%

See CDC’s COVID Data Tracker for details regarding this table.

Strategies outlined in this plan will be utilized as required by the Michigan Department of Health and Human Services (MDHHS) and/or local county Health Department recommendations given the current community transmission levels. The need for implementation of prevention strategies will be communicated to the College community as necessary.

 

Requirements to Enter Campus

COVID-19 Training

All employees must successfully complete mandatory COVID-19 training as required.Topics covered by this training include many of those in this document.  

Daily Screenings

Daily health screenings will be required prior to entry into campus. Screenings may include temperature checks with a touchless thermometer. Online screening questions are provided through the public college website "Symptom Checker" available here. Screening questions are based on CDC and Berrien County Health Department guidance. The Symptom Checker is monitored for any reasons flagging an employee, student or visitor as not able to come on campus. 

Outside Contractors & Vendor Controls

The College will take the following steps to minimize COVID-19 exposure from contractors/vendors working on campus:

  1. Provide contractors and vendors with a required on-site presence with the LMC Infectious Disease and Social Distancing Measure procedure and require written acknowledgement of the intent to comply.
  2. Review contractor/vendor COVID-19 exposure mitigation plans as well as documentation of any specific requirements for the work that must be conducted.
  3. Require all contractors/vendors to adhere to College procedures in place at the time of their visit to campus, such as health screening and requirement for face coverings.
  4. Not allow contractors/vendors to use public spaces for breaks if the College is closed to the public.
  5. Request that the contractor/vendor limit the number of visitors to the worksite, including a contractor/vendor trailer or office.
  6. Identify alternate supply chains for critical goods and services.

Responsibilities of Those on Campus

Familiarization with Symptoms & Exposure Risks of COVID-19

Employees and contractors must familiarize themselves with the symptoms and exposure risks of COVID-19 to protect themselves and others. Those with COVID-19 have had a wide range of symptoms reported, ranging from mild symptoms to severe illness. Symptoms may appear 2-14 days after exposure to the virus.

People with the below symptoms or combination of symptoms may have COVID-19:

  1. Cough
  2. Shortness of breath or difficulty breathing
  3. Fever or chills
  4. Fatigue
  5. Muscle pain or body aches
  6. Headache
  7. Sore throat
  8. New loss of taste or smell
  9. Congestion or runny nose
  10. Nausea or vomiting
  11. Diarrhea

An employee who develops COVID-19 symptoms as described must notify their supervisor immediately, and should consult their healthcare provider. (More information on this situation is in the LMC procedure Supervisor Responsibilities – Employee Calls in Sick – COVID-19.) Likewise, if an unvaccinated employee comes into close contact with someone showing these symptoms, they must notify their supervisor immediately and should consult their healthcare provider.

Employees should not report to campus or should immediately leave campus upon experiencing symptoms.

Unvaccinated employees should not report to campus after learning of close contact with a COVID-19 positive individual.  

If an employee/student/guest becomes ill while on campus and is unable to drive due to illness, that individual should isolate in one of the following areas while waiting for transportation:

  1. Benton Harbor Campus – Wellness Center Changing Room in Main Building, D Wing, Rooms D113 & D122 
  2. Niles Campus – Room 114A
  3. South Haven Campus – Room 126

“Close contact” is not brief or incidental contact with a person with COVID-19 symptoms; instead, the CDC defines “close contact” as either:

  1. Being within 6 feet of an infected person for a cumulative total of 15 minutes or more over a 24-hour period; or
  2. You provided care at home to someone who is sick with COVID-19; or
  3. You had direct physical contact with someone who has COVID-19 (examples: hugged or kissed them); or
  4. You shared eating or drinking utensils; or 
  5. They sneezed, coughed or in some way transmitted respiratory droplets to you. 

