By: Paul Luker, CSP
Clear to Work
I am a Board Certified Safety Professional and a professional member of the American Society of Safety Professionals with a safety career that spans more than twenty years. I am amazed and dismayed that our health officials have promoted positions that have no basis in science and are not going to reduce the pandemic spread of the COVID-19 virus.
A review of the current return to normal post pandemic guidance from our government health care officials leads me to make the following observations and comment on the effectiveness of our current response plan.
Quoting Ben Franklin, “an ounce of prevention is worth a pound of cure.” Today, prevention is failing to manage the pandemic spread, because health care officials are trained to diagnose disease and then treat the disease. Prevention is not their expertise. It is time to challenge some current ideas about slowing the spread and preventing the current pandemic increasing its impact on our communities.
The CDC guidelines for return to normal post pandemic is a disjointed, dysfunctional discussion that provides guidance for various types of businesses and public venues that is inconsistent for the basic controls to be implemented. The guidelines fail to provide the guidance at a granular level.
OSHA clearly states that cloth masks are not considered personal protective equipment (PPE) for the wearer. They are used to protect other people from the wearer of the cloth mask spreading infectious respiratory droplets. Cloth and paper masks are minimally effective in containing the large droplets that are expelled when a person coughs or sneezes. OSHA, in their latest guidance, then goes on to say that employers can allow the use of clothe masks if they implement additional controls but don’t describe what those additional measures are or how to implement additional controls. OSHA guidance is providing “cover” for reducing the minimum respiratory protection requirements which can only lead to increased transmission of the virus as workers and community members begin to interact as the quarantine is relaxed. We are seeing the spike now even though these measures have been communicated to the public and private community. Clear contradictions in regulation and enforcement only lead to further community spread by diluting the effective of the guidance. Private businesses are struggling with implementation of pandemic response programs and there is a dramatic difference in implementation from business to business. Some businesses have taken robust measures and implemented strong protocols. Others have taken the approach of freedom to choose. Therefore, no proactive measures are being implemented. With the current incubation period for COVID-19, reactive measures once a(n) individual(s) is ill is too late. Small businesses are especially prone to this minimalist approach and cite the cost of implementation as the reason for failing to implement protective measures. If our government would implement an effective N95 face mask policy with uniform enforcement, this issue would be easily resolved.
Retail establishments have installed “sneeze guards” at registers even though there is no evidence that these are effective. These measures have been implemented without considering the airflow from the ventilation systems and the effectiveness of the controls. Further, it is possible for infectious respiratory droplets to be concentrated where money and goods pass through. It is apparent when passing though these registry lines that these measures are for show. There isn’t any enforcement for wearing face coverings and social distancing for employees and the public. Compliance is on the honor system. “Counting heads” in and out of the retail establishment is also for show only and fails to actually provide any real measure for safety or managing social distancing. Limiting access without additional measures, i.e. health screening, does not contribute to the management of community spread.
Schools are busy installing “sneeze guards” made from clear plastic at each student’s desk in an attempt to provide protection from infection spread. The schools have not considered the effects of these “sneeze guards” on the air circulation in the room or the impact of the ventilation (HVAC) circulating the infectious material. All of the school systems I have investigated so far have placed the responsibility of performing daily temperature checks on the parents and schools are not preparing to perform temperature checks on faculty and students entering the campus each day. This is the same protocol that schools have implemented for school security to prevent weapons and other contraband from entering the campus. We all know how well that program is working.
No clear guidance is being provided for enhanced cleaning and no enforcement has been proposed for following the guidance. Because most facilities will take the minimalist approach to managing cleaning along with other controls, this too is likely to fail.
Because public schools and other government agencies enjoy sovereign immunity for their decisions, they can take a minimalist approach with immunity from consequences. Federal, state and local governments have exempted themselves from the regulations and rules that they impose on us and private business.
Without clear regulations and robust enforcement of these regulations, the general public will continue to be misled to believe that the necessary controls are being implemented to protect their health.
Testing is not prevention. Testing is not a proactive measure nor can the numbers be considered a leading indicator of the effectiveness of the pandemic countermeasures. A COVID-19 test costs approximately $50 for analysis but does not include the cost of collection of the test, transportation of the test, or recording and reporting the test. The information is mostly useless since the test report is a snapshot in time and the time delay between collection, reporting, and tracking is days. Anyone who may have tested positive could potentially expose a host of others while they wait for test results.
