; charset=UTF-8" /> COVID-19 Response « Onodi

COVID-19 Preparedness & Response Plan

  1. 1. General

The following COVID-19 preparedness & response plan has been established for  Onodi Tool & Engineering in accordance with MIOSHA Emergency Rules for Coronavirus disease 2019 (COVID-19).  The purpose of this plan is to minimize or eliminate employee exposure to SARS-CoV-2.

The Emergency Rules have general safeguards applicable for all workplaces and specific safeguards for certain industries. Gerry Giudici, Operating Executive has read these emergency rules carefully, developed the safeguards appropriate to Onodi Tool & Engineering based on its type of business or operation, and has incorporated those safeguards into this COVID-19 preparedness and response plan.

Onodi Tool & Engineering has designated one or more worksites supervisors to implement, monitor, and report on the COVID-19 control strategies developed in this plan. The worksite supervisor(s) is Jerry Busby, Plant Manager. The supervisor or designee will always remain on-site when employees are present on site. An on-site employee may be designated to perform the supervisory role.

The plan will be made readily available to our employees and their representatives. The plan will be made available via the company’s website and/or hard copy.

  1. 2. Exposure Determination

Onodi Tool & Engineering has evaluated routine and reasonably anticipated tasks and procedures for all employees to determine whether there is actual or reasonably anticipated employee exposure to SARS-CoV-2.  Gerry Giudici, Operating Executive was responsible for the exposure determination.

Onodi Tool & Engineering has determined that its employees’ jobs fall into only the lower exposure and medium exposure risk categories as defined by the OSHA Guidance on Preparing Workplaces for COVID-19:

Lower Exposure Risk Jobs. These jobs do not require contact with known or suspected cases of COVID-19 nor frequent close contact (for example, within six feet) with the general public. Workers in this category have minimal occupational contact with the public and other coworkers. Examples are small offices, small manufacturing plants (less than 10 employees).

Medium Exposure Risk Jobs. These jobs are those that require frequent or close contact (for example, within six feet) with people who may be infected with SARS-CoV-2, but who are not known or suspected COVID-19 patients. Examples are most jobs at manufacturing plants, and other high-population-density work environments.

Onodi Tool & Engineering has categorized its jobs as follows:

NOTE: Some jobs may have more than one type of exposure risk depending on the task or qualifying factors.

Job/Task Exposure Risk Determination
(Lower or Medium)
Qualifying Factors

(Ex. No Public Contact, Public Contact)

Administration Low No Public Contact
Plant Management Medium Employee Contact
Operators (Machinist & Assemblers) Medium Employee Contact
Shipping and Receiving Medium Employee Contact
Quality Control Medium Employee Contact
Truck Driver Medium Employee and Vendor Contact

  1. 3. Engineering Controls

Onodi Tool & Engineering has implemented feasible engineering controls to minimize or eliminate employee exposure to SARS-CoV-2. Engineering controls involve isolating employees from work-related hazards using ventilation and other engineered solutions. In workplaces where they are appropriate, these types of controls reduce exposure to hazards without relying on worker behavior and can be the most cost-effective solution to implement.

For lower exposure risk jobs, new engineering controls are not required. For medium exposure risk jobs, engineering controls can include:

■ Installing physical barriers (such as clear plastic sneeze guards) between coworkers or between workers and customers; 100% mask mandate; distribute face shields

Jerry Busby, General Manager will be responsible for seeing that the correct engineering controls are chosen, installed, maintained for effectiveness, and serviced when necessary.

The following engineering controls have been implemented:

Job/Task Engineering Control
Shipping and Receiving Reconfigure space for 6 feet working distance; reduce traffic in office area
Engineering Room Distance workstations; redesign work to reduce traffic in office
Operator (Assembly) Deburring Machines – disinfect tools

  1. 4. Administrative Controls

Administrative controls are workplace policies, procedures, and practices that minimize or eliminate employee exposure to the hazard. Gerry Giudici, EVP, will be responsible for seeing that the correct administrative controls are chosen, implemented, and maintained for effectiveness.

The following administrative controls have been established for Onodi Tool & Engineering:

Job/Task

Administrative Control

All employees Maintain at least six feet from everyone on the worksite.
Use ground markings, signs, and/or physical barriers to prompt employees to remain six feet from others.
Restrict face-to-face meetings. Communicate with others through phone, email, and teleconferencing,
Restrict vendors and customers on site – only critical few allowed
Minimize the sharing of tools, equipment, and items; institute cleaning protocol
Provide employees with non-medical grade face coverings (cloth face coverings).
Require employees to wear cloth face coverings in the facility
Institute self-assessment health and temperature checks at entrance building to avoid exposure
Require vendors/customers to wear cloth face coverings and provide self-assessment health and temperature checks
Ensure that sick leave policies are flexible and consistent with public health guidance, so employees do not go to work sick.
Require a healthcare provider’s note for employees who are sick with acute respiratory illness to validate their illness.

