OFFICE OF ENVIRONMENTAL HEALTH AND SAFETY 5255 Hampton Blvd. Spong Hall, suite 2501 Norfolk, Virginia 23529

Phone: (757) 683-4495 Fax: (757) 683-6025

Occupational Safety & Health Environmental Health Laboratory Safety Industrial Hygiene Radiation Safety Hazardous Waste Pollution Prevention

Occupational Health Program/ Communicable Disease Management

Administered by

Environmental Health and Safety Office

Revision Date: October 2020

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Table of Contents I. Asbestos Standard (29CFR1926.1101 ..................................................................................... 3

II. Bloodborne Pathogen Standard (29CFR1910.1030) ........................................................... 4

III. Hazardous Waste Operations and Emergency Response Standard ..................................... 4

IV. Laboratory Standard............................................................................................................. 4

V. Lead Standard ...................................................................................................................... 5

VI. Hearing Conservation Standard ........................................................................................... 5

VII. Respirator Standards ............................................................................................................ 5

VIII. Welding, Cutting and Brazing Standards ......................................................................... 6

Communicable Disease Management (COVID-19) ................................................................... 7

I. Occupational Exposure Risk Levels: ....................................................................................... 7

II. Requirements for Job Tasks classified as “Very High” or “High” Exposure Risk: ............ 8

III. Requirements for Job Tasks classified as “Medium” Exposure Risk: ............................... 10

IV. Screening, Testing, and Contact Tracing: .......................................................................... 10

V. Training .............................................................................................................................. 11

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Old Dominion University Occupational Health Program

This program applies to University employees who are exposed to occupational health hazards in the course of their work and may require occupational health services such as medical exams, blood analyses, and immunizations. The following Occupational Safety and Health Administration (OSHA) regulations and University procedures in which medical surveillance is required are applicable to the University:

I. Asbestos Standard (29CFR1926.1101) For employees who are exposed at or above the 8-hour TWA of 0.1 fiber/cm3 and/or excursion limit of 1 fiber/cm3 or for employees who are engaged in Class I, II or III work for a combined total of 30 or more days per year. Required Medical Surveillance/Frequency: • Administer the OSHA Medical Questionnaire, per 29CFR1926.1101 Appendix D. (pre-

employment and annually) • Obtain medical and work histories with special emphasis directed to symptoms of the

respiratory system, cardiovascular system, and digestive tract. (annually) • Conduct a physical exam. (annually) • Perform a chest roentgenogram (posterior-anterior 14x17 inches).

(Chest roentgenograms shall be interpreted and classified by a B-reader, a board eligible/certified radiologist, or an experienced physician with known expertise in pneumoconioses. All interpreters shall have immediately available for reference a complete set of the ILO-U/C International Classification of Radiographs for Pneumoconiosis. Recordation shall be made on an interpretation form following the format of the CDC/NIOSH (M) 2.8 form. The form shall be filed in the employee's chart.)

Frequency of chest roentgenograms

Years since first exposure Age of employee 15 to 35 35 to 45 45+

0 to 10 Every 5 yrs. Every 5 yrs. Every 5 yrs. 10+ Every 5 yrs. Every 2 yrs. Every 1 yr.

• Conduct a pulmonary function test ((FVC and FEV1). (annually)

• Perform any other tests that the examining physician deems by sound medical practice to be

necessary. (as recommended)

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II. Bloodborne Pathogen Standard (29CFR1910.1030) For employees identified as being at risk of an occupational exposure to blood or other potentially infectious material. Required Medical Surveillance/Frequency: • Administer Hepatitis B vaccines. (upon employment or assignment - vaccination series

completed over a 6 month period) • Administer titers. (within two months of completing vaccination series for employees using

needles only - not recommended for other employees) • Administer boosters. (as recommended) • Administer post-exposure medical care and prophylaxis in accordance with the most current

recommendations of the U.S. Public Health Service. (upon exposure) • Provide HIV, Hepatitis B Surface Antigen and Hepatitis C Viral testing to source patients.

