Benton Harbor Campus is open 8 a.m.-5 p.m. Monday through Friday. Niles and South Haven campuses close at 4 p.m. on Friday; check additional hours for some student services on the myLMC page. Before you come to campus, please call (269) 927-1000 to make sure your needs will be met.
COVID-19 Preparedness and Response Plan
Office of Origin: Human Resources
Responsibility: Executive Director, Human Resources
Original Date Adopted: 5/18/2020
Dates Revised: 6/10/2020, 6/30/2020, 7/25/2020
Last Date Approved:
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), Berrien County Health Department, and other public officials.
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
- Requirements to Enter Campus
- COVID-19 Training
- Daily Screenings
- Outside Contractors & 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
- Worker Exposure Classification
- Worksite Preventative Measures & Controls for Limiting Exposure
- Worksite Cleanliness Measures
- Assistance for Employees Affected by COVID-19
- Federal Programs
- State 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 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:
- Denise Eberth, Executive Director, Human Resources
Phone: 269-927-8704 Email: email@example.com
- Sara VanderVeen, Executive Director, Facilities Management
Phone: 989-948-9390 Email: firstname.lastname@example.org
Potential transmission sources of COVID-19 in the workplace:
- The general public/visitors
- Residents (guidance to be developed prior to residents returning to campus)
- Construction contractors/vendors
Requirements to Enter Campus
All employees must successfully complete mandatory COVID-19 training prior to returning to campus. Topics covered by this training include many of those in this document.
Daily health screenings will be required prior to entry into campus. Screenings may include temperature checks with a touchless thermometer. Screening questions will be based on CDC and Berrien County Health Department guidance.
Outside Contractors & Vendor Controls
The College will take the following steps to minimize COVID-19 exposure from contractors/vendors working on campus:
- 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.
- Review contractor/vendor COVID-19 exposure mitigation plans as well as documentation of any specific requirements for the work that must be conducted.
- 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.
- Not allow contractors/vendors to use public spaces for breaks if the College is closed to the public.
- Request that the contractor/vendor limit the number of visitors to the worksite, including a contractor/vendor trailer or office.
- 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:
- Shortness of breath or difficulty breathing
and/or at least two of these symptoms:
- Fever (either feeling feverish or a temperature of 100.4 degrees or higher)
- Repeated shaking with chills
- Muscle pain
- Sore throat
- New loss of taste or smell
- Congestion or runny nose
Less common are gastrointestinal symptoms, i.e.: nausea, vomiting or diarrhea.
If an employee develops a fever and symptoms of respiratory illness 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 employee comes into close contact with someone showing these symptoms, they must notify their supervisor immediately and should consult their healthcare provider.
“Close contact” is not brief or incidental contact with a person with COVID-19 symptoms; instead, the CDC defines “close contact” as either:
- Being within approximately 6 feet of a COVID-19 infected person or a person with any COVID-19 symptom(s) for a “prolonged period of time;” or
- Having direct contact with infectious secretions of a COVID-19 infected person or person with any COVID-19 symptom (e.g., being coughed on).
There is no precise definition of “prolonged period of time.” The CDC estimates a range from 10 to 30 minutes. To better protect employees, the College has adopted the lower end of this range and considers a “prolonged period” to be 10 to 15 minutes of exposure.
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:
- 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.
- Avoid touching your eyes, nose, or mouth with unwashed hands.
- Follow appropriate respiratory etiquette, which includes covering for coughs and sneezes.
- Avoid close contact with people who are sick.
- While there is community spread of COVID-19, maintain appropriate social distance of 6 feet to the greatest extent possible.
- Wear a face covering (over nose and mouth) when away from home. Remember a cloth face cover is not a substitute for social distancing.
- Wipe down surfaces of your work area, especially shared equipment and high touch surfaces, daily.
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 manager or supervisor or contact Human Resources. 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 addresses without delay.
Expectations of Supervisors and Managers
All managers and supervisors must be familiar with this Plan and be ready to answer questions from employees. Managers and 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. Managers and 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.
Specifically, employees may not report to work if:
- 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 manager or supervisor.
- The employee has, in the last 14 days, had close contact with or lived with any person having a confirmed COVID-19 diagnosis.
- The employee 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 College’s 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 Human Resources.
Return to In-Person Work Requirements
Employees diagnosed with COVID-19 or having experienced symptoms of COVID-19 may only return in-person to work after confirmation of the cessation of symptoms and contagiousness. Proof of this must be demonstrated via the test-based strategy or the symptom-based strategy as defined by the CDC.
A test-based strategy is no longer recommended to determine when to discontinue home isolation, except in certain circumstances. For an employee who has tested positive for COVID-19 but never developed symptoms, he/she may return to in-person work 10 days after the date of their first positive RT-PCR test. Under this strategy, employees who have experienced COVID-19 symptoms and had a positive COVID-19 test, may return in-person to work upon achieving the following:
- Resolution of fever without the use of fever-reducing medications;
- Improvement in respiratory symptoms (e.g., cough, shortness of breath); and
- 10 days have passed since his/her first positive RT-PCR test.
