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Health & Safety Best Practices During COVID-19

In these challenging times, it is important for wineries and affiliated businesses to be prepared to appropriately respond when a workplace is impacted by the novel coronavirus, or COVID-19.

Following Wine Institute’s recent webinar on workplace health and safety best practices related to the COVID-19 virus, we received many requests for examples of how to facilitate these health and safety protocols. Wine Institute collaborated with Dr. Karakousis, Associate Professor of Medicine at the Johns Hopkins University School of Medicine, and Mr. Sarvadi, Partner at Keller Heckman, LLP, to create the following three health and safety best practice protocols for use by wineries and affiliated businesses to appropriately respond when their workplace is impacted by cases of COVID-19.

We are aware that some companies will not be able to adopt all recommendations outlined in these protocols. Please note these protocols are to be used as guidance only and are evolving documents. The information included is relevant to the date on which it was last revised and employers should check back to ensure they have the latest version at the time of use.

Please read this important notice & disclaimer first

 

Management of Employees Testing Positive or Presumed Positive for COVID-19

Last Updated: April 7, 2020

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The Centers for Disease Control and Prevention (CDC) and other governmental authorities published guidance on what employers should do to help slow the spread of COVID-19. Below, we summarize CDC’s guidelines and other federal agency guidance on what companies should do.

Wineries should have in place policies requiring employees to report illnesses and to refrain from coming to work if they have symptoms, particularly those identified by CDC as characteristic of COVID-19: shortness of breath, coughing, and fever. Recently, several authorities have added other symptoms that may also be present: sore throat, muscle aches (new), acute onset of loss of smell or taste (without other explanation). Employees should be presumed to have COVID-19 in the absence of a physician’s diagnosis of another cause or a negative COVID-19 test if they satisfy one of the following two tests: (1) If an employee reports one or more of the primary symptoms above AND has exposure to a known case; or (2) Individuals reporting two or more symptoms with no known exposure history.

The following are strong recommendations generally based on guidance from federal agencies, including CDC, OSHA, and EEOC. In some states and localities, some of these recommendations may be mandatory. Check with local officials for details about their public health emergency orders and requirements.

CDC’s guidelines are changing regularly. Consult the guidelines for more details on this subject:

https://www.cdc.gov/coronavirus/2019-ncov/hcp/disposition-in-home-patients.html

Steps to take if an employee tests positive for COVID-19 or is “presumed positive”

  • If an employee is reporting symptoms at work, the employee should be treated as presumed positive. The employer should:
    • Recommend the employee get tested for COVID-19, and
    • Immediately send employee home to self-isolate and follow the “Return to Work” criteria below to determine when the employee is eligible to return to work.
  • Permit employee to return to work only if he or she meets the following conditions below.
    • At least 7 days have passed since symptoms first appeared, and at least 72 hours have passed since the employee exhibited no symptoms, without the use of fever-reducing medications and the complete absence of respiratory symptoms (e.g., cough, shortness of breath); or
    • The employee has tested negative for COVID-19, following the CDC test-based strategy (at least two consecutive negative tests collected ≥24 hours apart from nasopharyngeal swab specimens); or
    • The employee provides a Health Care Provider’s (HCP) note that the employee is fit to return to work.
  • For employees presumed positive but without a confirmed test and no symptoms
    • Immediately send employee home to self-quarantine for at least 14 days; and
    • Recommend employee get tested for COVID-19; and
      • Permit the employee to return to work if at least 14 days have passed without the development of symptoms; or
      • If symptoms develop during that 14-day quarantine period, treat the employee as presumed positive with symptoms as above and permit employee to return to work following the “Return to Work” criteria above.
    • The EEOC acknowledges that new approaches may be necessary due to the possible unavailability of HCPs helping patients during the outbreak and suggests relying on local clinics to certify that the individual is safe to return to work.
    • Maintain privacy of employee by not disclosing sick employee’s name to others in the workplace.
    • The burden to report confirmed cases of coronavirus from the CDC is on health care providers; employers are not required to do so, however, local authorities may mandate reporting of confirmed cases, so check with local authorities if a case is reported. Employers should direct their workers to see their health care provider if they believe that they have any symptoms consistent with COVID-19. Employers should also obtain lists of work-related contacts and follow up with them consistent with the guidance provided regarding “persons tested or presumed positive with COVID-19.”
    • Make a list of individuals who have been in “close contact” with, or in the same work area as, the ill employee and notify those employees about their potential exposure to COVID-19.
      • Follow protocols for “What to do When Employees are Found to be in “Close Contact” with Person Who Has Tested Positive or Displays Symptoms of COVID-19.”
    • Institute appropriate cleaning measures based on cleaning protocols. See “Recommended Cleaning Procedures Identification of An Employee Who is Diagnosed or Tested Positive for COVID-19.”
    • Consider whether the case may meet OSHA recordkeeping requirements for recording the illness.
    • If the employee handled wine shipments (i.e., carboard boxes):
      • Move the boxes indoors and let them remain untouched for at least 24 hours before further packing, unpacking, and handling.

