If you currently have construction underway, or are contemplating a construction start in the near future, it is critical that your contractor have a comprehensive and detailed COVID-19 response plan in place.
A little more than a month ago most contractors, and certainly all senior living operators, were not even familiar with what such a plan should even look like. However, now, it is critical that senior living operators ensure their contractors have a solid COVID-19 response plan in place. Thus, many contractors are quickly creating such strategies, with wide degrees of quality and comprehensiveness.
Why the importance?
Vassar Byrd, CEO of Rose Villa in Portland, OR, just began early construction work on her campus ahead of a much larger project hoping to start this summer. Vassar notes, “We felt it was absolutely critical to get as far ahead of the curve on this as possible to not only safeguard the workers on campus but also our residents and staff, and so that my management team and board understand thoroughly our contractors plan in advance.”
Randy Gross, Vice President of Development with Covenant Retirement communities in Chicago, IL, with several projects under construction or in the planning stages, adds, “It is critical to not only understand how the contractor will be safeguarding workers to prevent the spread, but also, that the owner and the contractor are on the same page in regard to responding to a potential or confirmed exposure on the job site in terms of cleaning, quarantine and possible shutdown of part or all of the job site. It is essential to understand the plan in advance along with the various protocols, so the team is not reacting to an exposure without the benefit of prior discussions reflected in the plan.”
“First, a well-thought out plan prevents the spread and insures there is a protocol in case of exposure,” adds Jason Schneider, Partner & Director of Project Development with VJS Construction Services Inc. in Milwaukee, WI, noting the impact of the plan is twofold. “Second, it demonstrates to all the trades and workers that we’re following best practices to create a safe site which gives them the confidence to show up and work on the site, which obviously impacts both schedule and quality of work”
Craig Johnson, a Project Manager with CE Floyd Construction in Middletown, CT adds, “Even if the job site is being run as safely as possible, a solid plan must also confirm for the owner that the contractor is being proactive in terms of checking on their offsite suppliers and vendors so that COVID 19 is not impacting scheduled material deliveries”.
Finally, the plan needs flexibility to evolve. The plan should be based on state and local public health department guidelines and construction industry best practices and, Randy Gross adds, “These should be monitored continuously as they are changing often, even daily”.
Below is a 75-point checklist based on a review of multiple suggested best practices COVID-19 plans from various construction trade associations plus exemplar plans from specific contractors.
We hope this is a tool you can use to evaluate the specific plan presented by your contractor for your senior living construction project.
We have broken down the checklist into five categories as follows, which you can click to be taken to each section of this article:
I. Responsibility for the Plan
III. Response in the event of an exposure at the job site
V. Refining & updating the Plan
As noted in Section 5, as the pandemic and our understanding of the virus and its spread evolves, so too will your plan need to be updated and refined. For example, new items were added just as this post was published based on updated recommendations.
We also present this checklist with three caveats.
First, it is not the intent of this checklist to provide legal advice. Furthermore, once under construction, job site safety is the primary responsibility of the contractor. Julie Peterson, a partner with the law firm of Erickson Peterson Cramer in St. Paul, Minnesota, notes, “The contractor needs to make the call on specific steps and protocols on the job site. If an owner gets too involved with small specifics, they are potentially opening themselves to legal liability. However, the contractor has the responsibility to act reasonably and the owner can ask them to confirm they are following industry best practices, e.g.if the contractor is proposing to shut down an entire job site for an extended period and thus asking for extended general conditions to do so.”
Second, your contractor’s COVID-19 response plan must be complementary to and supplement the contractor’s overall safety plan, which we assume the owner has already reviewed and approved.
Finally, each construction site and construction job is unique and some of these items may not be applicable to or feasible at all sites.
I. Responsibility for the Plan
1. Decide who at the contractor’s corporate office is the point-person responsible for the plan.
2. Designate one individual at the job site charged with establishing, implementing and enforcing the plan.
- This may be the foreman
- It may also be wise to designate a Social Distancing Officer
3. If possible, make it so the designated person can be easily identified with an identifying vest or badge.
4. Determine if any special training has been received by the onsite designated individual or if further training is needed.
5. Ensure that all contractor’s personnel both onsite and at the corporate office familiar with and able to answer questions from employees and trade partners about the plan.
