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COVID-19 Hierarchy of Controls

The Hierarchy of Controls is a system used to deploy effective controls within an organization, workplace, or community to identify the most effective ways to control a hazard. Depicted within the inverted pyramid below the more effective controls are on the large, top side of the pyramid, whereas the least effective controls are on the bottom. This document uses the hierarchy of controls to identify the best practices for controlling a person’s exposure to SARS-CoV-2, the novel coronavirus that has led to the COVID-19 pandemic.

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Definitions:

  • Elimination – Completely eliminating exposure to the hazard. The most effective control.

  • Substitution – Replacing the hazard with a non-hazardous object, device or substance.
  • Engineering Controls – Isolating the person from the hazard through physical or mechanical means.
  • Administrative Controls – Changes made to the way that people work.
  • Personal Protective Equipment – Equipment worn by the person to protect themselves from real or potential hazards, e.g. gloves, lab coats, safety glasses, respirators, etc.
  • Community Protective Equipment – Equipment worn by a person to prevent community spread from an asymptomatic carrier of COVID-19. This is the last line of defense and its effectiveness depends on community use and their ability to adopt disinfection, distancing, and hygiene practices

Control Methods:

Elimination

  • Stay home, work remotely and avoid public areas

  • Work on-campus and avoid occupied/public areas. Avoid use of shared equipment and spaces.
  • Virtual appointments, meetings, site visits, and training through the use of web conferencing applications (Zoom,Skype), or video calls (WhatsApp, FaceTime).
    • Consider if it is necessary to be in-person. Examples where it is/may be necessary include healthcare workers seeing patients, food preparation/service, cashiers

Substitution 

  • None currently identified.

Engineering Controls

  • Barriers, partitions, ropes to separate employees from public or building occupants, e.g.  plexiglass screens, sneeze guards, theater ropes and stanchions, hazard warning tape, etc.

  • Use of biosafety cabinets when performing research.

  • Drive-thru style partitions and windows
  • Hands-free trash receptacles, soap and towel dispensers, door openers, and other similar hands-free equipment.
  • Handles, push-buttons, and other high touch points made of copper or coated with copper tape. SARS-CoV-2 has a low virus stability on copper surfaces and research has proven there to be no viable virus after 4 hours on copper surfaces.
  • Create isolated spaces/workstations for employees or students with immune deficiency.

Administrative Controls

  • Social Distancing Requirements – Maintain a six feet distance from others, if you are unable to maintain distance you shall wear a mask.

  • Use floor markings and other barrier types to promote distancing. 

  • Cough and Sneeze Etiquette Procedure – Using your sleeve is a good way to cover your sneeze or cough with smaller risks of contamination
  • Proper Hand Hygiene and Control Procedure:
    • Do not touch eyes, nose, mouth, and face.
    • Wash hands thoroughly with soap and water for 20-30 seconds. In the absence of soap and water use alcohol-based hand sanitizer (≥60% alcohol). Hand sanitizer is not a replacement for good hand hygiene, wash your hands as soon as possible.
  • Disinfection procedures for specific operations, facilities, and/or work areas.
  • Signage to communicate social distancing, cough and sneeze etiquette, proper hand hygiene and control, and other critical procedures.
  • Employee health monitoring Formalizes the stay home if your sick or have had contact with a person known to test positive for COVID-19
    • Stay home if you have symptoms of illness
    • If you are at work and you develop symptoms of an illness, distance yourself from others, contact your supervisor, go home, and remain home until symptom-free.
    • Employee Health Protection Procedure
    Employee Training, EHS 2019 Return to Work Health and Safety Training for COVID-19
  • Restart Checklists. To enable consistency in our restart efforts.
  • Modified interactions or screening procedures with customers, public, students, or employees with
    the intent to minimize exposure to anyone of those groups.
  • Shift Change Procedures:
    • Have people coming in half time or stagger the work hours.
    • Look at existing high-density areas and ask half of staff to work on site certain days with virtual
      meetings.
    • Stagger workdays and hours so only 1 out of 2 workspaces is occupied on any day or portion of
      day.
    • Stagger start times to avoid bottlenecks at the entrance.

Personal Protective Equipment

  • COVID-19 related PPE requirements currently exist for Patient Care (Cornell Health and CUHA), Person Under Investigation Transport, Isolation Room Entry, and COVID-19 Research.

  • Respiratory Protection Program Requirements apply to all employees who wish to don a respirator. 

  • N95 respirators and KN95 respirators are critical supplies that must be reserved for healthcare workers, first responders and those performing high-risk tasks in direct support of the continuity of healthcare, public safety or essential research.
  • Consult and don manufacturer’s PPE requirements for disinfectant products prior to use.

Community Protective Equipment (Face Coverings and Masks)

  • Face Coverings and Masks are to be worn as a community effort to prevent asymptomatic carriers of COVID-19 from spreading the virus.

  • Employees are required to wear a face covering or mask when:
    • Outdoors: All employees, students, and visitors are required to have a mask or face covering readily available on their person (e.g., around neck) when on campus outdoors and to put on their mask or face covering when it is NOT feasible to maintain physical/social distancing measures (i.e., at least 6 feet of separation between others).
    • Indoors: Anyone entering a building must put on a mask or face covering prior to entering building and to continue to wear mask or face covering in common areas such as elevators, lobby, bathrooms, when traveling around the building and working in shared spaces.  Additionally, masks and face coverings are required in common areas of residence halls, dining halls, community centers, the Cornell Stores, and other retail locations and gathering spaces across campus.  Face coverings or masks can only be removed when alone in a cubicle, office, or other Unit designated area following social distancing guidelines.  (Note: For the intent of this procedure, cubicle is defined as a space with three walls at least 5' in height.)
    • Visit the Face Covering and Mask Requirements page for more information.
  • Handmade face coverings and masks should:

    • Fit snugly but comfortably against the side of the face
    • Be secured with ties or ear loops
    • Include multiple layers of fabric
    • Allow for breathing without restriction
    • Be able to be laundered and machine dried without damage or change to shape
  • Wearing such face coverings shall not be used in lieu of other control methods and users must be vigilant about:
    • Clean hands with soap and water or an alcohol-based hand sanitizer with at least 60% alcohol prior to putting on, touching mask while wearing it, and removing a cloth face covering.
  • Wearing N95 Respirators or other face masks with exhalation valves is not permitted as a face covering. Such respirators and masks are not effective in reducing the spread of COVID-19. See the examples below of face coverings that would not be permitted for use:
  • Discard or wash cloth face coverings after each use.
  • Do not wear a cloth face covering when it is damp or when wet from spit or mucus.
  • When removing the cloth face covering, remove it from behind, do not touch the front.

For more information visit Cornell’s Coronavirus Updates, Frequently Asked Questions, and Human Resources COVID-19 Workplace Guidance.