Airborne Infectious Agents Plan
Table of Contents
- 1.1 On September 6, 2021, Governor Kathy Hochul announced the designation of COVID-19 as an airborne infectious disease under the HERO Act. This designation requires all New York State employers to implement workplace safety plans and train employees on the minimum workplace requirements to combat the spread of COVID-19. Outlined in our plan are the minimum public health requirements at this time, and other considerations that may be implemented into specific operations or may be implemented in the future if transmission rates increase in our community.
Please note many of these public health requirements have been in place since the start of the pandemic at Cornell, and as requirements change the university will continue to inform the community of any updates through town halls, university-wide memos, and through the COVID-19 Reactivation and Planning website.
- 1.2 The purpose of this plan is to protect employees against exposure and disease during an airborne infectious disease outbreak. This plan goes into effect when an airborne infectious disease is designated by the New York State Commissioner of Health as a highly contagious communicable disease that presents a serious risk of harm to public health. This plan is subject to any additional or greater requirements arising from a declaration of a state of emergency or executive order due to an airborne infectious disease, as well as any applicable federal standards.
- Employees should report any questions or concerns with the implementation of this plan to the designated contact.
- This plan applies to all “employees” as defined by the New York State HERO Act, which means any person providing labor or services for remuneration for a private entity or business within the state, without regard to an individual’s immigration status, and shall include part-time workers, independent contractors, domestic workers, home care and personal care workers, day laborers, farmworkers, and other temporary and seasonal workers. The term also includes individuals working for digital applications or platforms, staffing agencies, contractors, or subcontractors on behalf of the employer at any individual worksite, as well as any individual delivering goods or transporting people at, to, or from the worksite on behalf of the employer, regardless of whether delivery or transport is conducted by an individual or entity that would otherwise be deemed an employer under this section. The term does not include employees or independent contractors of the state, any political subdivision of the state, a public authority, or any other governmental agency or instrumentality.
- 2.1 This plan applies to all employees of Cornell University performing work in New York state.
- 2.2 This plan requires a commitment to ensure compliance with all plan elements aimed at preventing the spread of infectious disease. The following supervisory employees are designated to enforce compliance with the plan. Additionally, these supervisory employees will act as the designated contacts unless otherwise noted in this plan:
|Allan Bishop||AVP for Human Resources||East Hill Plaza, 337||
|John Clarke||Director of Occupational Medicine||Cornell Health, 310||
|Tim Fitzpatrick||Senior Director of EHS and Emergency Management||East Hill Office Building, Suite 210||
- 3.1 Minimum Controls During an Outbreak
- During an airborne infectious disease outbreak, the following minimum controls will be used in all areas of the worksite:
- 3.1.1 General Awareness: Individuals may not be aware that they have the infectious disease and can spread it to others. Employees should remember to:
- a. Maintain physical distancing;
- b. Exercise coughing/sneezing etiquette;
- c. Wear approved face coverings, as appropriate (tight-fitting, over mouth and nose);
- d. Wear gloves, and personal protective equipment (PPE), as appropriate;
- e. Stop social etiquette behaviors such as hugging and handshaking that would bring individuals into close proximity, and
- f. Wash hands properly and often as a general hygiene practice.
- 3.1.2 “Stay at Home Policy”: If an employee develops symptoms of infectious disease, the employee should not be in the workplace. The employee should inform their human resource representative and follow New York State Department of Health (NYSDOH) and Centers for Disease Control and Prevention (CDC) guidance regarding obtaining medical care and isolating.
- 3.1.3 Health Screening: Employees will be screened for symptoms of the infectious disease at the beginning of their shift. Employees are to self-monitor throughout their shift and report any new or emerging signs or symptoms of the infectious disease to their supervisor, or the dailycheck.cornell.edu health screening application. An employee showing signs or symptoms of the infectious disease should be removed from the workplace and should contact a healthcare professional for instructions, or a complete return to work process defined by the university. The health screening elements will follow guidance from NYSDOH and CDC guidance, if available.
- 3.1.4 Face Coverings: When in use, face coverings must cover the nose and mouth, and fit snugly, but comfortably, against the face. The face covering itself must not create a hazard (e.g., have features could get caught in machinery or cause severe fogging of eyewear). The face coverings must be kept clean and sanitary and changed when soiled, contaminated, or damaged. All employees are required to comply with Cornell's Face Mask requirements on the COVID-19 Response webpage.
