CA COVID-19 Prevention Program (CPP) for KNA Solutions LLC.
This CPP is designed to control exposures to the SARS-CoV-2 virus that may occur in our workplace.
Authority and Responsibility
Amelia Christy, COO, has overall authority and responsibility for coordinating the provisions of this CPP in collaboration with our California clients COVID-19 Prevention Program. In addition, Human Resources, all managers, supervisors and client representatives are responsible for implementing and maintaining the CPP in their assigned work areas and in coordination with KNA clients, ensuring employees receive answers to questions about the program in a language they understand.
All employees are responsible for using safe work practices while on KNA property or client property, following all KNA/Client directives, policies and procedures, and assisting in maintaining a safe work environment as defined by KNA and/or the KNA client.
Identification and Evaluation of COVID-19 Hazards
KNA will work in collaboration with our clients to identify and evaluate hazards in the workplace.
Ensure the client has conducted workplace-specific evaluations.
Ensure the client evaluates employees’ potential workplace exposures to KNA associates.
Review applicable orders along with general and industry-specific guidance from the State of California, Cal/OSHA, and the local health department related to COVID-19 hazards and prevention.
Collaborate with clients to evaluate existing COVID-19 prevention controls and potential needs for additional controls.
Collaborate with clients to conduct periodic inspections as needed to identify unhealthy conditions, work practices, and work procedures related to COVID-19 and to ensure compliance with our COVID-19 policies and procedures.
Employees and their authorized employees’ representatives are encouraged to participate in the identification and evaluation of COVID-19 hazards by reaching out to their KNA representative and identifying potential hazards and/or suggestions for improvements.
We screen our employees by allowing them to self-screen based on CDC guidelines. Where clients have mandatory screening practices, client policy will be followed.
Correction of COVID-19 Hazards
Unsafe or unhealthy work conditions, practices or procedures will be documented with our client and corrected in a timely manner based on the severity of the hazards as defined by client policy.
Control of COVID-19 Hazards
Where possible, KNA will coordinate with client sites to ensure at least six feet of physical distancing at all times. KNA will do this by ensuring our client workplaces have reasonable best practices in place help ensure minimal physical interactions.
Individuals will be kept as far apart as possible when there are situations where six feet of physical distancing cannot be achieved.
KNA clients will provide clean, undamaged face coverings and ensure they are properly worn by employees over the nose and mouth when indoors, and when outdoors and less than six feet away from another person, including non-employees, and where required by orders from the California Department of Public Health (CDPH) or local health department. If you are not provided a face covering by a client that typically provides one or are in need of a new face covering, please request through your client supervisor. If the client does not provide face coverings, you will be responsible for ensuring you have a face covering before entering the client facility. If there are issues, contact your KNA client representative and or KNA Human Resources.
The following are exceptions to the use of face coverings. If client exceptions differ, client exceptions will take precedence:
When an employee is alone in a room.
While eating and drinking at the workplace, provided employees are at least six feet apart and outside air supply to the area, if indoors, has been maximized to the extent possible.
Employees wearing respiratory protection in accordance with CCR Title 8 section 5144 or other safety orders.
Employees who cannot wear face coverings due to a medical or mental health condition or disability, or who are hearing-impaired or communicating with a hearing-impaired person. Alternatives will be considered on a case-by-case basis.
Specific tasks that cannot feasibly be performed with a face covering, where employees will be kept at least six feet apart.
Any employee not wearing a face covering, face shield with a drape or other effective alternative, or respiratory protection, for any reason, shall be at least six feet apart from all other persons.
KNA will collaborate with clients to implemented measures for situations where we cannot maintain at least six feet between individuals.
To the extent feasible, clients will maximize the quantity of outside air for buildings with mechanical or natural ventilation systems.
Cleaning and disinfecting
KNA will collaborate with clients to ensure cleaning and disinfection measures are in place for frequently touched surfaces.
Should we have a COVID-19 case in a client workplace, KNA will work with the client to notify employees potentially exposed as well as determine necessary sanitary steps to be taken to ensure safety.
Shared tools, equipment, and personal protective equipment (PPE)
PPE must not be shared, e.g., gloves, goggles and face shields.
Items that employees come in regular physical contact with, such as phones, headsets, desks, keyboards, writing materials, instruments and tools must also not be shared, to the extent feasible. Where there must be sharing, the KNA will collaborate with the client will ensure items will be disinfected or disinfectant is available for use between uses.
Sharing of vehicles will be minimized to the extent feasible, and high-touch points (for example, steering wheel, door handles, seatbelt buckles, armrests, shifter, etc.) will be disinfected between users.
In order to implement effective hand sanitizing procedures, we:
Encouraging and allowing time for employee hand washing.
