Procedures for Inspections and Fieldwork During COVID–19
August 3, 2020 Version 2
COVID-19 General Information
The CDC is responding to a pandemic of respiratory disease spreading from person-to-person caused by a novel (new) coronavirus. The disease has been named "coronavirus disease 2019" (abbreviated "COVID-19"). This situation poses a serious public health risk. The federal government is working closely with state, local, tribal, and territorial partners, as well as public health partners, to respond to this situation. COVID-19 can cause mild to severe illness. DEC recommends that all staff familiarize themselves with COVID-19 symptoms and other concerns related to the disease. Detailed information, including how to protect yourself and others, is located on the CDC website and the DHSS website.
In response to the Global COVID-19 Pandemic, countries, companies, communities, and individuals have been called upon worldwide to make every effort to minimize to the greatest extent possible the risks associated with the transmission and perpetuation of the coronavirus. This document provides guidance to help mitigate the transmission of the coronavirus and provide safe and healthy working environments.
This document is designed to give clear, concise, consistent direction to DEC employees conducting inspections and fieldwork throughout the State of Alaska. Due to the fluidity of the events surrounding this pandemic, this document is considered a "living document" and will be updated as conditions change, and as relevant information is disseminated by local, state, and federal agencies.
This document outlines the minimum steps for DEC staff to follow when resuming inspections and fieldwork. Inspections and other field activity will continue upon approval by the supervisor, and program or division director. This document is effective until superseded or revoked. This document will provide general guidance to employees but further detailed, program, and/or site-specific plans may be developed by programs for those conducting fieldwork, provided those plans are not in conflict with this one. Inspectors will coordinate with facility operators and determine whether the facility has a protective plan, and should consider integrating requirements from the facility's plan that are more restrictive than this plan. Contract staff will follow their own internal procedures and work with DEC if there is a conflict in protocols before conducting inspections. Exceptions to these procedures will be determined on a case-by-case basis and may require director approval.
Roles and Responsibilities
DEC is committed to ensuring the health, safety, and protection of personnel continuing to work through this pandemic, to their families, and to the communities in which they live and work. The following measures have been taken and will continue throughout the duration of this pandemic:
- Commissioner's office
- The Commissioner's office will continue to monitor the COVID-19 Pandemic situation and changing dynamics. The Commissioner's office will remain in contact with all applicable local, state, and federal leaders through the DEC Disaster Response Coordinator and Unified Command. They will ensure that any new directives given by governing bodies are immediately communicated to and implemented by the Department.
- Division directors
- Division directors will ensure that all applicable COVID-19 directives from the Commissioner's Office are immediately implemented and that all activities are conducted to ensure that coronavirus transmission risks are as low as reasonably achievable.
- Program managers
- Program managers are responsible for ensuring that the procedures contained in this document are available to and are followed by all personnel in the field.
- Field staff
- Inspectors and other field staff are responsible for following the procedures contained in this document; for reporting to their immediate supervisor any unsafe or unsanitary conditions; and for immediately self-reporting and self-quarantining if they have any illness symptoms. Field personnel are responsible for helping to maintain safe, clean, and healthy work sites.
Planning for Inspections and Fieldwork
- Coordinate with other divisions/programs. Check the rural travel calendar and coordinate with others that plan on traveling to the same area. Determine whether one traveler can accomplish the goals of both divisions/programs.
- Prioritize critical inspections/fieldwork. Consider whether your goals can be accomplished remotely (ex., photo analysis, records, and other document audits, etc.). Review high-priority and critical inspections with your supervisor, and they will assist in prioritizing facilities in conjunction with program managers as appropriate.
- Prioritize day trips. Inspections that require overnight travel will require approval from division director, or program manager if the director has formally delegated travel approval authority.
- Prioritize inspections/fieldwork that need only one DEC representative. If more than one inspector/field staff is necessary, limit participants to essential staff. If traveling by road, travel in separate vehicles, if possible. Program managers may allow two staff to travel together under certain circumstances and agreement of the travelers. However, no more than two people to a vehicle and occupants will wear cloth facemasks. Inspectors will follow sanitizing and disinfecting guidance provided in the Vehicle and Sanitizing/Housekeeping sections of this document.
- Prioritize outdoor facilities with a low likelihood of close contact (e.g., wellheads, underground storage tanks, etc.). If possible, only one person at a time should enter small or cramped areas. If an inspection is necessary at a facility where there is a high likelihood of close contact (closer than 6 feet), program manager approval is necessary.
- Identify worksites or operations in more restrictive locations (i.e. rural communities or private buildings/facilities), and follow local public health guidelines/mandates, unless otherwise directed by DHSS or the Office of the Governor.
Note that staff that are either in a vulnerable category for COVID-19, or who have family members in a vulnerable category for COVID-19, and that have concerns about conducting inspections should consult human resources (HR). See the CDC website for more information on people who are at higher risk for severe illness.
Program managers and inspectors will take steps to minimize impacts to communities and limit interactions with others to the extent possible throughout the duration of the inspection. Prior to mobilization, inspectors will ensure that every practical effort has been made to provide for the following:
- Personnel are healthy and ready for work.
- All necessary housing and transportation have been arranged to minimize exposure or interaction between staff and public.
- Ensure availability of food at the location or a plan to bring food to ensure ability to practice heightened social distancing when possible.
