COVID-19 Preparedness and Response Plan
CLS Infectious Disease Preparedness and Response Plan
Created 3/10/2020 rev. 6/1/2020 rev. 10/23/2020 rev. 5/27/2021
CLS has developed the following COVID-19 Preparedness and Response Plan and CLS Infectious Disease Preparedness and Response Plan. It is in accordance with applicable public health orders and rules
This plan will be placed where it is readily available to Employees, Union Representatives and Customers. CLS has posted physical copies of this plan at all locations.
COVID-19
CLS takes the health and safety of our employees seriously. With the spread of COVID-19 and the need for certain employees to continue in-person work, either because they are critical infrastructure workers or they are needed to conduct minimum basic operations for the Company, the Company is committed to reducing the risk of exposure to COVID-19 at the Company’s workplace(s) and to providing a healthy and safe workplace for our employees.
This Plan is based on information and guidance from the CDC and OSHA* at the time of its initial development, follows the Michigan COVID-19 Employee Rights Act and is subject to change based on further information provided by the CDC, OSHA, MIOSHA, MDHHS, Michigan law and other public officials. The Company may also amend this Plan based on operational needs(see Current Government Regulations folder).
All referenced files are kept on the CLS G-drive and this file has been shared with all members of the Executive Management team and HR staff. CLS has provided access to physical copies of this plan by posting them at all locations.
*Guidance on Preparing Workplaces for COVID-19
U.S. Department of Labor Occupational Safety and Health Administration OSHA 3990-03 2020
WORKPLACE SAFETY COORDINATOR
This plan will be coordinated by the CLS Executive Team and HR Director, and adjusted based on changes in Federal and State guidance. The first point of contact will be the HR Director. This plan will be reviewed and updated on a yearly basis by the CLS Executive Team.
CLS STATUS AS CRITICAL INFRASTRUCTURE
Based on declarations issued by the U.S. Government and/or the State of Michigan, CLS will put the following steps into action:
● Review CLS status as Critical Infrastructure
-CLS will follow guidance based on local or national legislation. Generally this guidance will follow the definition of business considered Critical Infrastructure as defined by the U.S. Cybersecurity and Infrastructure Security Agency.
-If not clearly stated in the legislative documents, CLS will seek a legal opinion. Based on legal opinion provided related to COVID-19, CLS is considered Critical Infrastructure as defined by the U.S. Cybersecurity and Infrastructure Security Agency.
Note- TRSA has succeeded (May 2020) in getting the linen, uniform and facility services industry and their suppliers added as critical workforce, thus allowing commercial/industrial laundries to maintain operations. It is recognized by DHS and all states.
● If CLS is NOT determined to be Critical Infrastructure, CLS ownership will make the final decision to close the business and CLS will follow the orderly closing procedure outlined in the infectious disease closing plan (see Infectious Disease Closing Plan folder)
● Upon determination that CLS is considered to be Critical Infrastructure as defined above, the following steps will be put into place to protect Team Members, Customers and Visitors:
COMMUNICATION
Executive Team Planning
Meetings will be implemented (frequency TBD) with the CLS Executive Team to make decisions to protect our Team Members, Customers, Visitors and the business in general. This team will also be responsible for developing internal and external communication. All media contacts will be handled by the President of CLS.
All social media platforms will be utilized to advise customers that CLS has been identified as a Critical Infrastructure supplier and is remaining open to supply their needs.
All social media platforms will be utilized as well as written communication to advise CLS Team Members that CLS has been identified as a Critical Infrastructure supplier and is remaining open.
Internal and external communication (meetings) should be conducted virtually wherever possible.
CRITICAL WORKERS
Critical Infrastructure Workers
CLS will identify all workers that are defined as Critical Infrastructure Workers and will provide a letter to each Team Member identifying them as such. This letter is to be carried by the Team Member for identification to law enforcement (see Essential Infrastructure Workers folder).
Minimum Basic Operations Workers
CLS will identify all workers that are defined as Minimum Basic Operations Workers and will provide a letter to each Team Member identifying them as such. This letter is to be carried by the Team Member for identification to law enforcement (see Essential Infrastructure Workers folder).
CRITICAL SUPPLIERS
Suppliers necessary to support Critical Infrastructure (Michigan)
If the declaration is made by the state of Michigan, CLS operations management will review all Michigan based suppliers to determine their status and if they should be provided written notice that they are designated a SUPPLIER/secondary supplier AS NECESSARY to support critical infrastructure (see Critical Suppliers folder).