• Effective February 10, 2022: Employees will wear appropriate face coverings in accordance with guidance from State Department of Health or the Centers for Disease Control and Prevention, as applicable. Consistent with the guidance from the State Department of Health, if indoor areas do not have a mask or vaccine requirement as a condition of entry, appropriate face coverings are recommended, but not required. It is also recommended that face coverings be worn by unvaccinated individuals, including those with medical exemptions, in accordance with federal CDC guidance. Further, the State’s masking requirements continue to be in effect for public transit, health care, and other sensitive settings in accordance with CDC guidelines. New York State and the State Department of Health continue to strongly recommend face coverings in all public indoor settings as an added layer of protection, even when not required.
- 3.1.5 Physical Distancing: Physical distancing will be followed as much as feasible. Avoid unnecessary gatherings and maintain a distance of at least six feet (or as recommended by the NYSDOH/CDC for the infectious agent) from each other when feasible and safe to do so.
- In situations where prolonged close contact with other individuals is likely, use the following control methods bolded below where and when appropriate. As changes with the COVID-19 pandemic occur so may our distancing requirements:
- a. restricting, limiting, or procedures for customer or visitor entry;
- b. limiting occupancy or density;
- c. reconfiguring workspaces;
- d. physical barriers (dining, healthcare, retail);
- e. signage;
- f. floor markings;
- g. telecommuting, or web conferencing;
- h. remote meetings, hybrid or remote work (department dependent);
- i. preventing activities (limiting singing and wind instruments indoors), events, gatherings;
- j. restricting travel;
- k. creating new work shifts and/or staggering work hours;
- l. adjusting break times and lunch periods;
- m. delivering services electronically, remotely, or through curbside pickup.
- n. modify vehicle occupancy procedures
- 3.1.6 Hand Hygiene: To prevent the spread of infection, employees should wash hands with soap and water for at least 20 seconds or use a hand sanitizer with at least 60% alcohol to clean hands BEFORE and AFTER:
- a. Touching your eyes, nose, or mouth;
- b. Touching your mask;
- c. Entering and leaving a public place; and
- d. Touching an item or surface that may be frequently touched by others, such as door handles, tables, gas pumps, shopping carts, electronic cashier registers/screens, or other shared equipment.
- 3.1.7 Cleaning and Disinfection: See Section 4.0 of this plan.
- 3.1.8 “Respiratory Etiquette”: Because infectious diseases can be spread by droplets expelled from the mouth and nose, employees should exercise appropriate respiratory etiquette by covering the nose and mouth when sneezing, coughing, or yawning.
- 3.1.9 Special Accommodations for Individuals with Added Risk Factors: due to underlying health condition, or other factors, may be at increased risk of severe illness if infected. Contact the Medical Leaves Administration in Human Resources at firstname.lastname@example.org for accommodations or for more information, visit Medical Leaves Administration’s disability accommodations webpage.
- 3.1.1 General Awareness: Individuals may not be aware that they have the infectious disease and can spread it to others. Employees should remember to:
- 3.2 Advanced Controls During an Outbreak
- For activities where the Minimum Controls alone will not provide sufficient protection for employees, additional controls from the following hierarchy may be necessary.
- 3.2.1 Elimination controls NOT currently implemented for COVID-19 designation.
- Elimination: Employers should consider the temporary suspension or elimination of risky activities where adequate controls could not provide sufficient protection for employees. Examples include:
- a. Limiting or eliminating in-person learning, study, or work,
- b. Limiting gatherings by location and scale
- c. Limiting or eliminating in-person activities, recreational and/or events.
- 3.2.2 Engineering controls bolded below are implemented where feasible.
- Engineering Controls: Employers should consider appropriate controls to contain and/or remove the infectious agent, prevent the agent from being spread, or isolate the worker from the infectious agent.
- a. Mechanical Ventilation, for example:
- Increasing the percentage of fresh air introduced into air handling systems;
- Utilize air filters with a rating of Minimum Efficiency Reporting Value (MERV) 13 or higher, if compatible with the HVAC system(s). If MERV–13 or higher filters are not compatible with the HVAC system(s), use filters with the highest compatible filtering efficiency for the HVAC system(s);
- If fans are used in the facility, arrange them so that air does not blow directly from one worker to another. Remove personal fans as necessary but keep heat hazards in mind and address in other methods if appropriate;
- Local duct; and
- Air purifiers, e.g., HEPA, UV, Ozone.