Control & Preventative Protocols for All Workers

OSHA and the CDC have provided the following control and preventative measures for all workers, regardless of exposure risk:

  1. 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.
  2. Avoid touching your eyes, nose, or mouth with unwashed hands.
  3. Follow appropriate respiratory etiquette, which includes covering for coughs and sneezes.
  4. Avoid close contact with people who are sick.
  5. When required based on Level of Community Transmission:
    1. Maintain appropriate social distance of at least 6 feet to the greatest extent possible.
    2. Wear a face covering (over nose and mouth) when away from home. Remember a cloth face cover is not a substitute for social distancing.
    3. All employees must wear a mask when indoors on campus (unless alone in own office), and when outdoors if near other people/unable to maintain social distancing of at least 6 feet. Masks must fit snugly on face and always cover both nose and mouth.
    4. Wipe down surfaces of your work area daily.
    5. Wipe down shared equipment and high touch surfaces daily and before/after use.  

Expectations of Employees

The College expects all employees to adhere to prevention efforts while on campus. In order to minimize the impact of COVID-19 at College worksites, everyone must play their part. As described herein, the College has established various housekeeping, social distancing, and other best practices to minimize exposure to COVID-19 and prevent its spread in the workplace. All employees must follow these practices at all times for them to be effective.

Beyond these best practices, the College requires employees to report immediately to their supervisor if they are experiencing signs or symptoms of COVID-19, as described herein.

If employees have questions about this Plan or COVID-19, they should ask their supervisor or contact HR.

Retaliation against any employee who adheres to the College's COVID-19 related guidelines or raises workplace safety or health concerns is strictly prohibited and will be addressed without delay.

Expectations of Supervisors and Managers

All supervisors must be familiar with this Plan and be ready to answer questions from employees. Supervisors must set a good example by following this Plan at all times. This involves practicing good personal hygiene and worksite safety practices to prevent the spread of the virus. Supervisors must encourage and expect this same behavior from all employees.    

Employees Who May Not Report to Work

Employees may not report to work or remain in the workplace if they test positive or display symptoms of COVID-19 or if other risk and exposure determinations are made, as described below. This information may present itself through the responses to the daily health screening via the Symptom Checker or it may be reported through a supervisor or to HR directly.

Specifically, employees may not report to work if:

  1. The employee tests positive for COVID-19 or displays signs of COVID-19 symptoms, as listed above. Employees who have tested positive for COVID-19 or are experiencing signs or symptoms of COVID-19 are required to report it immediately to their supervisor.
    or
  2. The employee is not vaccinated and has, in the last 14 days, had close contact with or lived with any person having a confirmed COVID-19 diagnosis.
    or
  3. The employee is not vaccinated and has, in the last 14 days, had close contact with or lived with a person displaying COVID-19 symptoms, as described above.

Any employee who develops symptoms while on campus must separate immediately from other individuals and go home/seek medical care as outlined in the Infectious Disease Prevention and Social Distancing procedure.

These employees may only resume in-person work upon meeting all return-to-work requirements outlined below and being cleared to return by HR. Refer to current COVID-19 Student/Employee Guidance for Illness or Exposure document (the “scenario chart.”)

Return to In-Person Work Requirements

Employees diagnosed with COVID-19 or having experienced symptoms of COVID-19 may only return from isolation to in-person work after confirmation of the cessation of symptoms and contagiousness.  Current evidence supports ending isolation and precautions for most persons with COVID-19 using a symptom-based strategy as defined by the CDC.

Under the symptom- based strategy, employees may return in-person to work upon achieving the following:

  1. At least 24 hours of resolution of fever without use of fever-reducing medications;
  2. Improvement of other symptoms, and
  3. and, if unvaccinated, at least 10 days have passed since symptoms first appeared.

If all criteria are met, the employee may return to in-person work on the 11th day. 

A limited number of persons who are severely immunocompromised, or with severe COVID-19 illness, may require isolation away from others beyond 10 days and up to 20 days after symptoms first began.  A test-based return strategy may be used in these cases.
    
Employees who tested positive for COVID-19 but did not develop symptoms require a 10-day isolation period following the date of their first positive viral test.  These employees will typically be cleared to return to work on the 11th day.

There are differing quarantine timelines for employees who came into close contact with, or live with, an individual with a confirmed diagnosis or symptoms. 

Vaccination status may also impact timelines.  Proof of vaccination must be provided to HR in order to reduce quarantine or isolation timeframes.