- This can be led on site by the designated point person
6. Confirm that all trade partners are made aware of and are required to follow the plan.
7. Make sure that key provisions of the plan are posted at highly visible parts of the job site.
8. Understand the provisions for warnings and/or fines if contractor’s personnel and/or trade partner/sub-contractors do not follow these protocols.
II. Preventing the Spread of COVID-19
Job Site Considerations
Getting to the job site
9. Encourage employees to minimize ride sharing.
10. Make arrangements for the contractor working with subcontractors to stagger job starts and finishes to avoid congestion entering and leaving the site.
11. After the workday, encourage workers to change work clothes prior to arriving home and to wash clothes in hot water with laundry sanitizer.
Site Access
12. Make sure all construction employees entering the job site are screened by a contractor or trade partner supervisor as follows:
- Touch-less Temperature Check
- Confirm your HR and / or legal department have reviewed for any HIPAA implications if data is being logged.
- Ideally temperature checks would provide all workers the same level of confidence as them knowing everyone on site also has to have work boots, protective glasses, safety vests, hard hat, etc.
- Answering the following questions:
- Have you or anyone in your family been confirmed positive for COVID-19 or in the process of being tested?
- Are you or anyone in your family currently experiencing any symptoms?
- Have you been in close contact with others confirmed positive or experience symptoms?
13. Mandate that only construction-related personnel are allowed on the job site.
14. Determine under what provisions, if any, are off-site construction personnel, the owner, architect or owner’s representative to be allowed on the job site.
- Such provisions may include: Not at all, only during off-hours, only if escorted, etc.
15. Establish if whether weekly Owner OAC walk-throughs with the construction team will be held via FaceTime or similar video streaming platform.
Deliveries
16. Establish protocols for site deliveries so as to meet minimal contact and cleaning protocols:
- Require delivery personnel to remain in their vehicles if possible while deliveries are unloaded solely by receivers using proper PPE.
- Whenever possible, make sure nothing is passed between the deliverer and the receiver (e.g. shipment documents and pens for signature).
Clearly limit and identify delivery zones to receivers and deliverers only.
Community Access
17. Confirm that construction employees will not have access to any other parts of the community campus including currently occupied resident buildings for any reason or specify under what conditions and requirements that would allow them access to other areas.
Job Site Infrastructure
Cleaning Stations
18. Ensure that the contractor provides multiple hand washing facilities at the jobsite.
- E.g. with soap and water, alcohol-based hand rubs and/or hand sanitizer in the workspace
19. Ensure that the contractor provides Safety Data Sheets for all disinfectants used onsite.
20. In lieu of a common source of drinking water, such as a water cooler, mandate workers to use individual water bottles.
Work Trailers
21. As a general rule, ensure only necessary or assigned contractor employees are allowed to enter the trailers and that they must maintain social distancing while inside the trailer.
22. If project meetings are not able to be held online or outside and must be held in the trailer, confirm they must meet the requirements of job site interactions and meetings below.
23. There shall be no community provided food, e.g. lunch buffets, donuts, candy dishes, etc.
24. Remove communal coffee pots, water dispensers, hot boxes and microwaves from trailers and other common areas.
Construction Equipment & Vehicles
25. Encourage employees to use/drive the same exact truck or piece of equipment every shift.
Doors & Pathways
26. Whenever possible, leave doors open have doors and/or handles removed.
Breaks & Lunch
27. Encourage employees to stagger breaks and lunches.
28. Require lunches and breaks to be taken in the worker’s vehicle.
29. If other means of transportation are used to arrive at the job site, establish a firm rule against groups of more than ten people and, still require social distancing.
30. Disallow food trucks and/or communal food on the job site.
Portable restrooms (aka port-a-potty)
31. Ensure that the contractor works with its trade partners to provide, whenever possible, one port-a-potty per trade designated for use only for that trade, locked with access only to the designated trade, and equipped with disinfecting spray and disinfectant towels outside each port-a-potty, which will be cleaned regularly per the cleaning sections below.
Job Site Cleaning
32. Require the contractor or trade partner to clean frequently touched surfaces with a disinfecting solution at least once a day if not several times a day.
- These might include common areas such as doorknobs, keyboards, desks, remote controls, radios.
33. Establish how frequently the job site will be cleaned, such as each day or a certain number of times per week. This could include:
- Wiping down contact surfaces in the job site, e.g. entry gates, door handles and knobs, locks, handrails, gang box handles, keyboards, counters, ladders, switches, controls and other surfaces.