Suppliers necessary to support Critical Infrastructure (National)
If the declaration is made by the U.S. Government, CLS operations management will review all U.S. based suppliers to determine their status and if they should be provided written notice that they are designated a SUPPLIER/Secondary supplier AS NECESSARY to support critical infrastructure (see Critical Suppliers folder)
ABILITY TO SERVICE (absenteeism)
CLS is a decentralized organization with six distribution and three processing related facilities in the state of Michigan. CLS has over 200 Team Members across the state of Michigan and multiple locations, and believes it can overcome an impact at any of its locations.
Team Members that are sick will be actively encouraged to stay home. CLS maintains a PTO policy for absenteeism, and will implement any additional sick leave policies in keeping with Federal and State laws.
In addition, CLS had developed a Disaster Contingency Plan in which it has agreements from multiple partner companies to provide processing if there were to be a sudden and unexpected loss of one of its production facilities. This Contingency Plan is reviewed annually by the CLS Executive Team (see CLS- Disaster Contingency Plan).
CROSS TRAINING
Recognizing that Team Members may be absent or away from the business (working from home), cross training should be implemented wherever possible.
TRAVEL
All business travel will be restricted to business critical only, and only approved by ownership. For Team Members returning from vacation, CLS will follow CDC self-isolation guidelines in place at the time. Personal travel restrictions may be imposed based on conditions at the time.
VISITORS
Outside visitors will be kept limited. All visitors must have a scheduled appointment. All scheduled visitors will be required to complete a CLS Health Assessment prior to entrance into any CLS facility. In addition, they will be required to use hand sanitizer, wear a mask if not vaccinated and meet their CLS host at the front entrance at Manchester Road (see Visitor Screening Process file).
PREVENTATIVE
Materials
(See Educational and Safety Resources file)
RESPONSIBILITIES 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 jobsite safety practices to prevent the spread of the virus. Managers and supervisors must encourage this same behavior from all employees.
RESPONSIBILITIES OF EMPLOYEES
The Company is asking every one of our employees to help with our prevention efforts while at work. In order to minimize the impact of COVID-19 at our worksite(s), everyone must play their part. As set forth below, the Company has instituted various housekeeping, social distancing, and other best practices at our workplace(s) to minimize exposure to COVID-19 and prevent its spread in the workplace. All employees must follow these best practices at all times for them to be effective. Beyond these best practices, the Company requires employees to report immediately to their managers or supervisors if they are experiencing signs or symptoms of COVID-19, as described below. If employees have a specific question about this Plan or COVID-19, they should ask their manager or supervisor or contact the Human Resources Department.
In addition, employees must familiarize themselves with the symptoms and exposure risks of COVID-19 as defines by the Michigan COVID-19 Employee Rights Act (as of 12/31/2020):
The following workplace actions will be put into place as directed by MIOSHA (5/24/2021)
Basic infection prevention
• Promote frequent/thorough hand washing, provide antiseptic hand sanitizer • Prohibit entry into the workplace for symptomatic employees, employees who have tested positive, and non-vaccinated close contacts
• Increase facility cleaning in accordance with the CDC
• Use EPA-approved disinfectants
• Encourage sick employees to stay home
Health Surveillance
• Daily entry health screening for all employees and contractors
• Require employees to promptly report signs/symptoms
• Isolate, send home, require remote work for persons known or suspected to have COVID-19 • Notify co-workers/contractors/suppliers who may have come into contact with a person with a known case of COVID-19
• Prohibit employees from entry until isolation/quarantine requirements fulfilled • Comply with Michigan COVID-19 Employee Rights Act
Safety Coordinator, Social Distancing & Masks
• Have a COVID-19 Safety Coordinator at each location (primary is HR/Safety Manager) • Ensure unvaccinated employees remain 6 feet apart to the maximum extent feasible • Masks
o Provide to unvaccinated employees
o Require unvaccinated employees to wear while indoors if they cannot
consistently maintain 6 feet of separation from other individuals
Masks: Vaccinated/Unvaccinated & Training
Employees are considered “fully vaccinated” when at least two weeks have passed after receiving the final dose of an FDA-approved or FDA-authorized COVID-19 vaccine.