- Inspection materials and supplies have been obtained or located.
- Acquisition of all required PPE, First-Aid response kits, and consumables.
Inspectors will not mobilize to remote locations until all supplies necessary to safely conduct an inspection or site visit have been located, and adequate housing and transportation to provide safe working conditions have been obtained.
Use the factors in Table 1 to determine if an inspection can be performed while minimizing the risk of COVID-19 transmission.
Table 1. Factors to Consider Before Conducting Inspections
|1||Desk Audit||Can the goal(s) of the inspection/fieldwork be accomplished remotely by a desk audit (document/record review, photo analysis, etc.) or other means?||Delay the in-person inspection/fieldwork and conduct work remotely.|
|2||Facility Operation||Is the facility operational and to what extent?||Delay the inspection if closed and determine when the facility may reopen.|
|3||Location of Facility||Is the facility located in a community with travel restrictions that doesn't allow outside visitors?||If so, delay the inspection and coordinate with the facility and/or local community to determine when openings are expected.|
|4||Access to Facility||Is the facility or their corporate office limiting access from outside entities or sequestering critical personnel?||If so, delay inspection and determine when the facility expects to allow access.|
|5||Access to Areas||Are all necessary areas for the inspection accessible?||If not, delay the inspection or determine if a phased inspection is feasible.|
|6||Visitor Requirements||Does the facility have requirements for visitors?||Ensure facility requirements can be met. If you are asked to sign a release of liability or requirements cannot be met, contact your supervisor.|
Once it is determined that an inspection can be performed, the following planning steps should be taken:
- Contact the facility and explain the inspection process and safety precautions outlined in this document.
- Review and prepare paperwork before the inspection and obtain electronic documents or records from the facility, if possible. If the facility has video or teleconferencing capabilities, consider performing pre- and post-inspection discussions remotely.
- If traveling to a remote community, coordinate with community leaders, which may include tribal, and governing entities in remote locations prior to mobilization. Discuss COVID-19 safety protocols and site-specific plans, and any other local/community considerations.
- Consider logistics associated with travel to inspection sites (e.g., fuel stops, restrooms, etc.) and choose locations where physical distancing can be maintained. Ask whether facility staff have been exposed to or show symptoms associated with COVID-19 and if so, cancel the inspection. Symptoms may appear 2-14 days after exposure to the virus. People with these symptoms may have COVID-19:
- Provide a follow-up email that includes contact information and a statement requesting that the facility contact you if any COVID-19-related issues arise or if conditions change.
Transportation / Vehicles
Many remote locations require multiple transportation methods, both public and private (follow local public health guidelines/mandates). The following precautions will be taken to help minimize COVID-19 transmission risks during mobilization and transportation:
- Inspectors/field staff will wear a cloth face mask and bring with them gloves, EPA approved disinfecting cleaner, and hand sanitizer.
- Modes of transportation must be approved by the inspector's supervisor.
- All transportation vehicles, including marine vessels and aircraft will be cleaned and sanitized prior to each transport in accordance to CDC guidelines. Inspectors should request information about sanitary protocols for commercial transportation before departing.
- Transportation methods should allow reasonable space between personnel and overcrowding of transportation methods is prohibited.
- All state vehicles, vessels, and aircraft will contain PPE and first-aid kits to assist if an employee becomes ill during transit.
- Road vehicles should be limited to one employee without program manager's approval. No more than two employees may travel in a single road vehicle and both will wear cloth face masks. Employees may use their personal vehicle with supervisor approval and in accordance with the Alaska Administrative Manual (AAM 60.TRAVEL); the state is not responsible for any damages to personal vehicles.
- If two employees are traveling together, employees will remove all gear from state vehicles and disinfect it daily, as practicable (e.g. backpacks and shareable equipment).
- Employees are encouraged to store most gear in the trunk or truck bed, if possible, to reduce cleaning needed in the cab.
- Employees will avoid sharing gear and equipment to the extent possible. Disinfect field equipment between users if sharing equipment is necessary.
- Employees that "check out" a state vehicle for use must disinfect it before and after use, including commonly touched areas such as the steering wheel, door handles, dash, and center console. If gear was stored inside the main body of the vehicle, the gear storage area will be treated as a commonly touched area and disinfected as practicable.
- Staff will make no unnecessary stops, will travel only to sites, and will refuel the vehicle using a credit card at the pump to minimize public contact. Hand sanitizer should be used after refueling.
Conduct the Inspection/Fieldwork and Follow-up
Conduct field activities as planned. Any deviation must be done in coordination with your supervisor.
- Personnel must pass the self-assessment health screening prior to mobilization. Take your temperature and use CDC's self-checker. Personnel who have a fever and/or do not pass the screening criteria will not mobilize to the jobsite and should contact their health care provider.
- If you do not feel well, have a fever, or have been exposed to COVID-19, postpone the inspection and contact your supervisor and HR.
- The day-of inspection, ask whether facility staff have been exposed to or show symptoms associated with COVID-19 and if so, cancel the inspection. (See symptoms list under Planning for Inspections and Fieldwork section of this document).
- If at any time during the inspection you are uncomfortable or do not feel safe, discontinue the site visit and notify your supervisor.
- Fourteen days after conducting the inspection, contact the facility and ask if there were any on-site exposures to COVID-19 since the inspection.
- Notify your supervisor and HR of any potential exposure to COVID-19.