The surge
of COVID-19 cases during the past couple weeks is a wake-up call for all of us.
Unfortunately, it appears life with the virus will continue to be our “new
normal” for the foreseeable future. Until a vaccine is widely available, all
businesses need to take precautions so employees, clients, and customers don’t catch
and spread the disease. The construction industry is by no means immune (pardon
the pun) to these concerns. What do experts recommend as the common-sense, best
practices for minimizing the risk of transmission on construction jobsites?
Last
Wednesday’s June (virtual) meeting of the Construction Specifications Institute/Willamette Valley Chapter featured an informative presentation by David
Kahn of Forensic Analytical Consulting Services, Inc. (FACS) on the subject of COVID-19 safety in
construction. FACS is one of the country’s leading and most diverse industrial
hygiene consulting firms. The company has stepped up during the current crisis by
forming the COVID-19 FACS Expert Team, of which David is a member. The team has
been continuously reviewing the latest data and guideline revisions to keep itself
and FACS clients up to speed with the best science and right perspective on
addressing the pandemic.
Construction
jobsites constitute unique and challenging settings in which project teams must
overlay the recommended precautions associated with minimizing the risk of SARS-CoV-2
transmission. Each site presents one-of-a-kind quandaries. There may be confined
spaces to work in, limited access to others, and other environmental
challenges. Construction work often requires cooperative efforts in proximity
with other team members and at odds with physical distancing recommendations. Equipment is by necessity often shared. New workers cycle
on and off the jobsite with regularity, and each may unknowingly be carrying
the virus. Different trades must endure different work arrangements to get
their jobs done. The necessary precautions may slow or disrupt work progress,
and their implementation comes with costs. On top of this, there is uncertainty
about how the insurance industry will address the incidence of COVID-19 cases specifically
arising from construction activities.
The
implications for contractors, building owners, suppliers, design professionals,
and others who may visit a construction site demand the development and
application of a clear safety plan and a safe work practices program. David provided
some guidance in this regard, touching upon the necessity of risk assessment,
work modification, enhanced hygiene, social/physical distancing, and medical screening.
In a nutshell, David emphasized how putting well-considered plans and work
practices in place—communicating and enforcing site-specific requirements—is critical.
Why
should each construction project have its own Safety Plan? Why can’t a generic
set of rules and practices be applied? As mentioned above, the primary reason is
construction projects and jobsites almost always present unique conditions. Additionally,
regulatory requirements may vary from jurisdiction to jurisdiction, and with
them the legal concerns and liability. Public perception and expectations
regarding “acceptable” risk may vary from locale to locale. A significant
reason for overlaying project-specific plans is the need for communicating a common
strategy rather than allowing the owner or individual trades to default to
their generic practices, thereby avoiding multiple sets of rules. The bottom
line is a tailored Safety Plan is the responsible thing to do.
The objectives
of each project’s Safety Plan are to protect people, protect resources, protect
the general contractor’s reputation, and to be defensible, practical, and flexible.
Each plan consists of a Site Risk Assessment and a set of Safe Work Practices.
Site
Risk Assessment
A
proper site risk assessment is a precursor to developing a project’s Safe Work
Practices program. The assessment includes evaluation of the expected building condition,
whether work can be staggered to limit occupancy, how much activity will occur
indoors and within tight spaces, and whether workers will be in frequent
contact with others. If the project is a renovation of an existing building,
the questions to be asked might additionally include whether portions of the
building not within the project scope will be occupied during construction and,
if so, whether they the HVAC system will provide adequate levels of ventilation
to mitigate the risks of virus transmission. Again, the key is understanding
the particulars of the project to protect workers most effectively and everyone
else associated with it.
Safe
Work Practices Program Elements
David
outlined the key elements of a Safe Work Practices program for a construction
project:
COVID-19
Safety Team
The COVID-19
Safety Team is comprised of a Core Team and an Extended Team for a given
project. The Core Team possesses a command of the subject matter and
organizational expertise. The Core Team is responsible for developing the Safe
Work Practices Program and monitoring public health agency guidelines as they
evolve to keep the program current.