No comprehensive proactive response has been developed and the safety professionals who managed through the past pandemics have been mostly left out of the response discussion.
What should we be doing?
- Everyone should be required to wear a N95 grade mask when in public. Issuing N95 masks to the public instead of doing testing would be a much better approach to managing the spread. The cost would be a better investment than testing and contact tracing. N95 mask production has caught up with demand and a mask distribution could be implemented quickly to distribute N95 masks to the most vulnerable people first and continue to the balance of the population, as soon as practical. Typically, an employer issuing this type of respirator as a requirement triggers inclusion in a respiratory protection program under 29 CFR 1910.134. where at a minimum an employee receives fit testing, medical evaluation, and training. We’ve all seen the people wearing their cloth coverings and masks with only their mouth covered. At a minimum, training should be provided to the public on how to wear a N95 mask. Further, if they have any underlying medical issues, they should consult with their doctor prior to wearing any face covering.
- Provide clear guidance for enhanced cleaning including a list of products that are effective, cleaning techniques that are effective, necessary frequency for cleaning, and guidance for proper disposal of waste. The enhanced cleaning plan should be documented so it can be improved and reviewed. For example, how many times are elevator buttons and bathroom doorways being cleaned per day?
- Provide clear guidance for minimum requirements for HEPA quality ventilation systems in private businesses and public venues along with inspection and maintenance criteria.
- Quarantine of the public en masse should be eliminated as a control measure for managing COVID-19 and replaced with proactive measures. Even during the height of the pandemic, people who were under quarantine orders were allowed to move about in the community for necessities. Quarantine measures reduced the spread, but they are not feasible in the short or long term. “Essential businesses” continued to operate through the quarantine. No empirical evidence has been produced to show that these “essential businesses” prevented or caused any additional community spread. The common-sense principle can be applied here to show that if a large supermarket can continue to operate safely, other business can follow suit.
- Real-time initial screening must be implemented prior to individuals entering the workplace. This will minimize the amount of COVID-19 virus transfer by sick individuals onto common surfaces, air-borne circulation in the work area, and person-to-person interactions. There are current technologies that allow for contactless facial recognition scanner with infra-red forehead temperature scanner. Reference, “Application of Non-Contact Infrared Thermal Devices for Prevention and Response of Infectious Disease”.
- Human Resource (HR) departments should be required to develop written protocols to protect the job, pay, and sick leave of individuals with elevated temperatures and sickness. By the time a COVID-19 test is taken and verified, it is too late. Proactive steps should be taken to allow an individual with a suspected illness that may be COVID-19 to have their job, pay, and sick leave protected while they get tested and isolate, until better. Further, HR departments should be working as a team with their supervisors and environmental, health, and safety personnel to determine a response should one or more individuals test positive. A business contingency plan should allow for the business to continue instead of a knee jerk reaction of shutting everything down. Our country and businesses cannot continue to be viable with this reactive and fear driven approach.
- Business and public venues can develop and implement all the above protocols and procedures above into a pandemic plan which should also include a comprehensive list including but not limited to: social distancing protocols; how to handle elevators, restrooms, and commons areas; additional cleaning supplies for employees; signage for social distancing reminders; how to handle visitors; etc. Specific requirements and needs based on their particular business should be included.
- Lastly, with all the unclear guidance and confusion, training must be provided to employers, employees, and business owners on the procedures and protocols. Everyone should have an outlet to express concerns and/or gaps in the plan.
With the current fear-based approach, we will continue to shut down our economy and businesses. Now is the time to allow businesses, with guidance from safety professionals, to manage through health exposures and risks. Now is the time to provide regulatory requirements and enforce them. Businesses that follow the law are used to implementing new requirements and procedures to meet regulations
Our businesses, public venues, and workforce face risks every day and we’ve learned to proceed forward and proactively manage these risks. With the current government approach, will a school be forced to shut down if they have one positive case? For how long? What about working parents? What about a business? Will there be another “knee jerk” reaction to a new case? This could go on and on if we don’t take a proactive approach.
What we are currently doing isn’t working. We must focus on prevention at a higher level with serious enforcement and have a continuity of purpose and policy.
From a concerned Safety Professional with solutions on how to move forward without shutting down our economy and businesses.
Paul Luker, CSP
Clear to Work
The views and opinions expressed in the article are those of the authors and do not necessarily reflect the official policy or position of The Winn Parish Journal. Any content provided by the authors are of their opinion and are not intended to malign any religion, ethnic group, club, organization, company, individual or anyone or anything.