(upon exposure for source patient)

III. Hazardous Waste Operations and Emergency Response Standard (29CFR1910.120)

For Environmental Health and Safety Office employees conducting hazardous waste operations or emergency response operations for releases of hazardous substances. Required Medical Surveillance/Frequency: • Provide medical exams to include medical and work history and physical exam with special

emphasis on symptoms related to the handling of hazardous substances and health hazards and to fitness for duty including the ability to wear any required personal protective equipment under conditions that may be expected at the work site. (upon employment or assignment, annually, upon termination and upon development of symptoms related to exposure)

IV. Laboratory Standard (29CFR1910.1450)

For all employees working with hazardous chemicals in laboratories. Required Medical Surveillance/Frequency: • Provide medical exams to include medical and work history and any other procedures or tests

specified in other OSHA standards (if applicable) or deemed necessary by the physician. (upon exposure or in accordance with any other OSHA standard)

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V. Lead Standard (29CFR1910.1025) For employees who are or may be exposed at or above the action level of 30 ug/m3 for more than 30 days per year. Required Medical Surveillance/Frequency: • Provide medical exams to include medical and work history with particular attention to past

lead exposure and a physical exam with particular attention to the teeth, gums, blood pressure, hematologic system, gastrointestinal system, renal system, cardiovascular system, and reproductive system. (upon employment or assignment)

• Provide blood chemistry profile to include: blood lead, zinc protoporphyrin (ZPP), hemoglobin and hematocrit, red cell indices, peripheral smear morphology, blood urea nitrogen, and serum creatinine.

Frequency of blood lead and ZPP testing

Last blood lead level Subsequent testing < 40 ug/100g Every 6 months 40-49ug/100g Every 2 months > 50 ug/100g Every 1 month

• Perform a routine urinalysis with microscopic examination and any other procedures or tests

deemed necessary by the physician. (upon employment or assignment) • Perform pregnancy testing or laboratory evaluation of male fertility. (upon request from

employee)

VI. Hearing Conservation Standard (29CFR1910.95) For employees exposed to noise at or above the action level of 85 decibels. Required Medical Surveillance/Frequency: • Perform audiometric testing. The tests shall be performed by a person qualified per

29CFR1910.95 (g)(3) and the audiograms shall meet the requirements of 29CFR1910.95 (h). (baseline within 6 months of employee's exposure at or above the action level and annually thereafter)

VII. Respirator Standards (29CFR1910.134 & 139)

For employees assigned to wear respirators in the course of their work. Required Medical Surveillance/Frequency: • Complete the OSHA Respirator Medical Evaluation Questionnaire. (upon employment or

assignment) • If further medical examinations are deemed necessary, provide medical exams to include any

tests, consultations or diagnostic procedures deemed necessary by the physician to make a final

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decision on the employee's ability to wear a respirator. (upon recommendation from the reviewing physician)

VIII. Welding, Cutting and Brazing Standards (29CFR subpart Q)

For employees who perform welding as a job function. Required Medical Surveillance/Frequency:

• Provide medical exams to include medical and work history, blood chemistry profile, physical exam and any other procedures or tests deemed necessary by the physician. (upon employment or assignment and annually thereafter).

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Communicable Disease Management (COVID-19) Coronavirus Disease 2019 (COVID-19) is a respiratory disease caused by the SARS-CoV-2 virus. This plan summarizes mandatory health and safety requirements for engineering, administrative and work practice controls, and personal protective equipment (PPE) to reduce the risk of exposure and transmission of COVID-19 to employees of Old Dominion University. The employee risk categories described in this plan are based on the Virginia Emergency Temporary Standard, 16VAC25-220, as well as guidance from the Centers for Disease Control and Prevention (CDC). Job tasks are classified according to the hazards employees are potentially exposed to. Old Dominion University communicates information on COVID-19 to employees and students on the University website. Employees should regularly visit this site for updates. Additionally, all employees of the University are expected to comply with the practices, protocols, and guidelines described in the Department of Human Resources’ Return to Campus Guide and the ODU Blueprint for Fall 2020 Reopening. This information, as well as other important updates, are available at the following website: ODU COVID-19 Website: https://www.odu.edu/emergency/news/2020/2/novel_coronavirus_co

I. Occupational Exposure Risk Levels:

The COVID-19 exposure risk level for all job functions performed on campus shall be assessed to ensure appropriate hazard controls are applied. Hiring managers, in conjunction with the Human Resources Department, are responsible for assessing the tasks performed by employees. Job tasks will be rated as “Very High”, “High”, “Medium”, or “Lower” based on the hazards encountered. Factors that should be considered when assessing exposure risk level include job duties and the types of hazards encountered, work environment, exposure to known or suspected cases of COVID-19, the number of employees and other persons present in relation to the size of the work area, practicable working distance between employees or persons, the duration and frequency of potential employee exposure, contact with potentially contaminated objects or surfaces, and the use of shared spaces such as work vehicles, break rooms, workstations, entryways and exits, etc. Job tasks will fall into the following categories:

