Safety Procedures

A Message to Our Customers

COVID-19 Exposure Prevention, Preparedness, and Response Plan for Construction

Mechanical Heating & Cooling takes the health and safety of our employees very seriously. With the spread of the coronavirus or “COVID-19,” a respiratory disease caused by the SARS-CoV-2 virus, we all must remain vigilant in mitigating the outbreak. This is particularly true for the construction industry. In order to be safe and maintain operations, we have developed this COVID-19 Exposure Prevention, Preparedness, and Response Plan to be implemented throughout the company and at all of our jobsites. We have also identified a team of employees to monitor available U.S. Center for Disease Control and Prevention (“CDC”) and Occupational Safety and Health Administration (“OSHA”) guidance on the virus.

This plan is based on currently available information from the CDC and OSHA, and is subject to change based on further information provided by the CDC, OSHA, and other public officials. The company may also amend this plan based on operational needs.

I. Responsibilities of Managers and Supervisors

All managers and supervisors must be familiar with this plan and be ready to answer questions from employees. Managers and supervisors must set a good example by following this plan at all times. This involves practicing good personal hygiene and jobsite safety practices to prevent the spread of the virus. Managers and supervisors must encourage this same behavior from all employees.

II. Responsibilities of Employees and Trade Contractors

We are asking every one of our employees and trade contractors to help with our prevention efforts while at work. In order to minimize the spread of COVID-19 at our jobsites, we all must play our part. As set forth below, the company has instituted various housekeeping, social distancing, and other best practices at our jobsites. All employees and trades must follow these. In addition, employees and trades are expected to report to their managers or supervisors if they are experiencing signs or symptoms of COVID-19, as described below. If you have a specific question about this plan or COVID-19, please ask your manager or supervisor. If they cannot answer the question, please contact Shawn Bafile.

OSHA and the CDC have provided the following control and preventative guidance to all workers, regardless of exposure risk:

  • All employees and trade contractors must wear the following PPE at all times:
    • Mask covering mouth and nose
    • Eye protection
    • Gloves
  • Frequently wash your hands with soap and water for at least 20 seconds. When soap and running water are unavailable, use an alcohol-based hand rub with at least 60% alcohol.
  • Avoid touching your eyes, nose, or mouth with unwashed hands.
  • Follow appropriate respiratory etiquette, which includes covering for coughs and sneezes.
  • Avoid close contact with people who are sick.

In addition, employees must familiarize themselves with the symptoms of COVID-19:

  • Coughing
  • Fever
  • Shortness fo breath, difficulty breathing
  • Early symptoms such as chills, body aches, sore throat, headache, diarrhea, nausea/vomiting, and runny nose

If you develop a fever and symptoms of respiratory illness, such as cough or shortness of breath, DO NOT GO TO WORK and call your healthcare provider right away. Likewise, if you come into close contact with someone showing these symptoms, call your healthcare provider right away.

If you develop symptoms or are around someone showing symptoms, you are required to report it to Courtney Wensley.

III. Jobsite and Office Protective Measures

Mechanical Heating & Cooling has instituted the following protective measures at all jobsites and offices.

A.General Safety Policies and Rules

  • Any employee/contractor/visitor showing symptoms of COVID-19 will be asked to leave the jobsite or office and return home.
  • Safety meetings will be by telephone, if possible. If safety meetings are conducted in-person, attendance will be collected verbally and the foreman/superintendent will sign-in each attendee. Attendance will not be tracked through passed-around sign-in sheets or mobile devices. During any in-person safety meetings, avoid gathering in groups of more than 10 people and participants must remain at least six (6) feet apart.
  • Employees must avoid physical contact with others and direct employees/contractors/visitors to increase personal space to at least six (6) feet, where possible.
  • Employees must avoid physical contact with others and direct employees/contractors/visitors to increase personal space to at least six (6) feet, where possible.
  • All in-person meetings will be limited. To the extent possible, meetings will be conducted by telephone. Telephone, text and video conferences are encouraged whenever possible. Mechanical Heating & Cooling employees and trade contractors should use text messages to contact the materials truck driver and/or superintendents instead of talking face to face while on the jobsite.
  • When materials are being delivered by Mechanical Heating & Cooling employees, the material will be left on the jobsite perimeter for on-site employees to bring into the house whenever possible.
  • Mechanical Heating & Cooling understands that due to the nature of our work, access to running water for hand washing may be impractical. In these situations, the company will provide, if available, alcohol-based hand sanitizers and/or wipes.
  • Employees should limit the use of coworkers’ tools and equipment. To the extent tools must be shared, the company will provide alcohol-based wipes to clean tools before and after use. When cleaning tools and equipment, consult manufacturing recommendations for proper cleaning techniques and restrictions.
  • Employees are encouraged to limit the need for N95 respirator use, by using engineering and work practice controls to minimize dust. Such controls include the use of water delivery and dust collection systems, as well as limiting exposure time.
  • Employees are encouraged to minimize ride-sharing. While in vehicle, employees must ensure adequate ventilation.
  • If practical, employees should use/drive the same truck or piece of equipment every shift.
  • In lieu of using a common source of drinking water, such as a cooler, employees should use individual water bottles.