- b. Natural Ventilation, for example:
- Opening outside operable windows and doors
- a. Mechanical Ventilation, for example:
- 3.2.3 Engineering controls bolded below are implemented where feasible.
- Other Potential Engineering Controls Cornell May Implement:
- a. Install cleanable barriers such as partitions and clear plastic sneeze/cough guards (dining, healthcare, and retail).
- b. Establish entry to building protocols that are contactless.
- c. Install handwashing or sanitizing stations throughout the facility.
- d. Surveillance and supplemental testing.
- Subject to changes based on operations and circumstances surrounding the infectious disease, engineering controls that are anticipated to be used are listed in the following table:
Engineering Controls Utilized/Location:
1. HVAC Upgrades - Facility flush 2 hours before and after business hours, Increased outdoor air for recirculating systems, and MERV-13 or greater filtration where feasible. See Facilities and Transportation FAQs for more information.
- 3.2.4 Administrative controls bolded below are implemented where feasible.
- Administrative Controls are policies and work rules used to prevent exposure. Examples include:
- a. Physical distancing procedures for employees, students, and visitors;
- b. Disinfecting procedures for specific operations and shared equipment;
- c. Employee training;
- d. Prioritize job functions that are essential for continuous operations;
- e. Cross-train employees to ensure critical operations can continue during worker absence;
- f. Limit the use of shared equipment and workstations;
- g. Post signage reminding of respiratory etiquette, masks, hand hygiene, and other public health requirements;
- h. Rearrange traffic flow to allow for one-way paths of travel;
- i. Provide clearly designated entrance and exits;
- j. Establishing pods or cohorts of employees and students to limit exposure;
- k. Minimize elevator use or reduce elevator occupancy, post signage of limitations;
- l. Increase time between classes to allow for cleaning and ventilation;
- m. Utilize remote learning and work methods;
- n. Require health screening of employees and students (Cornell Health access only) upon entry to campus, or facilities; and
- o. Limit attendance of in-person meetings and occupant density. Host the meetings outdoors or electronically.
3.2.5 Personal Protective Equipment (PPE) are devices like eye protection, face shields, gowns, respirators, Tyvek, and gloves that protect the wearer from infection. PPE will be provided, used, and maintained in a sanitary and reliable condition at no cost to the employee. The PPE provided to an employee will be based on a hazard assessment for the workplace.
Subject changes based on operations and circumstances surrounding the infectious disease, the following specific administrative controls are anticipated to be used: Administrative Controls Utilized Location: A selection of administrative controls outlined above will be utilized as appropriate for the specific infectious agent of concern.
The following PPE that are anticipated to be used are in the following table: PPE Required - Activity Involved/Location: N-95 respirators, gowns, goggles, face shields, and nitrile gloves is used for patient contact with individuals suspected or confirmed of having COVID-19. Other procedures exist for employees performing Quarantine/Isolation Facility or Room entry, and Quarantine/Isolation Facility Shuttle Drivers.
1. The use of respiratory protection, e.g., an N95 filtering facepiece respirator, requires compliance with the OSHA Respiratory Protection Standard 29 CFR 1910.134 or temporary respiratory protection requirements OSHA allows for during the infectious disease outbreak.2. Respirators with exhalation valves will release exhaled droplets from the respirators, and do not meet the requirements of an approved face covering.
- 3.3 Exposure Control Readiness, Maintenance, and Storage:
- The controls we have selected will be obtained, properly stored, and maintained so that they are ready for immediate use in the event of an infectious disease outbreak and any applicable expiration dates will be properly considered.
- 4.1 Disinfection Methods and Schedules
- Objects that are touched repeatedly by multiple individuals, such as door handles, light switches, control buttons/levers, dials, levers, water faucet handles, computers, phones, or handrails must be cleaned frequently with an appropriate disinfectant. Surfaces that are handled less often, or by fewer individuals, may require less frequent disinfection. The disinfection methods and schedules selected are based on specific workplace conditions and the risk of fomite transmission. Ithaca Campus Building Care Cleaning Procedures.
- The New York State Department of Environmental Conservation (NYSDEC) and the Environmental Protection Agency (EPA) have compiled lists of approved disinfectants that are effective against many infectious agents. Select disinfectants based on NYSDOH and CDC guidance and follow manufacturer guidance for methods, dilution, use, and contact time.
- 4.2 Adjustments to Normal Housekeeping Procedures
- Normal housekeeping duties and schedules should continue to be followed during an infectious disease outbreak, to the extent practicable and appropriate consistent with NYSDOH and/or CDC guidance in effect at the time. However, routine procedures may need to be adjusted and additional cleaning and disinfecting may be required.