Employee Management Policies for “Close Contacts” with COVID-19 Cases

Last Updated: April 7, 2020

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The Centers for Disease Control and Prevention (CDC) and other governmental authorities have released guidance on how employers should respond to situations where the employer is notified that one or more employees have been “in close contact” with an individual who is diagnosed or has a positive COVID-19 test. Below, we summarize CDC’s guidelines on how to handle the situations.

The following are strong recommendations generally based on guidance from federal agencies, including CDC, OSHA, and EEOC. In some states and localities, some of these recommendations may be mandatory. Check with local officials for details about their public health emergency orders and requirements.

See CDC guidelines on contacts and patients:

www.cdc.gov/coronavirus/2019-ncov/php/public-health-recommendations.html

Who is in “close contact” as defined by CDC?

  • The CDC defines “close contact” as either
    • Being within approximately 6 feet of the individual with COVID-19 for a prolonged period of time.
      • In the same work area, break room, meetings, or similar circumstances for prolonged periods.
      • Living with, visiting, or caring for a person who is ill with COVID-19.
    • Unprotected contact with the infectious secretions of COVID-19 (i.e., direct contact with droplets from cough or other body fluids). If an employee leaves the workplace after experiencing symptoms while at work, employees who use the same equipment or workstations for prolonged periods should be considered “close contacts.”
  • “Prolonged period” is currently undefined. CDC notes that data are insufficient to precisely define the duration of time that constitutes a prolonged exposure. Recommendations vary from 10 minutes or more to 30 minutes or more. In part it depends on the circumstances of the contact. Being in a meeting room with low ceilings and limited ventilation, even if separated by the required 6 feet or more, for more than 10 minutes may be considered a prolonged period. In contrast, working on a production line where the physical space is more typical of manufacturing facilities, with 15-20 foot ceilings, mechanical ventilation meeting recommended standards, more than 6 feet spacing between workstations for an hour may not be sufficient to put the employee in the close contact group. Some authorities have suggested periods of contact of ten minutes or greater, depending upon the degree of contact.
  • Employers may need to adjust the length of time depending on the degree of interaction employees must experience to carry out their tasks, the physical conditions in the workplace, and similar considerations. Note also that events may be cumulative; several meetings in a single day in a low ceiling meeting room may qualify, as could an aggregate of meetings, close proximity at workstations, or any other circumstance where the employees may be within a space as a group for more than a few minutes. In the end, there are so many variables that each employer’s situation may require a case-by-case assessment.
  • For any employee deemed to be a close contact, the employer should either:
    • Send those employees home with directions to self-quarantine for 14 days. Any employee subjected to those directions should be permitted back only if, during the entirety of those 14 days, he or she has had no symptoms associated with COVID-19, including cough, shortness of breath, fever, sudden acute loss of taste or smell, or body aches without using either prescription or over-the-counter medications. Employees reporting symptoms while in self-quarantine should be treated as presumed COVID-19 positive, continue to stay at home to isolate, seek medical attention, and be allowed to return to work only if they satisfy the criteria for those individuals.
    • Or, if an employer is willing and able to conduct full screenings, including taking a temperature pre-shift, a close contact employee may remain at work if:
      • The employee remains asymptomatic;
      • The employer conducts the pre-shift screening, which includes measuring the employee’s temperature and assessing symptoms associated with COVID-19 prior to the individual starting work;
      • The employee self-monitors, including temperature, for 14 days outside of work;
      • The employee wears a mask at all times while in the workplace for 14 days after last exposure;
      • The employee maintains proper social distancing (over 6 feet) while at work;
      • The employer disinfects and cleans workspaces such as offices, bathrooms, common areas, and shared electronic equipment routinely; and
      • The employee is sent home immediately if they begin to show symptoms associated with COVID-19. At which point it is also necessary for the employer to assess whether any other employees were in close contact with the individual at any time in the previous 48 hours.