The
Extended Team implements the Safe Work Practices program, performs necessary
training, enacts program provisions, represents individual constituencies within
the organization, and solicits feedback regarding the program’s implementation.
Each Safety
Team should have its dedicated COVID-19 safety coordinator.
Prevention
We’re
all familiar by now with the recommended prevention practices: Wash your hands.
Don’t touch your face. Stay home if sick. Wear a mask and use other PPE. Maintain
social distancing. Clean and disinfect the worksite frequently. Medically
screen workers before they step on site. Stagger trades and shifts to the
extent practicable. All of these measures have proven effective and easy to
understand. The challenge is to consistently and diligently apply them.
Response
If one or
more persons on the project team contract the virus, the Safety Team will respond
in accordance with established protocols. These include documenting the case,
separating and isolating the individual or individuals, contact tracing, cleaning
and disinfection, monitoring and validation, and follow-up as necessary.
Recordkeeping
Recordkeeping
would include documenting the training conducted and also listing site, job, and
task-specific activities. Keeping a log of all jobsite visitors (including
their contact information) is an imperative, both to facilitate contact tracing
and for verification and audit purposes. The Safe Work Practices program should
also institute a formal record retention policy.
Supply
Management
The
Safe Work Practices program would also formalize the specification, procurement,
distribution, and inventorying of necessary supplies, including PPE and cleaning products.
Additional
Components
In the
case of projects involving building sites that may be closed due to COVID-19
and subsequently reopened, the shutdown of water systems and HVAC systems—before
closure, during closure, and before re-occupancy—presents its own set of issues.
General contractors and occupants need to follow guidance for reopening
buildings after a prolonged shutdown or reduced operation. Mitigating the risks
of potential microbial hazards (such as mold in ducts or Legionella in
standing or stagnant water systems) requires implementation of plans to control
humidity, inspect and replace filters as indicated, and flush pipes and other
systems.
Safe
work practices need to additionally include the public health practices for vendors
that will enter the property during progressive states of pandemic concerns and
mandated or recommended public access controls. These practices are to provide
protection for the general contractor but also for the vendors, staff, or
residents (of occupied projects).
Effective
safety plans meet local state, federal guidelines and requirements. They are clear,
concise, and effective statements communicating appropriate requirements and a
commitment to measures that are feasible to implement.
As
David explained, a well-drafted COVID plan—prepared with the assistance of consultants
like the COVID-19 FACS Expert Team—coupled with training and consistent
implementation of protocols is the best way to protect a company’s staff and
employees and by extension their families. Additionally, having such
a plan inserts a firewall to help protect project owners, GC’s, and other
stakeholders by limiting liability.
The COVID-19
virus remains very dangerous and continues to pose a great threat to the health
of the every one of us. Anybody involved in construction activities needs to be
informed about, be aware of, and always follow safe work practices. Big thanks to
David for sharing his insights and providing an essential primer on a topic of great
importance today.
* *
* * * *
Following
the meeting, Emily Ricker—FACS Client Services Coordinator—sent me the
following list of resource information about COVID-19 and the construction
industry’s response to the pandemic:
Government Resources
Oregon
Health Authority COVID Main Page
https://govstatus.egov.com/OR-OHA-COVID-19
Oregon
OSHA Guidance for Construction
https://osha.oregon.gov/covid19/Pages/covid-19-contractors.aspx
Washington
Safe Start Construction Industry Guidance
https://www.governor.wa.gov/sites/default/files/03.25.20-Construction%20Guidance%20Memo%20%28002%29.pdf
Washington
L&I COVID Resource Page
https://www.lni.wa.gov/safety-health/safety-topics/topics/coronavirus
Centers
for Disease Control & Prevention COVID-19
https://www.cdc.gov/coronavirus/2019-ncov/index.html
World Health Organization COVID-19
https://www.who.int/emergencies/diseases/novel-coronavirus-2019
Other Useful Resources
Association
of General Contractors COVID Main Page
https://www.agc.org/coronavirus
CPWR
COVID-19 Construction Clearinghouse
http://covid.elcosh.org/index.php
NIEHS
COVID-19 Worker Training Tools
https://tools.niehs.nih.gov/wetp/covid19worker/index.cfm
Swinerton
Construction COVID Safety Plan