Employees are typically required to submit a release to return in-person to work from a healthcare provider. Depending on the current stress upon the healthcare system, if an employee is unable to produce a release form, the College may accept a written statement from an employee confirming all the factors supporting their release to return to in-person work.

Requirements for returning in-person to work are based upon federal, state, and local guidance, and are subject to change. 

College Response to COVID-19 Diagnoses or Symptoms

An individual with a COVID-19 diagnosis or who displays COVID-19 symptoms as described above must immediately leave the campus or not come on to campus, whichever applies. Notification of COVID-19 diagnosis and/or symptoms may present itself through the responses to the daily health screening via the Symptom Checker.

The College is reliant on students and visitors self-reporting using an online tool. To assist with student reporting, faculty have been trained on where to find the online form and encourage students to file a report when reported to them by the student. The Advising Department manages the process for students and visitors, with assistance from Director of Advising and the Directors of Housing and/or Intercollege Athletics if appropriate. 

HR manages the process for employees and contractors. Employees and contractors are required to report through their supervisor.  

The College will take the following actions upon notification of COVID-19 diagnosis and/or symptoms:

  1. Detailed interview is taken by the respective managing department. Gathered information includes last date on campus, onset of symptoms and/or exposure date, impacted areas and individuals on campus, and present symptoms. Using the College’s scenario chart and in conjunction with the health department, the employee or student is issued a quarantine or isolation length and return date. 
  2. Inform all employees who had close contact with and near whom the diagnosed/symptomatic employee worked of a potential exposure within 24 hours.
  3. Keep the identity of the diagnosed/symptomatic employee confidential in compliance with regulatory requirements.
  4. Immediately notify the Berrien County Health Department of COVID-19 outbreaks.
  5. Conduct deep cleaning of the diagnosed/symptomatic employee’s workstation, as well as those common areas potentially infected by the employee.
  6. Complete an OSHA Form 300 (Log of Work-Related Injuries and Illnesses) and Form 301 (Injury and Illness Incident Report) if “it is more likely than not that a factor or exposure in the workplace caused or contributed to the illness.” If an employee infects a coworker, the coworker has suffered a work-related illness if one of the recording criteria (e.g., medical treatment or days away from work) is met.
  7. All unvaccinated employees who worked in sustained, close proximity to the diagnosed / symptomatic employee will be required to work off-site (e.g., at home) for at least 14 days; however, if an exposed employee later develops COVID-19 symptoms and/or receive a confirmed diagnosis, they may not report on-site until all return-to-work requirements are met, as outlined herein.   

 

College Practices to Minimize Exposure to COVID-19

As described below, the College has instituted various housekeeping, social distancing, and other best practices to minimize exposure to COVID-19 and prevent its spread in the workplace.

In-Person Work Determination

If determined necessary, in-person work may be prohibited for employees to the extent that their work activities can feasibly be conducted remotely. Factors such as the need for in-person communication or instruction, need for usage of technology / machinery / equipment not available remotely, and need for access to confidential or paper records not available remotely will be considered.

Worker Exposure Classification

In accordance with and based on OSHA guidance, the College has classified its positions into one or more the following “worker exposure” classifications:  

  1. Lower Exposure Risk - work performed does not require direct contact with people known or suspected to be infected with COVID-19 or require frequent close contact with the public.
  2. Medium Exposure Risk - work performed requires frequent and/or close contact with people who may be infected with COVID-19 but who are not known COVID-19 patients, or contact with the general public in areas where there is ongoing community transmission.
  3. High Exposure Risk - work performed requires high potential for exposure to known or suspected source of COVID-19. (At the College, this level of exposure would occur when clinical faculty provide instruction to students on the delivery of health services involving exposure to patients.)
  4. Very High Exposure Risk - work performed has a high potential for exposure to known or suspected sources of COVID-19 during specific medical, postmortem, or laboratory procedures. (At the College, this level of exposure would occur when clinical faculty provide instruction to students on performing certain medical/dental procedures involving exposure to patients.)

Each job category was assigned to a worker exposure classification based on types of potential exposure to COVID-19. Documentation of the classifications and the primary methods for minimizing COVID-19 exposure risk are available to employees upon request from HR.