Employers should emphasize maintaining sufficient separation between employees in all circumstances. Outside meetings can be considered as long as distance is maintained.

Recommended Cleaning Procedures Following Identification of an Employee Who Is Diagnosed or Tested Positive for COVID-19

Last Updated: April 7, 2020

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Wineries are covered by the Food and Drug Administration’s (FDA) Good Manufacturing Practices (GMP), which require wineries to have in place adequate policies and procedures for cleanliness. With respect to the current outbreak of COVID-19, the Centers for Disease Control and Prevention (CDC) has released guidance on how employers should properly clean and disinfect rooms or areas occupied by suspected or confirmed cases involving employees. Below, we highlight the CDC’s guidance.

The following are strong recommendations generally based on guidance from federal agencies, including CDC, OSHA, and EEOC. In some states and localities, some of these recommendations may be mandatory. Check with local officials for details about their public health emergency orders and requirements.

See CDC guidelines at:

www.cdc.gov/coronavirus/2019-ncov/community/organizations/cleaning-disinfection.html

www.cdc.gov/coronavirus/2019-ncov/community/disinfecting-building-facility.html

What to do after an employee tests positive for, or is suspected to have, COVID-19

Wineries should have in place policies requiring employees to report illnesses and to refrain from coming to work if they have symptoms, particularly those identified by CDC as characteristic of COVID-19: shortness of breath, coughing, and fever. Recently, several authorities have added other symptoms that may also be present: sore throat, generalized muscle aches (new), acute onset of loss of smell or taste (without other explanation).  Employees who report one or more of the symptoms listed should be presumed to have COVID-19 in the absence of a physician’s diagnosis of another cause or a negative COVID-19 test.  Employees are also presumed positive if they in “close contact” with someone with COVID-19 (see “Employees Management Policies For “Close Contacts” with COVID-19 Cases” guidance).

  • Evacuate employees in areas used, occupied, or travelled by the employee and close them off; do not allow other employees to enter the area.
  • Wait “as long as practical” before beginning cleaning and disinfection protocols to minimize potential for exposure to respiratory droplets. CDC does recommend waiting 24 hours, but where this is not practical, and general mechanical ventilation is provided to the work area, a shorter time may be necessary.
    • If cleaning staff perform routine cleaning at the end of the workday and the area has been closed off for at least four hours, the employer should perform routine cleaning following the daily cleaning routine.
    • Employers should consider factors like the size of the room and ventilation system when deciding how long to close off a room or work area where someone was ill or suspected to be ill with COVID-19.
    • If it is determined that it is necessary to perform deep cleaning by a third-party professional cleaning service, the cleaning service should follow CDC guidelines for protection of cleaning staff.
  • If consistent with GMPs, open outside doors and windows to increase air circulation in the area.
  • Assure all cleaning is done with disinfectants that are on EPA’s List N, those EPA believes are effective disinfectants against COVID-19. Only use disinfectants that clearly state on the label it is approved for food contact surfaces and only when consistent with safe food practices and quality control for wine products.
  • Assure cleaning staff strictly follow the instructions on the disinfectant labels for 1) what type of personal protective equipment (PPE) to wear, 2) contact time, and 3) how to properly use the disinfectant. Pay particular attention to contact time and instructions to adequately wet all surfaces, especially those touched by employees regularly, such as keyboards, computer screens, switch panels or other controls.
    • Assure that a PPE assessment is performed as required by OSHA standards to determine what PPE is required.
    • Refer to your written respirator program and manufacturer instructions for cleaning and disinfecting, fit testing, inspection, replacement and other aspects of managing mask usage in the workplace.
    • Assure the disinfectants used are approved for use in food manufacturing areas or food establishments.
  • Require cleaning staff to clean and disinfect all areas used or occupied by the employee for more than 15 minutes.
    • Surfaces can be cleaned using a detergent or soap and water; if surfaces are dirty, thoroughly clean prior to disinfection.
  • Require cleaning staff to do the following after cleaning:
    • Remove gloves and gowns after cleaning the area. Wash gloves with soap and water or hand sanitizer, then remove gloves last and use safe glove doffing procedure – peeling downward, turning the glove inside-out.
    • Clean hands immediately after removing their gloves by washing hands with soap and water for 20 seconds.
    • If soap and water is not available and hands are not visibly dirty, then use alcohol-based hand sanitizer that contains 60%-95% alcohol.

 

Questions?

Contact Wine Institute’s legal team

legal@wineinstitute.org