B.Workers entering Occupied Building and Homes

  • When employees perform construction and maintenance activities within occupied homes, office buildings, and other establishments, these work locations present unique hazards with regards to COVID-19 exposures. All such workers should evaluate the specific hazards when determining best practices related to COVID-19.
  • During this work, employees must sanitize the work areas upon arrival, throughout the workday, and immediately before departure. The company will provide alcohol-based sanitizer for this purpose.
  • Employees should ask other occupants to keep a personal distance of six (6) feet at a minimum. Workers should wash or sanitize hands immediately before starting and after completing the work.

C.Jobsite and Office Visitors

  • The number of visitors to the jobsite and office will be limited to only those neccessary for the work.
  • Mechanical Heating & Cooling employees on site are required to screen visitors upon arriving on the jobsite or office. If the visitor answers “yes” to any of the following questions, he/she should not be permitted to access the jobsite or office:
    • Have you been confirmed positive for COVID-19?
    • Are you currently experiencing, or recently experienced, any acute respiratory illness symptoms such as fever, cough, or shortness of breath?
    • Have you been in close contact with any persons who has been confirmed positive for COVID-19?
    • Have you been in close contact with any persons who have traveled and are also exhibiting acute respiratory illness symptoms?
  • Site deliveries will be permitted but should be properly coordinated in line with the employer’s minimal contact and cleaning protocols. Delivery personnel should remain in their vehicles it at all possible.

C.Personal Protective Equipment and Work Practice Controls

  • In addition to regular PPE for workers engaged in various tasks (fall protection, hard hats, hearing protection), employers will also provide:
    • Gloves: Gloves are to be worn at all times while on site. The type of glove worn should be appropriate to the task. If gloves are not typically required for the task, then any type of glove is acceptable, including latex gloves. Employees should not share gloves.
    • Eye protection: Eye protection is to be worn at all times while on site.
    • NOTE: The CDC is currently not recommending that healthy people wear N95 respirators to prevent the spread of COVID-19. Employees should wear N95 respirators if required by the work and if available.
  • Due to the current shortage of N95 respirators, reusable masks will be provided to each Mechanical Heating & Cooling employee. The following Work Practice Controls should be followed:
    • Keep dust down by using engineering and work practice controls, specifically through the use of water delivery and dust collection systems.
    • Limit exposure time to the extent practicable.
    • Isolate workers in dusty operations by using a containment structure or distance to limit dust exposure to those employees who are conducting the tasks, thereby protecting nonessential workers and bystanders.
  • Institute a rigorous housekeeping program to reduce dust levels on the jobsite.
  • Run an air scrubber at all possible times.

IV. Jobsite Cleaning and Disinfecting

Mechanical Heating & Cooling has instituted regular housekeeping practices, which includes cleaning and disinfecting frequently used tools and equipment, and other elements of the work environment, where possible. Employees should regularly do the same in their assigned work areas.

  • Jobsite trailers and break/lunchroom areas will be cleaned at least once per day. Employees performing cleaning will be issued proper personal protective equipment (“PPE”).
  • Any trash collected from the jobsite must be changed frequently by someone wearing nitrile, latex, or vinyl gloves. Trash cans will be placed on all jobsites and will be emptied frequently.
  • Any portable jobsite toilets will be cleaned by the leasing company at least once per week and disinfected on the inside. The company will ensure that hand sanitizer dispensers are always filled. Frequently touched items (i.e. door pulls and toilet seats) are to be disinfected after each use by employees and trade contractors.
  • Vehicles and equipment/tools should be cleaned at least once per day and before change in operator or rider.
  • All work areas are to be swept and vacuumed at the end of every day. Jobsites are not to be left prior to clean up.
  • If an employee has tested positive for COVID-19, OSHA has indicated that there is typically no need to perform special cleaning or decontamination of work environments, unless those environments are visibly contaminated with blood or other bodily fluids. Notwithstanding this, the company will clean those areas of the jobsite that a confirmed-positive individual may have come into contact with before employees can access that work space again.
  • The company will ensure that any disinfection shall be conducted using one of the following:
    • Common EPA-registered household disinfectant;
    • Alcohol solution with at least 60% alcohol; or
    • Diluted household bleach solutions (these can be used if appropriate for the surface)

V. Jobsite Exposure Situations

Employee Exhibiting COVID-19 Symptoms

If an employee exhibits COVID-19 symptoms, the employee must remain at home until he or she is symptom free for 72 hours (3 full days) without the use of fever-reducing or other symptom-altering medicines (e.g., cough suppressants). The company will similarly require an employee that reports to work with symptoms to return home until they are symptom free for 72 hour (3 full days). To the extent practical, employees are required to obtain a doctor’s note clearing them to return to work.