  1. 5. Hand Hygiene

Kevin Ksiazek, Contract Review Lead and Renee Gordon, Office Manager will be responsible for seeing that adequate handwashing facilities are available in the workplace and that regular handwashing is required. Frequency of such handwashing will be determined in part by factors such as when and how often the employees’ hands are potentially exposed to SARS-CoV-2. When handwashing facilities are not available, Onodi Tool & Engineering shall provide employees with antiseptic hand sanitizers or towelettes. Onodi Tool & Engineering will provide time for employees to wash hands frequently and to use hand sanitizer.

Onodi Tool & Engineering shall promote frequent and thorough hand washing, including by providing workers, customers, and worksite visitors with a place to wash their hands. If soap and running water are not immediately available, provide antiseptic hand sanitizers or alcohol-based hand towelettes containing at least 60 percent alcohol.

  1. 6. Disinfection of Environmental Surfaces

Onodi Tool & Engineering will increase facility cleaning and disinfection to limit exposure to COVID-19, especially on high-touch surfaces (for example, door handles), paying special attention to parts, products, and shared equipment (for example tools, machinery, vehicles). Onodi Tool & Engineering will make cleaning supplies available to employees at the worksite.

Kevin Ksiazek, Contract Review Lead will be responsible for seeing that environmental surfaces in the workplace are cleaned and disinfected. Frequency of such disinfection will be determined in part by factors such as when and how often the environmental surfaces are potentially exposed to SARS-CoV-2. When choosing cleaning chemicals, Onodi Tool & Engineering will consult information on Environmental Protection Agency (EPA)-approved disinfectant labels with claims against emerging viral pathogens. Products with EPA-approved emerging viral pathogens claims are expected to be effective against SARS-CoV-2 based on data for harder to kill viruses. The manufacturer’s instructions for use of all cleaning and disinfection products will be strictly adhered to.

The following is a list of environmental surfaces, methods used to disinfect, and the frequency of such disinfection.  A cleaning protocol similar to the one below, managed by Kevin Ksiazek for the plant and Renee Gordon for the office areas, has been established by Onodi Tool & Engineering; proper record-keeping has been established

Surface Method/Disinfectant Used Schedule/Frequency
Workstations/Surface Hospital grade disinfectant or fresh 10% chlorine bleach solution

Hospital grade disinfectant or fresh 10% chlorine bleach solution or similar disinfecting solutions

2 x daily beginning and end of shift
Office, desk, and Conference Tables Before and after each meeting; Office/workstations at the beginning and end of the day
Hand Tools/Machines Before and after each use
Moveable trays or containers Once a day; or if multiple users – before and after each usage
Shared computers, time clocks (electrical devices) Employees to use hand sanitizer/wash hands before and after usage
General Objects (handles, doors windows, faucet, sinks and bathroom) 2 x daily – morning and end of the day
Cafeteria (tables, chairs, surfaces, dispensers, vending machine buttons and slots) 2 x times daily after all breaks and meals
Forklifts/transport vehicles Before and after each use
Multiuser safety vests and other PPE After each shift
Floors and walls Daily

Onodi Tool & Engineering will perform enhanced cleaning and disinfection after persons confirmed to have COVID-19 have been in a work area. In the interim, that work area will be temporarily closed, and employees will be sent home or relocated. Kevin Ksiazek, Contract Review Lead will be responsible for seeing that this protocol is followed.

The impacted areas of the facility will be identified and cordoned off to limit access:

  • Cleaning personnel will use disposable nitrile gloves with long sleeves or use a Tyvek Suit
  • Identified areas used by the affected employees will be sanitized thoroughly using hospital grade bleach disinfectants
  • Affected areas will be spraying / wiping down work areas and common areas that were in direct contact with affected employee
  • Surfaces should be covered evenly with disinfectant and thoroughly wiped down
  • Disinfectants should sit wet on surfaces as directed to be effective
  • Machines, tooling, workstations, windows, and handles will be sprayed thoroughly, wiped down and allowed to dry
  1. 7. Personal Protective Equipment (PPE)

Onodi Tool & Engineering will provide employees with the types of personal protective equipment for protection from SARS-CoV-2 appropriate to the exposure risk associated with the job. The employer must follow current CDC and OSHA guidance for personal protective equipment.

All types of PPE are to be:

■ Selected based upon the hazard to the worker.

■ Properly fitted and periodically refitted as applicable.

■ Consistently and properly worn.

■ Regularly inspected, maintained, and replaced, as necessary.

■ Properly removed, cleaned, and stored or disposed of, as applicable, to avoid contamination of self, others, or the environment.