Clients providing employees with an effective hand sanitizer.
Encouraging employees to wash their hands for at least 20 seconds each time.
Personal protective equipment (PPE) used to control employees’ exposure to COVID-19
We collaborate/evaluate the need for PPE (such as gloves, goggles, and face shields) as required by CCR Title 8, section 3380, and provide such PPE as needed.
When it comes to respiratory protection, we evaluate the need in accordance with CCR Title 8 section 5144 when the physical distancing requirements are not feasible or maintained.
We collaborate with our clients to ensure provide and ensure eye protection and respiratory protection is provided in accordance with section 5144 when employees are exposed to procedures that may aerosolize potentially infectious material such as saliva or respiratory tract fluids.
Investigating and Responding to COVID-19 Cases
This will be accomplished by contacting all employees and potential employees who have been or may have been exposed using the KNA COVID questionnaire form. KNA will also follow this same process with individuals expressing symptoms that could potentially be related to COVID I9.
Employees who had potential COVID-19 exposure in our workplace will be:
Offered COVID-19 testing at no cost during their working hours based on client policy.
System for Communicating
Our goal is to ensure that we have effective two-way communication with our employees, in a form they can readily understand, and that it includes the following information:
How employees should report COVID-19 symptoms and possible hazards to, and how, this is done by verbal and electronic communication. Information is also posted on KNA’s website.
That employees can report symptoms and hazards without fear of retaliation.
Our procedures or policies for accommodating employees with medical or other conditions that put them at increased risk of severe COVID-19 illness.
Where testing is not required, how employees can access COVID-19 testing.
In the event KNA or our client is required to provide testing because of a workplace exposure or outbreak, we will communicate the plan for providing testing and inform affected employees of the reason for the testing and the possible consequences of a positive test.
Information about COVID-19 hazards employees (including other employers and individuals in contact with our workplace) may be exposed to, what is being done to control those hazards, and our COVID-19 policies and procedures.
Training and Instruction
We will provide effective training and instruction that includes:
KNA COVID-19 policies and procedures to protect employees from COVID-19 hazards.
Information regarding COVID-19-related benefits to which the employee may be entitled under applicable federal, state, or local laws.
The fact that:
COVID-19 is an infectious disease that can be spread through the air.
COVID-19 may be transmitted when a person touches a contaminated object and then touches their eyes, nose, or mouth.
An infectious person may have no symptoms.
Methods of physical distancing of at least six feet and the importance of combining physical distancing with the wearing of face coverings.
The fact that particles containing the virus can travel more than six feet, especially indoors, so physical distancing must be combined with other controls, including face coverings and hand hygiene, to be effective.
The importance of frequent hand washing with soap and water for at least 20 seconds and using hand sanitizer when employees do not have immediate access to a sink or hand washing facility, and that hand sanitizer does not work if the hands are soiled.
Proper use of face coverings and the fact that face coverings are not respiratory protective equipment - face coverings are intended to primarily protect other individuals from the wearer of the face covering.
COVID-19 symptoms, and the importance of obtaining a COVID-19 test and not coming to work if the employee has COVID-19 symptoms.
COVID-19 Training will be documented internally.
Exclusion of COVID-19 Cases
Where a client has a COVID-19 case, we will coordinate with the client to limit transmission by:
Ensuring that COVID-19 cases are excluded from the workplace until our return-to-work requirements are met.
Excluding employees with COVID-19 exposure from the workplace for 14 days after the last known COVID-19 exposure to a COVID-19 case.
Providing employees at the time of exclusion with information on available benefits provided by client or through Federal/State laws.
Reporting, Record keeping, and Access
It is our policy to:
Assist our client in the reporting of information about COVID-19 cases to the local health department whenever required by law, and provide any related information requested by the local health department.
Report immediately to Cal/OSHA any COVID-19-related serious illnesses or death, as defined under CCR Title 8 section 330(h), of an employee occurring in our place of employment or in connection with any employment.
Maintain records of the steps taken to implement our written COVID-19 Prevention Program in accordance with CCR Title 8 section 3203(b).
Make our written COVID-19 Prevention Program available at the workplace to employees, authorized employee representatives, and to representatives of Cal/OSHA immediately upon request.
Complete a KNA COVID questionnaire on each associate who has tested positive, has come into contact or has symptoms associated with COVID-19. These forms are saved in the employee’s medical information file.
Use the KNA HR COVID Tracker to keep record of daily follow up/contact activities with client and employees. Access is limited to Human Resources.
KNA follows CDC guidance for returning employees to work. KNA also will work with the client to ensure additional client requirements for returning to work are followed.
Amelia Christy, COO