• Compliance Options:
o Keep records of whether employees are fully vaccinated- CLS Choice
o Post signs in the workplace reminding employees that are not fully vaccinated to wear face coverings and to maintain appropriate distancing
o Allow or require remote work
o Require face coverings and social distancing for all employees regardless of vaccination status
• Training- will be provided and documented to Team Members covering at a minimum (see Training Documents folder):
o Workplace infection control
o Steps employees must take to notify business of symptoms, or suspected or confirmed COVID-19 diagnosis
o How to report unsafe working conditions
o Routes by which the virus containing COVID-19 is transmitted from
person to person
o Distance that the virus can travel by air, as well as it remains viable in the air and on environmental surfaces
o The use of PPE, including the proper steps for putting it on and taking it off.
o Information about vaccine availability
• Record Keeping
For a period of 6 months, CLS will keep the following records
▪ Daily entry screening: Non-vaccinated employees/contractors
▪ Positive test protocol notifications
▪ Vaccination information records if you are requiring them
The following additional steps/guidelines may be considered or put into place: General facility and office areas
Positions that involve direct contact with customers (i.e. service management, sales) will be advised by their leadership on reduced or eliminated face-to-face interactions
CLS Team Members will temporarily no longer sign for deliveries
Limitations will be placed on the number of people in the restroom
Team Members will be encouraged to utilize support services provided through their EAP resources
Posted signs indicating designated entry/exits for Production, Office, RSP, etc. workers, to prevent bypassing the required health screening process.
Reduce work days
Plant
Breaks will be spread out to limit the number of people in the breakroom Limitations will be placed on the number of people in the restroom
Install physical barriers between workstations where practical
Seats will be identified in the breakroom that meet the social distancing requirements established by the CDC
Equipment used with soiled products will be sanitized before reuse
Reduce work days
Routes
Hand sanitizer on all trucks
No signatures will be required on handheld devices
Handheld devices are to be wiped down several times per day
Sanitizing delivery vehicles will be completed daily
Reduce work days
Relays
Hand sanitizer on all trucks
Sanitizing semi-trailers will be completed daily
Reduce work days
REACTIVE
General
Follow guidelines and directives issued by the Federal and State governments related to time off related to the specific outbreak and monitored by Human Resources. CLS is participating in the voluntary extension of the payroll tax credit available to employers under the American Rescue Plan Act (“ARPA”). In accordance therewith, employees may qualify for two different types of paid leave described under the Families First Coronavirus Response Act (“FFCRA”). See HR for questions.
COMMUNICATION (see Suspected or Confirmed Case- HR folder):
Sick Team Member
The Team Member will report that they are sick or experiencing symptoms of the infectious disease (COVID-19) to their immediate supervisor, who will immediately report to Human Resources (see Suspected or Confirmed Case- HR folder).
Suspected or Confirmed Case
The Team Member will report the suspected or confirmed case to their immediate supervisor or directly to Human Resources. Human Resources will make the determination of actions to be taken. Generally, the Team Member will be advised to leave work or not come to work, and consult their healthcare provider.
Confirmed Case- within 24 hours, CLS will notify both:
– Any co-workers, contractors, or suppliers who may have come into contact with the person with the confirmed case of COVID-19. The Company will work to identify any employees who have close contact with individuals with COVID-19 symptoms. CLS will follow CDC and government issue guidelines and the CLS decision flow chart for isolation (see Suspected or Confirmed Case- HR folder). CLS will keep a record of this information.
Likewise, if unvaccinated employees come into close contact with someone showing these symptoms, they must notify their supervisor immediately and consult their healthcare provider. The Company will also work to identify any employees who have close contact with individuals with COVID-19 symptoms.
NOTE:
For unvaccinated individuals, “Close Contact” is defined by the CDC as someone who was within 6 feet of an infected person for a cumulative total of 15 minutes or more over a 24 hour period starting from 2 days before illness onset (or, for asymptomatic patients, 2 days prior to test specimen collection until the time the patient is isolated- (see Suspected or Confirmed Case- HR folder).
In coordination between the Executive Team, Human Resources and local management the following steps will be put into place:
The area that the employee worked will be closed off and deep cleaned using FDA and CDC approved disinfectants and following MSDS guidelines. The common areas that the Team Member came into contact with (I.e. breakroom, lunchroom) will be closed and deep cleaned using FDA and CDC approved disinfectants and following MSDS guidelines.
Depending on the situation, deep cleaning may be performed by an outside source specializing in biohazard remediation. These resources may include, but not limited to:
Service Master of Kalamazoo 269-344-3600
Servpro of East Kalamazoo 269-342-2366
Puroclean 269-463-8370
RETURN TO WORK
Monitored by the HR Director, CLS will allow Team Members with a suspected or confirmed case of COVID-19 to return to the workplace only after they are no longer infectious according to the latest guidance from the CDC or other governmental agencies. (see Return to Work file)