- 4.3 Cleaning and Disinfecting Infectious Persons’ Affected Areas
- If an employee develops symptoms of the infectious disease at work, it is ideal to isolate the area per guidance issued by NYSDOH or the CDC, before cleaning and disinfecting the sick employee’s work area. In these situations, a process for reporting the incident and a procedure for safely disinfecting the affected area will be in place, similar to the Guidance for HR Representatives and Supervisors For COVID-19 Positive, Quarantined, or Isolated Employees.
- 5.1 If an actual, or suspected, infectious disease case occurs at work, take the following actions:
- 5.1.1 Instruct the sick individual to wear a face covering and leave the worksite and follow NYSDOH/CDC guidance.
- 5.1.2 Follow Cornell Human Resources, local and state authority guidance to inform impacted individuals.
- 6.1 DESIGNATION OF COVID-19 AS A AIRBORNE INFECTIOUS DISEASE IN PLACE, Complete EHS 2021 - HERO Act Designation of COVID-19 as an Airborne Infectious Disease Compliance Training
- 6.2 Environment, Health and Safety will verbally inform all employees of the existence and location of this Plan, the circumstances it can be activated, the infectious disease standard, employer policies, and employee rights under the HERO Act.
- 6.2 When this plan is activated, all personnel will receive training which will cover all elements of this plan and the following topics:
- 6.2.1 The infectious agent and the disease(s) it can cause;
- 6.2.2 The signs and symptoms of the disease;
- 6.2.3 How the disease can be spread;
- 6.2.4 An explanation of this Exposure Prevention Plan;
- 6.2.5 The activities and locations at our worksite that may involve exposure to the infectious agent;
- 6.2.6 The use and limitations of exposure controls
- 6.2.7 A review of the standard, including employee rights provided under Labor Law, Section 218-B.
- 6.3 The training will be
- 6.3.1 Provided at no cost to employees and take place during working hours. If training during normal work hours is not possible, employees will be compensated for the training time (with pay or time off);
- 6.3.2 Appropriate in content and vocabulary to your educational level, literacy, and preferred language; and
- 6.3.3 Verbally provided in person or through telephonic, electronic, or other means.
The employer will review and revise the plan periodically, upon activation of the plan, and as often as needed to keep up to date with current requirements. Document the plan revisions below:
|Date||Participants||Major Changes||Approved By|
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Updated plan to reflect current controls and processes for COVID-19 designation
No employer, or his or her agent, or person, acting as or on behalf of a hiring entity, or the officer or agent of any entity, business, corporation, partnership, or limited liability company, shall discriminate, threaten, retaliate against, or take adverse action against any employee for exercising their rights under this plan, including reporting conduct the employee reasonably believes in good faith violates the plan or airborne infectious disease concerns to their employer, government agencies or officials or for refusing to work where an employee reasonably believes in good faith that such work exposes him or her, other workers, or the public to an unreasonable risk of exposure, provided the employee, another employee, or representative has notified the employer verbally or in writing, including electronic communication, of the inconsistent working conditions and the employer’s failure to cure or if the employer knew or should have known of the consistent working conditions.
Notification of a violation by an employee may be made verbally or in writing, and without limitation to format including electronic communications. To the extent that communications between the employer and employee regarding a potential risk of exposure are in writing, they shall be maintained by the employer for two years after the conclusion of the designation of a high-risk disease from the Commissioner of Health, or two years after the conclusion of the Governor’s emergency declaration of high-risk disease. The employer should include contact information to report violations of this plan and retaliation during regular business hours and for weekends/other non-regular business hours when employees may be working.
Policy 4.6 Standards of Ethical Conduct – Retaliation: The university will not tolerate retaliation toward or harassment of employees who report actual or possible violations. The identity of individuals providing information concerning possible violations, including fraud, will be protected within legal limits. Individuals who take retaliatory action will be subject to discipline, up to and including discharge.
Report hazard concerns, and/or non-compliance to askEHS@cornell.edu, or one of the designated contacts outlined in section 2.2 of this plan.
Report unethical behavior and employee retaliation to 1-866-293-3077 or online at the Cornell Ethical Conduct and Compliance Hotline.
*March 12, 2022 - 3.1.4 Face Coverings section updated to reflect revisions to NYS DOH's Model Airborne Infectious Disease Exposure Prevention Plan and Cornell's updated Face Mask requirements.