Covid-19 Statement

Feb 5, 2021

Roles in Responding to COVID-19

Under the OSH Act, employers are

responsible for providing a safe and healthy workplace free from recognized hazards likely to cause death or serious physical harm.

Implementing a workplace COVID-19
prevention program
is the most effective way to mitigate the spread of
COVID-19 at work.

The most effective COVID-19
prevention programs engage workers and their representatives in the program’s
development and implementation at every step, and include the following

1.       Assignment of a workplace coordinator HR is responsible for COVID-19 issues on the employer’s

2.       Identification of where and how workers might be exposed
to COVID-19 at work
. We have completed a thorough hazard assessment to identify potential workplace hazards related to
COVID-19. This assessment will be most effective if it involves workers (and
their representatives) because they are often the people most familiar with the
conditions they face.


3.       Identification of a combination of measures that will
limit the spread of COVID-19 in the workplace, in line with the principles of
hierarchy of controls.This should include a combination of eliminating the
hazard, engineering controls, workplace administrative policies, personal
protective equipment (PPE), and other measures, prioritizing controls from most
to least effective, to protect workers from COVID-19 hazards. Key examples (
discussed in additional detail below)

4.       In addition to these general guidelines, more specific guidance is available
for certain industries.

A.      eliminating the hazard by separating and sending home infected or
potentially infected people from the workplace

B.       implementing physical distancing in all communal work areas [includes remote work and telework];

C.       installing barriers where physical distancing cannot be maintained;

D.      suppressing the spread of the hazard using face coverings;

E.       improving ventilation;

F.       using applicable PPE to protect workers from exposure;

G.      providing the supplies necessary for good hygiene practices; and

H.      performing routine cleaning and disinfection.

5.       Consideration of protections for workers at higher risk for severe illness through supportive policies and practices. Older adults and people of any age who
serious underlying medical conditions are at higher risk for severe illness from COVID-19.
Workers with disabilities may be
legally entitled to “reasonable
accommodations” that protect them from the risk of contracting COVID-19.
Where feasible, we consider reasonable modifications for workers identified as
high-risk who can do some or all of their work at home (part or full-time), or
in less densely-occupied, better-ventilated alternate facilities or offices.

6.       Establishment of a system for communicating effectively
with workers and in a language they understand.
Imperial encourages workers to report to HR, without
fear of reprisal (see 12 below), COVID-19 symptoms, possible COVID-19
exposures, and possible COVID-19 hazards at the workplace. Communicate to
workers, in a language they can understand and, in a manner, accessible to
individuals with disabilities, all policies and procedures implemented for
responding to sick and exposed workers in the workplace. See below for
additional elements involving
educating and training workers of COVID-19 procedures.

7.       In addition, a best practice has been created and test
two-way communication systems that workers can use to self-report if they are
sick or have been exposed, and that employers can use to notify workers of
exposures and closures, respectively.

8.       Educate and train workers on your COVID-19 policies and
procedures using accessible formats and in a
language they
Communicate supportive
workplace policies clearly, frequently, in plain language that workers understand
(including non-English languages, and American Sign Language or other
accessible communication methods, if applicable), and in a manner accessible to
individuals with disabilities, and via multiple methods to employees,
contractors, and any other individuals on site, as appropriate, to promote a
safe and healthy workplace. Communications should include:

Basic facts about COVID-19,
including how it is spread and the importance of physical distancing, use of
face coverings, and hand hygiene. See
About COVID-19 and What Workers Need to Know About COVID-19, above and see more on physical distancing, PPE, face coverings, and hygiene, respectively, below;

Workplace policies and
procedures implemented to protect workers from COVID-19 hazards (the employer’s
COVID-19 prevention program); and

Some means of tracking
which workers have been informed and when.

  • In addition, we ensure that workers understand their rights to a
    safe and healthful work environment, whom to contact with questions or
    concerns about workplace safety and health, and their right to raise
    workplace safety and health concerns free of retaliation. This information
    should also be provided in a language that workers understand. (See
    Implementing Protections from Retaliation, below.) We also ensure supervisors are familiar with workplace
    flexibilities and other human resources policies and procedures.

9.       Instruct workers who are infected or potentially
infected to stay home and isolate or quarantine
to prevent or reduce the risk of transmission of
COVID-19. We ensure that absence policies are non-punitive. Policies that
encourage workers to come to work sick or when they have been exposed to COVID-19
are disfavored. See below for additional guidance involving
eliminating the hazard.

10.   Minimize the negative impact of quarantine and isolation
on workers.
When possible, Imperial allows
them to telework, or work in an area isolated from others. If those are not
possible, we allow workers to use paid sick leave, if available, or consider
implementing paid leave policies to reduce risk for everyone at the workplace.
Families First Coronavirus Response Act provides certain employers 100% reimbursement through
tax credits to provide employees with paid sick leave or expanded family and
medical leave for specified reasons related to COVID-19 through March 31, 2021.


11.   Isolating workers who show symptoms at work. Workers who appear to have symptoms upon arrival at work or
who develop symptoms during their work shift should immediately be separated
from other workers, customers, and visitors, sent home, and encouraged to seek
medical attention. See below for additional elements involving
screening and testing.