Worksite Preventative Measures & Controls for Limiting Exposure

The College encourages vaccination, but it is not a requirement for employment or registration as a student (except if living in the residence hall and/or where required by hospitals for clinical students). The College has established strategies to minimize potential exposure to COVID-19 from others, including personal protective equipment and work practice controls, administrative controls, and engineering controls. These are described below.

The following are worksite preventative measures and workplace controls for limiting exposure for all employees:

  1. Unvaccinated employees, students, and visitors are recommended to wear masks in accordance with CDC guidelines. Signage communicating this recommendation will be at all building entrances.
  2. Based upon community transmission level, all employees (as well as students and visitors) may be required to wear a mask in all College buildings
  3. Non-medical cloth masks will be provided to all employees.
  4. Disposable masks will be provided to students and visitors who do not have one of their own.
  5. Hands should be washed before putting on a mask, and mask should fit snugly against the sides of the face and secure under the chin, and must always cover both the nose and mouth. Make sure you can breathe easily.
  6. Do not touch the mask while wearing, and if you do, wash your hands.
  7. To remove your mask, untie the strings behind your head or stretch the ear loops or ties. Handle only by the ear loops or ties. Fold the outside corners together. Place mask in washing machine, or if you must wear again before washing, store face down on a paper towel or hanging on a paper bag. Be careful not to touch your eyes, nose, and mouth when removing your mask and wash hands immediately after removing.
  8. Do not place a mask on a child younger than 2 years of age, or anyone who has trouble breathing, is unconscious, incapacitated or otherwise unable to remove the mask without assistance.
  9. Because cloth masks offer some level of protection to the wearer but primarily protect other people from the wearer’s respiratory secretions, they are not considered PPE. 

Personal Protective Equipment (PPE)

  1. Appropriate PPE will be identified through assessment of known or suspected hazards based upon an employee’s job duties and their work environment.
  2. Will be properly fitted and refitted (i.e., medical-grade masks or respirators).
  3. Will be consistently and properly worn and cared for (removal, cleaning, and storage) as required to avoid contamination of self, others, or the work environment.
  4. Will be regularly inspected and replaced as needed.
  5. Employees who work within six feet of patients known to be, or suspected of being, infected with COVID-19 and those performing aerosol-generating procedures, need to use respiratory protection as determined by the appropriate medical professional through our occupational health services provider.

Work Practice Controls

  1. Mandatory training is required for all employees.
  2. Employees, students, and guests should keep a distance of at least 6 feet between themselves and others, both indoors and outdoors, when possible or at all times if required based upon community transmission levels.
  3. The COVID-19 Resources subsite on the Employee Portal will electronically house all employee resources related to COVID-19.
  4. Visual reminders will be posted about safe work practices, such as social distancing, proper handwashing, and COVID-19 symptoms.
  5. Signage with maximum occupancies for areas where gathering may need to occur will be posted as necessary.
  6. Tissues and no-touch disposal receptacles will be provided to minimize exposure to infectious secretions.
  7. Consistent use of good hand hygiene will be expected of all employees. This includes regularly washing hands with soap and water for at least 20 seconds. If soap and water are not readily available, employees are expected to use alcohol-based hand sanitizer that is at least 60% alcohol. If hands are visibly dirty, soap and water should be chosen over hand sanitizer.
  8. The College will ensure that adequate supplies of soap and hand sanitizer are maintained. Hand sanitizer will be maintained in multiple locations. Employees must notify their supervisor or Facilities Management if supplies need to be replenished.
  9. Employees are expected to avoid physical contact, such as shaking hands.
  10. Employees are expected to avoid other employees’ phones, desks, offices, other work tools and equipment and other commonly touched surfaces whenever possible. If sharing is unavoidable, employees are expected to disinfect items/surfaces before and after use.
  11. Eating should take place in an employee’s private office or in eating areas that allow social distancing. Based upon community transmission level, designated eating areas may be assigned.
  12. Employees are expected to avoid sharing food utensils and food with others.
  13. Meetings should be conducted remotely when possible.  For required in-person meetings, space should be considered that allows for social distancing for all participants. Based on based upon community transmission levels, remote meetings may be required.