- Wiping down and cleaning vehicles, equipment and tools.
- Wiping down all surfaces in the job site trailers.
- Collecting and removing trash.
- Portable job site toilets.
34. Require employees performing cleaning to wear proper PPE including latex or vinyl gloves and that they use proper disinfectant.
35. Confirm cleaning techniques using pressurized air or water sprays (that may result in bioaerosols) will be avoided.
Job Site Interactions & Meetings
36. Mandate all workers and employees to avoid physical contact with others and direct others to increase personal space to at least six feet.
37. Confirm the preferred venue for meetings is by telephone or video call if possible.
38. Confirm all onsite meetings including but not limited to, Safety Meetings, Foreman Meetings, and Pre-Construction Meetings, or other meetings that cannot be held by phone or video call, are encouraged to be held outside where employees can maintain the 6’ distancing rule.
39. If meetings must be held inside the job office or trailer, or inside any occupied space, ensure that all employees must maintain the 6’ distancing rule and groups are limited to no more than 10 people.
40. Discourage the exchange/sharing of paper documents or shared writing utensils, and use electronic communication whenever possible.
Job Site Compartmentalization
41. Segregate the construction site to the extent possible in physical zones or implement other methods to keep crews & trades physically separated so that trades will not be stacked in their workflow.
42. Set upper limits on the number of people allowed in each zone.
43. Establish one-way staircases where practical to minimize worker contact.
44. Have the contractor divide crews & staff into two groups for the duration of the project wherever possible so that projects can continue to work effectively, especially if one of the divided teams is required to quarantine per Section 3 below.
45. Outline the reasons for allowing an employee to shift from one work group to another.
46. Have the contractor develop and communicate a scheduled staggered use of “Skip, Elevator, Stairwell” volume controls for building entry and exit procedures.
47. Operate/occupy freight elevators by one individual at a time where feasible.
Work Groups
48. Confirm workers & employees know they must maintain a work distance of six feet between each other at all times.
49. Establish the protocol if employees cannot maintain the 6’ distancing rule for a particular task.
- For example, this may require them to use personal protective equipment (PPE) at all times, e.g.
- Full-face hard hat face shield.
- ½ mask respirator with P100 cartridges.
- N95 mask
50. Confirm daily cleaning of face shield or ½ mask respirator is required.
51. Instruct employees to limit the use of co-workers’ tools and equipment.
52. To the extent tools must be shared, have the contractor provide alcohol-based wipes to clean tools before and after use.
53. Confirm workers are not allowed to share PPE.
Individual Workers
54. In additional to regular PPE for workers engaged in various tasks (safety glasses, fall protection, hard hats, hearing protection), the contractor should also provide and/or require workers to wear:
- Gloves – any type appropriate for the task
- Eye protection
- Masks
- The CDC is currently not recommending N95 masks, but establish whether employees are recommended to wear or required to wear non-N95 masks.
55. Confirm that storage of personal gear, such as jackets, vests and rain gear is not permitted on-site unless stored in a location where contact with individuals is not possible.
Responsibility of the Individual Worker
56. Confirm that all employees and workers are instructed and understand they must NOT report to work or; if at work, report to their manager or supervisor if they are experiencing signs or symptoms of COVID-19 or come into close contact with someone showing these symptoms:
- Coughing
- Fever
- Shortness of breath, difficulty of breathing, and
- Early symptoms such as chills, body aches, sore throat, headache, diarrhea, nausea/ vomiting and runny nose.
57. Confirm that workers leaving the job site because of illness must collect their personal possessions before existing the work site.
58. Confirm training and instruction that all workers must frequently wash their hands with soap and water for at least 20 seconds; when soap and running water are unavailable, use an alcohol-based rub with at least 60% alcohol.
59. Confirm training and instruction that all workers must avoid touching their eyes, nose or mouth with unwashed hands.
60. Confirm that all workers must avoid using other workers’ phones, equipment, desks, offices or other work tools when possible.
61. Confirm that all workers must follow appropriate respiratory etiquette, which includes covering for coughs and sneezes.