Employee Tests Positive for COVID-19

An employee that tests positive for COVID-19 will be directed to self-quarantine away from work. Employees that test positive and are symptom free may return to work when at least seven (7) days have passed since the date of his or her first positive test, and have not had a subsequent illness. Employees that test positive and are directed to care for themselves at home may return to work when: (1) at least 72 hours (3 full days) have passed since recovery; and (2) at least seven (7) days have passed since symptoms first appeared. Employees that test positive and have been hospitalized may return to work when directed to do so by their medical care provider. The company will require an employee to provide documentation clearing their return to work.

Employee Has Close Contact with a Tested Positive COVID-19 Individual

Employees that have come into close contact with a confirmed-positive COVID-19 individual (coworker or otherwise), will be directed to self-quarantine for 14 days from the last date of close contact with the carrier. Close contact is defined as six (6) feet for a prolonged period of time.

If the company learns that an employee has tested positive, the company will conduct an investigation into coworkers that may have had close contact with the confirmed-positive employee in the prior 14 days and direct those individuals that have had close contact with the confirmed-positive employee to self-quarantine for 14 days from the last date of close contact with the carrier. If an employee learns that he or she has come into close contact with a confirmed-positive individual outside of the workplace, he/she must alert a manager or supervisor of the close contact and also self-quarantine for 14 days from the last date of close contact with the carrier.

VI. OSHA Recordkeeping

If a confirmed case of COVID-19 is reported, the company will determine if it meets the criteria for recordability and reportability under OSHA’s recordkeeping rule. OSHA requires construction employers to record work-related injuries and illnesses that meet certain severity criteria on the OSHA 300 Log, as well as complete the OSHA Form 301 (or equivalent) upon the occurrence of these injuries. For purposes of COVID-19, OSHA also requires employers to report to OSHA any work-related illness that (1) results in a fatality, or (2) results in the in-patient hospitalization of one or more employee. “In-patient” hospitalization is defined as a formal admission to the in-patient service of a hospital or clinic for care or treatment.

OSHA has made a determination that COVID-19 should not be excluded from coverage of the rule – like the common cold or the seasonal flu – and, thus, OSHA is considering it an “illness.” However, OSHA has stated that only confirmed cases of COVID-19 should be considered an illness under the rule. Thus, if an employee simply comes to work with symptoms consistent with COVID-19 (but not a confirmed diagnosis), the recordability analysis would not necessarily be triggered at that time.

If an employee has a confirmed case of COVID-19, the company will conduct an assessment of any workplace exposures to determine if the case is work-related. Work-relatedness is presumed for illnesses that result from events or exposures in the work environment, unless it meets certain exceptions. One of those exceptions is that the illness involves signs or symptoms that surface at work but result solely from a non-work-related event or exposure that occurs outside of the work environment. Thus, if an employee develops COVID-19 solely from an exposure outside of the work environment, it would not be work-related, and thus not recordable.

The company’s assessment will consider the work environment itself, the type of work performed, risk of person-to-person transmission given the work environment, and other factors such as community spread. Further, if an employee has a confirmed case of COVID-19 that is considered work-related, the company will report the case to OSHA if it results in a fatality within 30 days or an in-patient hospitalization within 24-hours of the exposure incident occurring.

VII. Confidentiality/Privacy

Except for circumstances in which the company 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. When it is required, the number of persons who will be informed of an employee’s condition will be kept at the minimum needed not only to comply with legally-required reporting, but also to assure proper care of the employee and to detect situations where the potential for transmission may increase. A sample notice to employees is attached to this plan. The company reserves the right to inform other employees that a coworker (without disclosing the person’s name) has been diagnosed with COVID-19 if the other employees might have been exposed to the disease so the employees may take measures to protect their own health.

VIII. General Questions

Given the fast-developing nature of the COVID-19 outbreak, Mechanical Heating & Cooling may modify this plan on a case by case basis. If you have any questions concerning this plan, please contact Shawn Bafile.


This plan must be followed by all employees and trade contractors. The discipline for not following this plan is as follows:

  • 1st Offense Removal from jobsite of office and one week off unpaid
  • 2nd Offense Removal from jobsite or office and two weeks off unpaid
  • 3rd Offense Termination

Any person who arrives at a Mechanical Heating & Cooling jobsite or office and knowingly has COVID-19 may be subject to immediate termination. If you are not feeling well, notify the appropriate people and stay home.