Under the symptom- based strategy, employees may return in-person to work upon achieving the following:
- At least 24 hours have passed since recovery, which is defined as resolution of fever without use of fever-reducing medications;
- Improvement in respiratory symptoms (e.g., cough, shortness of breath); and
- At least 10 days have passed since symptoms first appeared.
Employees who came into close contact with, or live with, an individual with a confirmed diagnosis or symptoms may return in-person to work after:
- Either 14 days have passed since the last close contact with the diagnosed/symptomatic individual, or
- The diagnosed/symptomatic individual receives a negative COVID-19 test.
Employees are typically required to submit a release to return in-person to work from a healthcare provider. Given the current stressors on 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 employee or other individual with a COVID-19 diagnosis or who displays COVID-19 symptoms as described above must immediately leave the worksite.
The College will take the following actions upon notification of employee’s COVID-19 diagnosis and/or symptoms:
- Inform the local health department and all employees who had close contact with and near whom the diagnosed/symptomatic employee worked of a potential exposure within 24 hours.
- Keep the identity of the diagnosed/symptomatic employee confidential in compliance with regulatory requirements.
- Immediately notify the Berrien County Health Department of a reported positive COVID-19.
- Conduct deep cleaning of the diagnosed/symptomatic employee’s workstation, as well as those common areas potentially infected by the employee.
- 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.
- All 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 these exposed employees later develop 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.
Worker Exposure Classification
In accordance with and based on OSHA guidance, LMC has classified its positions into one or more the following categories:
- Lower exposure risk - Employee “worker exposure” is classified as lower risk when the 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.
- Medium exposure risk - Employee “worker exposure” is classified as medium risk when the 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.
- High exposure risk – Employee “worker exposure” is classified as high risk when the work performed requires high potential for exposure to known or suspected source of COVID-19. (At LMC, this level of exposure would occur when clinical faculty members provide instruction to students on the delivery of healthcare services involving exposure to patients.)
- Very high exposure risk - Employee “worker exposure” is classified as very high risk when the work performed has a high potential for exposure to known or suspected sources of COVID-19 during specific medical, postmortem, or laboratory procedures. (At LMC, this level of exposure would occur when clinical faculty members provide instruction to students on performing certain medical and 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 Human Resources.
Worksite Preventative Measures & Controls for Limiting Exposure
LMC 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:
Cloth Face Mask/Coverings
- All employees (as well as all students and visitors) are required to wear a face covering/mask in all College buildings at all times, unless working alone in an office or outdoors with the ability to maintain social distancing. Masks must be worn over nose and mouth.
- The College will provide employees with non-medical grade face coverings.
- Disposable masks will be provided to students and visitors who do not have one of their own.
- Wash hands before putting on your mask. Put mask over your nose and mouth and secure under your chin. Try to fit the mask snugly against the sides of your face. Make sure you can breathe easily.
- Do not touch your mask while wearing, and if you do, wash your hands.
- 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.
- 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.
- Because cloth masks protect other people from the wearer’s respiratory secretions, rather than protecting the wearer, they are not considered PPE.
- Face shields may not be worn as a substitute for a cloth face covering/mask, based on CDC guidelines.
- The only time you are not required to wear a face covering while on-site is if you are in your own private office with the door closed. A face covering should also be worn if you are in your office with another individual.
Personal Protective Equipment (PPE)
- Appropriate PPE will be identified through assessment of known or suspected hazards based upon an employee’s job duties and their work environment.
- Will be properly fitted and refitted (i.e., medical-grade masks or respirators).
- 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.
- Will be regularly inspected and replaced as needed.
- 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
- Mandatory training is required for all employees.
- Employees, students, and guests must keep a distance of at least 6 feet between themselves and others, both indoors and outdoors, at all times.
- The COVID-19 Resources subsite on LMC’s Employee Portal will electronically house all employee resources related to COVID-19.
- Visual reminders will be posted about safe work practices, such as social distancing, proper handwashing, and COVID-19 symptoms.
- Signage with maximum occupancies for areas where gathering may need to occur will be posted.
- Tissues and no-touch disposal receptacles will be provided to minimize exposure to infectious secretions.
- 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.
- 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.
- Employees are expected to avoid physical contact, such as shaking hands.
- 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.
- Employees are expected to avoid sharing food utensils and food with others.
- Employees are expected to avoid meeting face-to-face, and to use the telephone, online conferencing, email, or instant messaging to conduct business as much as possible, even when participants are in the same building.
- Employees may not gather in workrooms, breakrooms, copier rooms, or any other areas where employees may have normally socialized. If use of such a room is unavoidable while another individual in the room, at least 6 feet distance must be maintain between people. If equipment is used in such rooms, such as copier, refrigerator, microwave, etc., employees must disinfect items/surfaces before and after use.
- Employees are expected to temporarily work from home, when possible and when feasible with respect to job duties, and with supervisor approval.
- Staggered schedules will be used to promote social distancing within certain work settings, when possible and when feasible with respect to job duties, and with supervisor approval.
- In-person meetings must be limited to as few as possible, and meeting space must allow for social distancing. Meeting room maximum capacities will be posted.