Onodi Tool & Engineering will provide non-medical grade face coverings (cloth face coverings) to employees (cloth face coverings are technically not considered PPE). Onodi Tool & Engineering will require employees to wear face coverings when they cannot consistently maintain six feet of separation from other individuals in the workplace. Onodi Tool & Engineering will provide  face shields when employees cannot consistently maintain three feet of separation from other individuals in the workplace.

The following type(s) of PPE have been selected for use:

Job/Task PPE
All employees Non-medical grade face coverings
Assemblers/Operators Full Face Shields when necessary
Inspectors, Managers, etc Face Masks &/or Face Shield if under 3 feet distance

  1. 8. Health Surveillance

Onodi Tool & Engineering. will conduct a daily entry self-screening protocol for all employees or contractors entering the workplace, including, at a minimum, a questionnaire covering symptoms and suspected or confirmed exposure to people with possible COVID-19, together with, if possible, a temperature screening. Gerry Giudici, EVP, will be responsible for ensuring that all required health surveillance provisions are performed.

As workers enter the place of employment at the start of each work shift, Onodi Tool & Engineering will have employees self-screen for COVID-19. Onodi Tool & Engineering will have employees complete a questionnaire covering the signs and symptoms of COVID-19 and their exposure to people with suspected or confirmed COVID-19. When obtainable, a no-touch thermometer will be used for temperature screening of employees. Onodi Tool & Engineering will similarly screen contractors, suppliers, and any other individuals entering the worksite.

Employees have been directed to promptly report any signs and symptoms of COVID-19 to Sarah Pallas, HR Manager before and during the work shift. Onodi Tool & Engineering has provided employees with instructions for how to make such a report to the employer.

The specific instructions for employee reporting signs and symptoms of COVID-19 are as follows:

Before Work – At Home

  • Employees are encouraged to fill out self-assessment daily 2 hours before work
  • If they answer yes to any question – they are instructed to stay home and contact HR

Before Work – At Site Entrance

Send Employee Home

  • Employee has answered “yes” on self-assessment OR
  • Has Covid-19 symptoms or temperature indicates fever
  • Assessor completes Employee Assessment Form, indicate temperature or symptoms
  • Assessor does not clear for work and ask employee to return home and call HR for further instruction
  • Assessor notifies and provides form to HR to take further action and be ready for call from employee

Clear for Work

  • Employee has answered “no” on self-assessment OR
  • Has a temperature with no symptoms – Ask employee to return to entrance in 5 minutes for recheck
  • If no temperature, assessor marks completes Employee Assessment Form, indicating new temperature and allows employee to enter and start shift

Onodi Tool & Engineering will physically isolate any employees with known or suspected COVID-19 from the remainder of the workforce, using measures such as, but are not limited to:

■ Not allowing known or suspected cases to report to or remain at their work location.

■ Sending known or suspected cases home where they are self-isolating during their illness.

■ Assigning known or suspected cases to work alone at home if feasible where they are self-isolating during their illness.

Onodi Tool & Engineering will not discharge, discipline, or otherwise retaliate against employees who stay at home or who leave work when they are at particular risk of infecting others with COVID-19.

When an employee is identified with a confirmed case of COVID-19, Sarah Pallas, HR Manager will notify  the local public health department immediately, and any co-workers, contractors, or suppliers who may have come into contact with the person who is the confirmed case of COVID-19, within 24 hours. When notifying coworkers, contractors, and suppliers, Onodi Tool & Engineering will not reveal the name or identity of the confirmed case.

Onodi Tool & Engineering will allow employees with a confirmed or suspected case of COVID-19 to return to the workplace only after they are no longer infectious according to the latest guidelines from the CDC.

  1. 9. Training

Sarah Pallas, HR Manager shall coordinate SARS-CoV-2 training and ensure compliance with all training requirements.

Onodi Tool & Engineering will train workers on, at a minimum:

■ Workplace infection-control practices.

■ The proper use of personal protective equipment.

■ Steps the employee must take to notify the business or operation of any symptoms of COVID-19 or a suspected or confirmed diagnosis of COVID-19.

■ How to report issues or concerns.

Sarah Pallas, HR Manager shall create a record of the training. Records should include the name of the employee(s) trained and the date of the training.

10. Recordkeeping

Onodi Tool & Engineering will maintain records of the following requirements:

■ Training.  The employer shall maintain a record of all COVID-19 employee training.

■ Screening protocols. The employer shall maintain a record of screening for each employee or visitor entering the workplace.

■ When an employee is identified with a confirmed case of COVID-19, record when the local public health department was notified; as well as any co-workers, contractors, or suppliers who may have come into contact with the person who was the confirmed case of COVID-19.

Sarah Pallas, HR Manager, will ensure that the records are kept.

(MIOSHA/CET-5700 — Revised 10/23/20) REVISED BY ONODI – 11/15/2020