A. “Very High Exposure Risk” Applies to employees who perform job tasks with the highest risk of transmission and where there is a high potential for exposure to persons known or suspected to be infected with COVID-19, such as during specific medical or laboratory procedures. “Suspected to be infected” refers to a person who has signs or symptoms of a COVID-19 but has not received a positive diagnosis. Examples of “very high exposure risk” include:

• Aerosol-generating procedures on a patient or person who is known or suspected to be infected with COVID-19.

• Collection or handling of specimens from a patient or person who is known or suspected to be infected with COVID-19.

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B. “High Exposure Risk”

Applies to employees who perform job tasks with a high potential for exposure inside of six feet with known or suspected sources of COVID-19. Examples include:

• Healthcare delivery and support services, wellness services, non-medical support services, physical assistance, etc., provided to a patient, resident, or other person known or suspected to be infected with COVID-19.

• First responder services provided to a patient, resident, or other person known or suspected to be infected with COVID-19.

• Medical transport or other transportation of patients or persons known or suspected to be infected with COVID-19.

C. “Medium Exposure Risk” Applies to employees who perform job tasks not otherwise classified as high or very high exposure risk where more than minimal occupational contact inside of six feet with coworkers or the general public who may be infected with COVID-19, but are not known or suspected to be. Examples include:

• Educational, dining, and retail settings.

• Fitness, gym, and exercise facilities.

• Healthcare delivery and support services that do not involve exposure to known or suspected sources of COVID-19.

D. “Lower Exposure Risk” Applies to employees who perform job tasks with minimal risk of transmission and do not require contact inside six feet with persons who may be infected with COVID-19. Employees in this category have minimal contact with members of the public or co-workers. This category also includes employees who can achieve minimal occupational contact through the implementation of engineering controls, or administrative controls and work practices such as: physical barriers constructed of impermeable materials, telecommuting, staggered works shifts that allow for sufficient physical distancing, remote services, mandatory physical distancing, etc. Face coverings used during contact inside of six feet are not considered an acceptable administrative control to minimize occupational risk. The use of personal protective equipment is not considered an administrative control or work practice.

II. Requirements for Job Tasks classified as “Very High” or “High” Exposure Risk: The controls listed below are in addition to the practices, protocols, and guidelines included in the Old Dominion University Blueprint for Fall 2020 Reopening.

A. Engineering Controls • Appropriate air-handling systems shall be installed and maintained in healthcare

facilities and other places of employment treating, caring for, or housing persons

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known or suspected to be infected with COVID-19. Air-handling systems shall comply with ASHRAE Standards 62.1 and 62.2.

• Employers shall designate airborne infection isolation rooms (AIIRs), when available, for performing aerosol-generating procedures on patients who are known or suspected to be infected with COVID-19.

• Special precautions associated with Biosafety Level 3 (BSL-3) shall be used when handling specimens from known or suspected cases of COVID-19.

• Where feasible, physical barriers shall be used to mitigate the spread of COVID-19.

B. Administrative and Work Practice Controls • Prior to beginning each work shift, employees are expected to conduct symptom

monitoring by completing a Health Screening Questionnaire.

• Non-employee access shall be limited or restricted to only certain workspace areas to reduce the risk of exposure. Occupancy limits within places of employment shall comply with Virginia executive orders.

• Employees are expected to complete education and training on preventing the spread of COVID-19.

• Where feasible, the following work practices shall be utilized: Telework or implement flexible work hours, such as staggered shifts. Increase physical distancing between employees and other persons. Implement flexible meeting options and postpone non-essential travel or

events. Deliver services remotely.

C. Personal Protective Equipment (PPE) • PPE shall be utilized when engineering, administrative, and work practice controls

are not feasible or do not provide sufficient protection.

• Employers shall assess the workplace to determine if job tasks are present or are likely that necessitate the use of PPE. Employees should be involved in this assessment process.

• Employees shall be provided with and wear gloves, a gown or Tyvek suit, a face shield or glasses, and a respirator when working within six feet of persons known or suspected to be infected with COVID-19.