Administrative Controls

Based upon community transmission levels:

  1. At least 6 feet distance should be maintained between people if possible.
  2. Employees may not be able to gather unmasked in workrooms, breakrooms, copier rooms, or any other areas where employees may have normally socialized.  
  3. If equipment is used in shared rooms (e.g., copier, refrigerator, microwave, etc.), employees must disinfect items/surfaces before and after use.
  4. Employees may be expected to temporarily work from home, when possible and when feasible with respect to job duties, and with supervisor approval.
  5. Staggered schedules may be used to promote social distancing within certain work settings, when possible and when feasible with respect to job duties, and with supervisor approval.
  6. Meeting room maximum capacities will be posted if capacity limitations are in place.
  7. Unnecessary business travel may be cancelled or postponed until deemed safe by the College to travel.
  8. Supervisors must have reviewed normal departmental/unit operating activities and tasks and develop specific work plans to minimize potential exposure to COVID-19.

Engineering Controls

In addition to those above, and based upon community transmission levels, the following are engineering controls for limiting exposure for Medium Exposure Risk employees.

  1. Stanchions, signage, and floor mats may be placed to define social distancing boundaries in more open areas.
  2. Face shields may be provided by the College for optional wearing.
  3. Disposable gloves will be provided by the College for employees in positions required to wear gloves.
  4. Physical barriers (e.g., sneeze guards between employees and co-workers, students, and visitors) may be provided/placed by the College.
  5. Outside air ventilation will be increased, when and where possible, in areas of greater occupancy and air in the system will be flushed after hours to support healthier indoor environmental quality.

Worksite Preventative Measures and Workplace Controls

In addition to all items listed above, and based upon community transmission levels, the following are worksite preventative measures and workplace controls for limiting exposure for High Exposure Risk and Very High Exposure Risk employees

  1. The College will provide appropriate PPE and comply with all infectious-disease requirements for healthcare facilities.    

Worksite Cleanliness Measures

The College will:

  1. Increase ventilation rates and circulation, where possible, throughout work sites.
  2. Perform routine environmental cleaning and disinfection, especially of common areas.
  3. Provide hand sanitizer in high-traffic area.
  4. At least after each weekday, clean and disinfect all frequently touched surfaces in the workplace, such as workstations, keyboards, telephones, handrails, and door handles.
  5. Provide disposable disinfecting wipes so that commonly used surfaces (e.g., doorknobs, keyboards, remote controls, desks, other work tools and equipment, microwaves, refrigerators) can be wiped down by employees before and after each use.
  6. Maintain Safety Data Sheets of all disinfectants used on site.
  7. Consult with Custodial Contractor for increased regular cleaning and post-exposure cleaning.

Assistance for Employees Affected by COVID-19

The following outlines certain programs available to employees affected by COVID-19. Employees are encouraged to contact HR with questions regarding these programs.

Federal Programs

Under the Family and Medical Leave Act (FMLA), employees may be entitled to unpaid leave if their absence is related to their own serious health condition or that of a family member. COVID-19 may constitute a serious health condition where “complications arise.”

Under the Americans with Disabilities Act (ADA), if an employee requests an accommodation because of a condition that may be complicated by COVID-19 (e.g., cystic fibrosis, emphysema, COPD), the College engages in the interactive process to provide a reasonable accommodation. This may mean allowing the employee to work remotely (if reasonable) for a period of time or work an alternative schedule.

College Programs

The College’s Employee Assistance Program (EAP) provides a limited number of counseling services for eligible employees and their immediate family members (e.g., those who could be covered under other LMC benefit plans). The services offered are both free and confidential. Referrals to counselors within LMC’s health insurance network are available if a participant wishes to continue to receive counseling beyond the free EAP sessions. Phone and video appointments are available. HelpNet may be contacted by telephone at 800-969-6162 or their website.

 

References

CDC
Infectious Disease Prevention and Social Distancing
OSHA
MIOSHA Emergency Rules-Coronavirus Disease 2019 (COVID-19)
Supervisor Responsibilities – Employee Calls in Sick – COVID-19

 

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