12.   Performing enhanced cleaning and disinfection after
people with suspected or confirmed COVID-19 have been in the facility
. If someone who has been in the facility is suspected or confirmed to have COVID-19, follow the CDC cleaning and disinfection recommendations. This includes:

a.       Closing areas used
by the potentially infected person for enhanced cleaning.

b.       Opening outside doors and windows to increase air circulation in the area.

c.       Waiting as long as practical before cleaning or disinfecting (24 hours is optimal).

d.       Cleaning and disinfecting all immediate work areas
and equipment used by the potentially infected person
, such as offices,
bathrooms, shared tools and workplace items, tables or work surfaces, and
shared electronic equipment like tablets, touch screens, keyboards, and remote

e.       Vacuuming the space if needed.
Use a vacuum equipped with a high-efficiency particulate air (HEPA) filter, if
available. Wait until the room or space is unoccupied to vacuum.

Providing cleaning workers
with disposable gloves
. Additional PPE (e.g.,
safety glasses, goggles, aprons) might be required based on the
cleaning/disinfectant products being used and whether there is a risk of

g.       After cleaning, disinfecting the surface with an appropriate EPA-registered
disinfectant on List N: Disinfectants for use against SARS-CoV-2

h.       Following requirements
in OSHA standards
29 CFR 1910.1200 and 1910.132, 133, and 138 for hazard communication
and PPE appropriate for exposure to cleaning chemicals.


  1. Once the area has been appropriately disinfected, it can
    be opened for use
    . Workers without close contact with the
    potentially infected person can return to the area immediately after
  2. If it is more than 7 days since the infected person
    visited or used the facility, additional cleaning and disinfection is not
    necessary. Continue
    routine cleaning and disinfection, described below.



13.   Providing guidance on screening and testing: Follow state or local guidance and priorities for
screening and viral testing in workplaces. Testing in the workplace may be
arranged through a company’s occupational health provider or in consultation
with the local or state health department. Employers should inform workers of
employer testing requirements, if any, and availability of testing options. CDC
has published
strategies for consideration of
incorporating viral testing for SARS-CoV-2, the virus that causes COVID-19,
into workplace COVID-19 preparedness, response, and control plans. (
See below for more on the use of testing to determine when a worker
may return to work after illness or exposure

14.   Note: Performing screening or health checks is not a
replacement for other protective measures such as face coverings and physical
distancing. Asymptomatic individuals or individuals with mild non-specific
symptoms may not realize they are infected and may not be detected during
through screening.

15.   Recording and reporting COVID-19 infections and deaths: Employers are responsible for recording work-related
cases of COVID-19 illness on their
Form 300 logs if the following requirements are met: (1) the case is
a confirmed case of COVID-19; (2) the case is
work-related (as defined by 29 CFR 1904.5); and (3) the case
involves one or more
relevant recording criteria (set
forth in
29 CFR 1904.7) (e.g., medical treatment,
days away from work). Employers must follow the requirements in
29 CFR 1904 when reporting
COVID-19 fatalities and hospitalizations to OSHA
. More information is available on OSHA’s website. Employers should also report outbreaks to health
departments as required and support their contact tracing efforts.

16.   In addition, Imperial is aware that reprisal or
discrimination against an employee for speaking out about unsafe working
conditions or reporting an infection or exposure to COVID-19 to an employer or
OSHA would constitute a violation of
Section 11(c) of the Act. In
29 CFR 1904.35(b) also prohibits
discrimination against an employee for reporting a work-related illness.

17.   Implementing protections from retaliation and setting up
an anonymous process for workers to voice concerns about COVID-19-related
Section 11(c) of the OSH Act
prohibits discharging or in any other way discriminating against an employee
for engaging in various occupational safety and health activities. For example,
employers may not discriminate against employees for raising a reasonable
concern about infection control related to COVID-19 to the employer, the
employer’s agent, other employees, a government agency, or to the public, such
as through print, online, social, or any other media; or against an employee
for voluntarily providing and wearing their own personal protective equipment,
such as a respirator, face shield, gloves, or surgical mask.

In addition to notifying
workers of their rights to a safe and healthful work environment, we ensure
that workers know whom to contact with questions or concerns about workplace
safety and health, and that there are prohibitions against retaliation for
raising workplace safety and health concerns or engaging in other protected
occupational safety and health activities (see
educating and training workers about COVID-19 policies and procedures, above); also consider using a hotline or other method
for workers to voice concerns anonymously.


19.   Not distinguishing between workers who are vaccinated
and those who are not:
Workers who are vaccinated
must continue to follow protective measures, such as wearing a face covering
and remaining physically distant, because at this time, there is no evidence
that COVID-19 vaccines prevent transmission of the virus from person-to-person.
CDC explains that experts need to
understand more about the protection that COVID-19 vaccines provide before
deciding to change recommendations on steps everyone should take to slow the
spread of the virus that causes COVID-19.


20.   Other
applicable OSHA Standards
: All of OSHA’s standards that apply to protecting
workers from infection remain in place. These standards include: requirements
for PPE (29 CFR 1910, Subpart I (e.g.,
1910.132 and 133)), respiratory protection
29 CFR 1910.134), sanitation (29 CFR 1910.141), protection from
bloodborne pathogens: (
29 CFR 1910.1030), and OSHA’s requirements
for employee access to medical and exposure records (
29 CFR 1910.1020). There is no OSHA standard
specific to COVID-19; however, employers still are required under the General
Duty Clause,
Section 5(a)(1) of the OSH Act, to provide
a safe and healthful workplace that is free from recognized hazards that can
cause serious physical harm or death.