Preventing the spread of COVID19 is good and this draft standard is a good first step.  The following items are not clear and need additional clarification.  For a health care employer, it is clear but not for other industries such as construction.

It would be great if a sample Infectious Control and Response plan for each type of employer hazard classification would be available to guide employers.  Many small businesses will fall in this category and do not have the resources to easily prepare a plan and do training.  Also include examples of best practices for sanitation, distancing, and PPE.

The standard lists: very high, high and medium exposure classification in different sections, this is confusing and needs clarification. 

70 A.  This is confusing does training on the plan requirements apply to “medium” hazard employers, or just to very high and high hazard employers?

How does the standard apply for a multiemployer work site.  If a construction project has 20 different contractors onsite, will each contractor have to prepare their own plan?  If the contractor has less than 11 employees onsite and is working on a construction project with more than 11 employees onsite will they have to prepare a plan?  The general contractor will have a plan, will each subcontractor need one and a knowledgeable person onsite?

§70 Infectious disease preparedness and response plan.

A. Employers with hazards or job tasks classified as:

1. “Very high,” and “high,” shall develop and implement a written Infectious Disease

Preparedness and Response Plan;

2. “Medium” with eleven (11) or more employees shall develop and implement a

written Infectious Disease Preparedness and Response Plan. 

B. The plan and training requirements tied to the plan shall only apply to those employees

classified as “very high,” “high,” and “medium” covered by this section.

Definition of Knowledgeable Person

For construction who meets the definition of a knowledgeable person in infection control principles and practices?  Will a competent person or supervisor meet this?  Will a competent person or supervisor with bloodborne pathogens training meet this?  For a health care employer, it is clear, not for construction or other industries.  Please clarify.

C. Employers shall designate a person to be responsible for implementing their Plan. The

Plan shall:

1. Identify the name(s) or titles(s) of the person(s) responsible for administering the

Plan. This person shall be knowledgeable in infection control principles and practices

as they apply to the facility, service or operation.

Preparedness and Response Plan.

I agree that general awareness training on COVID19 control, practices, symptoms and regulatory/local requirements is good.  If I am a “medium” hazard employer does section 80 apply to me?  Or just to very high or high exposure employers.

§80 Training.

A. Employers with hazards or job tasks classified as “very high” or “high” exposure risk shall

provide training to all employee(s) regardless of employee risk classification on the

hazards and characteristics of the SARS-CoV-2 virus and COVID-19 disease. The program

shall enable each employee to recognize the hazards of SARS-CoV-2 and symptoms of

COVID-19 and shall train each employee in the procedures to be followed in order to

minimize these hazards.

C. Employers covered by §50 of this standard/regulation shall verify compliance with §80.A

by preparing a written certification record for those employees exposed to hazards or

job tasks classified as “very high,” “high,” or “medium” exposure risk levels. The written

certification record shall contain the name or other unique identifier of the employee

trained, the trained employee’s physical or electronic signature, the date(s) of the

training, and the signature of the person who conducted the training or the signature of

the employer.