• Employees who are determined to require the use of a respirator must participate in the University’s Respirator Protection Program and obtain approval from the Environmental Health and Safety Office (EH&S). Use of any respirator requires Medical Clearance, Fit Test, and Training, which will be provided by the EH&S office.

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III. Requirements for Job Tasks classified as “Medium” Exposure Risk: The controls listed below are in addition to the practices, protocols, and guidelines included in the Old Dominion University Blueprint for Fall 2020 Reopening.

A. Engineering Controls • Appropriate air-handling systems shall be installed and maintained in healthcare

facilities and other places of employment treating, caring for, or housing persons known or suspected to be infected with COVID-19. Air-handling systems shall comply with ASHRAE Standards 62.1 and 62.2.

B. Administrative and Work Practice Controls • Prior to beginning each work shift, employees are expected to conduct symptom

monitoring by completing a Health Screening Questionnaire.

• Where feasible, the following work practices shall be utilized: Telework or implement flexible work hours, such as staggered shifts. Increase physical distancing between employees and other persons. Implement flexible meeting options and postpone non-essential travel or

events. Install physical barriers where such barriers will mitigate the spread of

COVID-19 (e.g., clear plastic sneeze guards). Deliver services remotely.

C. Personal Protective Equipment (PPE) • PPE shall be utilized when engineering, administrative, and work practice controls

are not feasible or do not provide sufficient protection.

• Employers shall assess the workplace to determine if job tasks are present or are likely that necessitate the use of PPE. Employees should be involved in this assessment process.

• PPE requirements for employees in the medium exposure risk category will depend on the specific work task, the hazard assessment, and the type of exposure.

• Employees who are determined to require the use of a respirator must participate in the University’s Respirator Protection Program and obtain approval from the Environmental Health and Safety Office (EH&S). Use of any respirator requires Medical Clearance, Fit Test, and Training, which will be provided by the EH&S office.

IV. Screening, Testing, and Contact Tracing: Employees are expected to perform daily symptom monitoring and complete a Health Screening Questionnaire prior to the beginning of each work shift.

A. Employees SHALL NOT report to work or to campus if they are showing signs or symptoms of COVID-19, including fever, cough, shortness of breath, new loss of taste or

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smell, and/or gastrointestinal problems. Employees with symptoms should self-isolate until receiving guidance from the University’s occupational health physician.

B. Employees who test positive or are presumed positive (experiencing symptoms) for COVID-19 SHALL NOT return to work or the campus for at least 10 days from symptom onset or until fever-free for at least three days (72 hours). Employees shall be required to be cleared by the University’s occupational health physician prior to returning to work.

C. Employees who have had close contact (defined as being within six feet for 15 minutes or longer) with any person having a confirmed COVID-19 diagnosis SHALL NOT report to work and will be advised to self-quarantine at home for at least 14 days after the close contact occurred. Employees shall be required to be cleared by the University’s occupational health physician prior to returning to work.

In the event of continuous community spread of a communicable disease, contact tracing may be performed by trained University staff or the local health department.

• Employees who test positive for COVID-19 will be interviewed to determine if they were in the workplace within 48 hours from symptom onset. If yes, the employee will be asked to describe their movements on campus and contact made with other personnel.

• Identified close contacts of an infected employee will be contacted and advised to self-quarantine for 14 days after the exposure took place. “Close contact” is defined as being within six feet for 15 minutes or longer.

V. Training a) All Old Dominion University employees will be required to complete training on the

hazards and characteristics of COVID-19, and the procedures to prevent the spread of infectious diseases.

b) The University’s Environmental Health and Safety Office will supply training, as appropriate, to employees who may be exposed to COVID-19 while working on campus. All employees may be required to take one or more training courses on the University’s online training software at https://www.odu.edu/facultystaff/training-development/safety-training.

c) Respiratory protection training is required for all personnel who will wear respirators, including N95 respirators, for work activities, in accordance with the University’s Respiratory Protection Program- https://www.odu.edu/facultystaff/university-business/safety/respiratory.

d) Additional job-specific training may be necessary depending on the employee’s responsibilities and job functions. Job-specific training may include requirements for Personal Protective Equipment (PPE) and specific workplace controls.

e) Refresher training or retraining shall be required under the following circumstances: a. Changes to job-specific training or other University policies. b. Changes in workplace conditions regarding COVID-19.

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c. Inadequacies in an employee’s knowledge or use of workplace control measures that indicate retraining is necessary, as determined by their supervisor.