62. Confirm that all workers must clean their personal tools daily.
63. Disallow hand-shaking or other contact greetings.
III. COVID Exposure Response
If a worker tests positive
64. Establish the protocol for if a worker tests positive.
- E.g. “Any worker who tests positive for COVID-19 will be directed to self-quarantine based on current CDC guidelines (e.g. symptom free and 7 days from test results).”
If a worker or any individual onsite exhibits symptoms
65. Establish the protocol for if a worker shows symptoms.
- E.g. any employee/ contractor/ visitor showing symptoms of COVID-19 will be asked to leave the job site immediately and return home until symptom free for 72 hours OR quarantined for 14 days unless can provide doctor’s note allowing them back to work.
If a worker has close contact (not on the job site) with an individual who tested positive
66. Establish the protocol for if a worker has a family member who tests positive or the worker worked at close contact (i.e.. within six feet) at another job site with an individual testing positive.
- E.g. They must self-quarantine for 14 days from date of last contact with that individual.
If a worker has close contact (on the job site) with an individual who tested positive
67. Establish the protocol for workers who were in close contact at the job site with someone who tests positive.
68. Establish the protocol for segregation and cleaning of the area.
- E.g. Sample Protocol
- If the contractor learns that a worker has tested positive, the contractor will investigate to determine the co-workers who may have had close contact (six feet) with the confirmed-positive employee in the prior 14 days.
- The contractor will direct those individuals who have had close contact with the confirmed-positive employee to self-quarantine for 14 days from the last date of close contact with that employee.
- If applicable, the contractor will also notify any sub-contractors, vendors, suppliers or visitors who may have had close contact with the confirmed-positive employee.
- All areas onsite potentially infected by a confirmed or probable case will be barricaded to keep individuals six feet away until the area (after waiting as long as possible to minimize potential for exposure to respiratory droplets), is properly cleaned and disinfected.
- The contractor may, at its discretion, also direct workers who were not within six feet but still proximately close to the confirmed positive worker to stay at home and self-monitor for some period.
Other
69. Confirm the protocols are compliant with OSHA and HIPAA.
- E.g. Sample protocol
- The contractor will determine which events meet the criteria for record-ability and reporting under OSHA’s record-keeping rules.
- Except for circumstances in which the contractor is legally required to report workplace occurrences of communicable disease, the confidentiality of all medical conditions will be maintained in accordance with applicable law and to the extent practical under the circumstances.
IV. Meeting the Schedule
70. Ensure that the contractor is continually and proactively reaching out to subcontractors and material suppliers to confirm that no COVID-19 impacts are affecting their scheduled work or deliveries.
71. In the event of an economic downturn, confirm the steps taken by the contractor to proactively check on the financial health of its subcontractors and material suppliers to avoid any project disruption.
V. Refining & Updating the Plan/Other Provisions
72. Confirm that these protocols and the cost to implement them are included in the contract price general conditions.
73. Confirm COVID-19 impacts will be a standing agenda item in the weekly Owner OAC meetings.
74. Determine the individual responsible for updating the plan and informing owner of any proposed changes.
75. Establish the provisions for changing or terminating the plan.
- E.g. “this plan will remain in effect until Contractor and Owner have mutually agreed that some or all of these protocols are no longer warranted based on the status of the COVID-19 pandemic and/or new guidance from the <State> Health Authority or the Center for Disease Control and, at that time, the plan will be updated and modified accordingly”
This checklist was prepared based on a review of recommended best practices documents and exemplar plans from the following sources
Trade Organizations/ Governmental
- AGC (Associated General Contractors of America) / CISC (Construction Industry Safety Coalition)
- AGC-Houston
- AGC-Minnesota
- ARTBA (American Road & Transportation Builders)
- CCA (Canadian Contractor Association)
- OSHA
Construction Company Exemplars
About the author:
Craig Witz, the principal of Witz Company, has more than 30 years successful seniors living experience. Before forming Witz Company in 2002, he served as a senior development manager with both regional and national senior living development firms. He has national experience on small and large independent living, assisted living, congregate and Life Plan communities. He is a member of Leading Age Wisconsin and is a licensed attorney.
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For more useful information to help senior living organizations navigate the challenges presented by COVID-19, visit the Love & Company blog for in-depth articles and resources. To learn more about how Love & Company can help your organization maintain its marketing and sales efforts during this time, contact Tim Bracken at 410-207-0013 or tbracken@loveandcompany.com.