- Unnecessary business travel is cancelled or postponed until deemed safe by the College to travel.
- Supervisors must have reviewed normal departmental / unit operating activities and tasks and develop specific work plans to minimize potential exposure to COVID-19.
In addition to those above, the following are engineering controls for limiting exposure for medium exposure risk employees
- Stanchions, signage, and floor mats will be placed to define social distancing boundaries in more open areas.
- Face shields will be provided by the College for optional wearing.
- Disposable gloves will be provided by the College for employees in positions required to wear gloves.
- Physical barriers such as sneeze guards between employees and co-workers, students, and visitors will be provided/placed by the College.
- The College will increase outside air ventilation, where possible, in areas of greater occupancy and flush air in system after hours to support healthier indoor environmental quality.
In addition to all items listed above, the following are worksite preventative measures and workplace controls for limiting exposure for high and very high exposure risk employees
- LMC will provide appropriate PPE and comply with all infectious-disease requirements for healthcare facilities.
Worksite Cleanliness Measures
The College will:
- Increase ventilation rates and circulation, where possible, throughout work sites.
- Perform routine environmental cleaning and disinfection, especially of common areas.
- Provide hand sanitizer in high-traffic area.
- At least after each weekday, clean and disinfect all frequently touched surfaces in the workplace, such as workstations, keyboards, telephones, handrails, and door handles.
- 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.
- Maintain Safety Data Sheets of all disinfectants used on site.
- Consult with Custodial Contractor for increased regular cleaning and post-exposure cleaning.
Assistance for Employees Affected by COVID-19
The following outlines several programs available to employees affected by COVID-19. Employees are encouraged to contact human resources with questions regarding these programs and to monitor emails and announcements concerning employee benefits.
Under the Families First Coronavirus Response Act (FFCRA)’s Emergency Paid Sick Leave Act (EPSLA), employees may seek up to 2 weeks (10 business days) of paid leave for the following reasons:
- Subject to a federal, state, or local quarantine or isolation order related to COVID-19;
- Advised to self-quarantine due to concerns related to COVID-19;
- Experiencing symptoms of COVID-19 and seeking a medical diagnosis;
- Caring for an individual subject to a quarantine or isolation order or advised to self-quarantine due to concerns related to COVID-19;
- Caring for a son or daughter whose school or childcare provider is closed or unavailable due to COVID-19 precautions; and
- Experiencing any other substantially similar condition specified by the Secretary of Health and Human Services, in consultation with the Secretary of the Treasury and the Secretary of Labor.
For full-time employees, 2 weeks of leave equates to 80 hours; for part-time employees, 2 weeks of leave equates to a number of hours equivalent to the number of hours usually worked in a 2-week period.
Paid leave for reasons 1, 2, and 3 above is paid at the employee’s regular rate of pay, capped at $511/day. Paid leave for reasons 4, 5, and 6 above is paid at a rate equivalent to 2/3 of an employee’s regular rate of pay or minimum wage, whichever is greater, capped at $200/day.
Under FFCRA’s Emergency Family and Medical Leave Expansion Act, employees may seek up to 12 weeks of leave to care for a son or daughter whose school or childcare provider is closed or unavailable due to COVID-19 precautions. The first 2 weeks of leave, which run concurrently with the EPSLA leave, may be unpaid; the remaining 10 weeks of leave are paid at a rate equivalent to 2/3 of an employee’s regular rate of pay or minimum wage, whichever is greater, capped at $200/day. For more information, see the College’s FMLA Leave Expansion and Emergency Paid Sick Leave procedure.
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.
Under the Coronavirus Aid, Relief, and Economic Security (CARES) Act and State of Michigan Executive Order 2020-57, unemployment compensation benefits are expanded in terms of eligibility, amount, and duration. Employees who are unable to report to work for reasons related to COVID-19 may be eligible for unemployment compensation benefits. Such reasons include the following:
- Being under self-isolation or self-quarantine in response to elevated risk from COVID-19 due to being immunocompromised;
- Displaying at least 1 of the principal symptoms of COVID-19 (i.e., fever, atypical cough, atypical shortness of breath);
- Having close contact in the last 14 days with a confirmed COVID-19 diagnosis;
- Needing to care for someone with a confirmed COVID-19 diagnosis; and
- Fulfilling a family care responsibility as a result of a government directive (e.g., caring for a child whose school or childcare provider is closed or otherwise unavailable due to COVID-19).
Under the State of Michigan Executive Order 2020-36, employees who require leave beyond the EPSLA because of their own COVID-19 diagnosis/symptoms, or because they have had close contact or live with an individual with a COVID-19 diagnosis/symptoms, may be eligible for unpaid leave under Executive Order 2020-36.
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. Telephone and video appointments are available. HelpNet may be contacted by telephone at 800-969-6162 or their website.
References: OSHA, CDC, State of MI Executive Orders, Supervisor Responsibilities – Employee Calls in Sick – COVID-19, Infectious Disease Prevention and Social Distancing, FMLA Leave Expansion and Emergency Paid Sick Leave