4/17/2020

Managing EHS Issues

and COVID-19

Because guidance on this topic is continually

changing, the content for this presentation
is current. If watching a recorded version of
Disclaimer the presentation, be aware guidance may
have changed.

1
 4/17/2020

Matt Schroeder –
Environmental
Division Manager
Offices
Illinois – Champaign, Freeport, Rochelle, Rockford, Springfield
Wisconsin – Monroe, Sheboygan
Iowa – Cedar Rapids, Manchester, West Union

Contact
Matt Schroeder
Environmental Division Manager
mschroeder@fehr-graham.com
920.838.6373 (cell)
920.453.0700 (office)
fehr-graham.com

Preventing disease transmission in the workplace

Housekeeping and Hygiene

Disinfection

Agenda CDC, OSHA, EPA, IEPA Guidance

Keeping your workplace safe

Respiratory Protection

Safety Training and Certifications

2
 4/17/2020

Preventing Disease
Transmission in the Good housekeeping has
never been more important
Workplace or received a higher priority.

Disinfecting a
workspace

3
 4/17/2020

CDC –
Instructions
and Guidance
for Cleaning

CDC Cleaning Guidance – 4/1/2020

cdc.gov/coronavirus/2019-ncov/community/organizations/cleaning-disinfection.html
8

4
 4/17/2020

EPA - Disinfectants for Use Against SARS-CoV-2

epa.gov/pesticide-registration/list-n-disinfectants-use-against-sars-cov-2 9

Be aware of potential impacts

of cleaning chemicals to onsite
wastewater treatment systems.
A couple
additional
consideration …
Managing waste from
disinfection processes.

10

10

5
 4/17/2020

A Worker Tests
Positive
• Have a plan in place for
decontamination
• Large scale cleaning beyond
capability of your
organization

11

11

What to do to keep
your workplace safe

• Communicate!!!!!
• Task Safety Team or Human Resources to monitor updates
• Administrative Controls – have a written plan, Crisis Committee
• Changes to teams and workgroups – evaluate options for high
risk groups
• PPE – mandatory mask, face shields, gloves, suits
• Employee/visitor temperature checks/survey
• In plant laundry
• Reduce paper processes/handling – look for automation
• Process observation/coordinator
• Now is a great time to look for opportunities to reduce
respiratory risks - engineering controls
• Mandatory cleaning/checklist at end of shift

12

6
 4/17/2020

Retaliation
Guidelines
What if a worker complains that you are
not doing enough to provide a safe and
healthy work environment?

13

Anti-Retaliation

14

14

7
 4/17/2020

OSHA Guidance
osha.gov/SLTC/covid-19/

15

15

What to do
if a worker
becomes ill

16

16

8
 4/17/2020

Have you developed guidelines for what your company will do following a
report of a worker testing positive?

17

17

OSHA
Enforcement
Flexibilities

18

18

9
 4/17/2020

Mandatory
Use of
Respirators

• Medically evaluated
• Fit Tested
• Trained

19

Voluntary Use of
Respirators

• Medical evaluation
• Training
• NO Fit Test
Requirement

20

20

10
 4/17/2020

OSHA
Memorandums
• Reassess engineering controls
and work practices in light of
N95 shortages
• Alternative respirators
• Extended use/Reuse of masks
under certain conditions
• Use of expired masks
• Go to the website for
additional info:

https://www.osha.gov/SLTC/covi
d-19/standards.html#directives

21

21

Managing
Safety
Training and
Certifications

22

22

11
 4/17/2020

23

U.S. Department of Labor

Under OSHA’s recordkeeping requirements, COVID-

OSHA Recordable 19 is a recordable illness, and employers are
responsible for recording cases of COVID-19, if:
1. the case is a confirmed case of COVID-19, as
defined by Centers for Disease Control and
Prevention (CDC)
2. the case is work-related as defined by 29 CFR
§ 1904.5
3. the case involves one or more of the general
recording criteria set forth in 29 CFR § 1904.7

23

As of April 10, 2020, OSHA will not enforce 29 CFR §

1904 to require other employers to make the same
work-relatedness determinations, except where:

Enforcement • There is objective evidence that a COVID-19 case may

be work-related. This could include, for example,
Guidance for many cases developing among people who work
closely together without an alternative explanation
Recording Cases
of Coronavirus The evidence was reasonably available to the employer.
• Information given to the employer by employees

Disease 2019 • Information that an employer learns regarding its employees’

health and safety in the ordinary course of managing its
business and employees.
(COVID-19)
• No exception to healthcare, EMS and correctional
facilities

24

24

12
 4/17/2020

CDC
Guidance

25

25

• EPA guidance on enforcement discretion.

• States are also applying judgement to enforcement.
• Be aware for the potential for enforcement by citizens.
Environmental • Importance of communication and planning.
• Be aware that EPA or state policy does not relieve
Agency regulated entities from compliance obligations.
• Make every effort to stay in compliance.

Enforcement • Act responsibly!

• Identify and document the specific nature and
causes of any non-compliance.
• Identify how COVID-19 was the cause.
• Use existing procedures to report noncompliance.

26

26

13
 4/17/2020

Reporting Deadlines

• May 1 – Annual Emissions Reports

• July 1 – Toxic Release Inventory
• Site Specific Reporting Obligations
• Discharge Monitoring Reports
• Semi-Annual and Annual Compliance Reports
• Air and Water Testing
• TSCA – Chemical Data Report –
• Deadline Extended June 1 – November 30

27

27

This is an emerging, rapidly evolving situation and

the Centers for Disease Control and Prevention will provide
updated information as it becomes available, in addition to
updated guidance. This website provides key EPA resources
on the coronavirus disease (COVID-19).
https://www.epa.gov/coronavirus

28

14
 4/17/2020

• CDC: Guidance for reducing health risks to

workers handling human waste or sewage
• CDC: Healthcare professionals: Frequently asked
Links for questions and answers
additional • CDC: Healthy Water
• Occupational Safety and Health Administration:
information: COVID-19 Control and Prevention: Solid waste
and wastewater management workers and
employers
• World Health Organization: Water, sanitation,
hygiene and waste management for COVID-19

29

29

• Illinois Department of Labor:

www2.illinois.gov/idol/Pages/default.aspx
Additional • www.epa.gov/coronavirus
• www2.illinois.gov/epa/topics/Pages/covid19.aspx
Links • www.fehr-graham.com

30

30

15
 4/17/2020

31

31

Matt Schroeder –
Environmental
Division Manager
Offices
Illinois – Champaign, Freeport, Rochelle, Rockford, Springfield
Wisconsin – Monroe, Sheboygan
Iowa – Cedar Rapids, Manchester, West Union

Fehr Graham IMEC

Matt Schroeder Emily Lee
Environmental Division Manager Program & Partner Relations Coordinator
mschroeder@fehr-graham.com elee@imec.org
920.838.6373 (cell) 608-445-4905 (cell)
920.453.0700 (office)
fehr-graham.com www.IMEC.org

32

16