Wednesday, July 8, 2020

COVID-19 Reminder: Reopening Building Facilities With Caution

While some city facilities have reopened, others remain closed. Microbial hazards such as mold and Legionella, the cause of Legionnaires’ disease, can develop in facilities without proper care during the shutdown or without proper precautions prior to reopening.

Potential Hazards

Mold and Bacteria:

Mold and bacteria thrive in moist conditions. When buildings are unoccupied for long periods of time moisture problems may go undetected allowing mold and bacteria to spread. Leaks from roofs and plumbing can deposit moisture and remain undetected while buildings are unoccupied if not inspected on a regular basis. Additionally, traps in floor drains, toilets, and sinks can dry out allowing moist, bacteria-infested sewer gas to flow into a building and collect on ceilings, walls, floors, curtains, and furniture.

Mold and bacteria can also spread throughout a building if furnace filters became damp and contaminated during shutdown and the HVAC system is put back in use before replacing the filters. If HVAC systems with manually adjusted humidifying units have been operating during the shutdown with limited supervision, the humidifier may still be at winter settings introducing excessive moisture through the air distribution network.

People can be exposed to mold through skin contact, inhalation, or ingestion. Individuals who are immunosuppressed are at increased risk for infection from mold.

Legionella:

Legionella is a naturally occurring bacteria that can be found in lakes, rivers, ground water, and thus water distribution networks, and, if present, it bacteria is normally found at a very low level. Legionella grows best in large, complex water systems that are not adequately maintained at temperatures between 77-108 o F. During prolonged facility shutdowns hot water lines are idle for long periods of time and the water temperature can fall into the Legionella growth range. Additionally, building operators may lower the temperature level of water heaters trying to save on fuel costs, but in doing so may be creating an environment where Legionella or other bacteria can multiply. In cold water lines where building air conditioning systems are not operating during shutdowns the ambient temperature around stagnant water lines and cooling towers can also fall into the Legionella growth temperature range.

Inhalation is the most common route of exposure for Legionella. The breathing in of small water droplets containing Legionella allows the microbes to enter the respiratory system. This transfer of water into a breathable source can include cooling towers, sinks, toilets, showers, decorative fountains, and hot tubs.

Double Jeopardy

Coronavirus is a respiratory virus usually affecting the lungs and weakening the immune system. Combining the respiratory hazards and immune deficiency issues created from the COVID-19 pandemic with an additional respiratory infection hazard from mold, Legionella, or other forms of bacteria can only make a bad situation worse. The most at risk individuals are people with pre-existing conditions like asthma, have allergies to mold, or have a weakened immune system.

Guidance

Fortunately, there is no need to reinvent the wheel as you plan to safely reopen your buildings. You can refer to the CDC Guidance for Reopening Buildings After Prolonged Shutdown or Reduced Operations. This CDC guide will cover minimizing mold and Legionella as buildings reopen risk in significant detail.

Looking for more information? Here are more resources you can explore:



Submitted by: Joe Gehrts, Senior Loss Control Coordinator

Monday, June 1, 2020

Fleet Safety: Evaluating Driver Quality in New Hires

Keeping things in perspective

In real estate the common saying is “Location, location, location!” After several years with one of the nation’s largest commercial vehicle insurance carriers, I have come to understand that managing vehicle safety results is often about “Driver quality, driver quality, driver quality!”

When hiring a driver, it would be nice to have a crystal ball to see into the future. Barring an intervention from the spirit world, the best available predictor of future performance is evaluating past performance. However, in making this evaluation you need to interpret the historical data in its proper context to achieve a high level of confidence more accurately predicting future performance. Driver quality metrics used in this analysis include: 

  • Experience driving                   
  • Experience with similar equipment
  • Driving record
  • Accident history

These metrics must not just be considered individually, but on a combined and interrelated basis.

Experience driving – The longer a person has been driving, the more situations that person has encountered. These situations sometime require quick and almost instinctive responses. Critical decision errors due to lack of driving experience can lead to serious crashes. When evaluating any driver candidate be sure to determine how long the person has been driving. The length of time a person has been driving will also have an impact on how the applicants driving record and accident history should be interpreted. Not all motor vehicle reports (MVRs) should be weighted equally. You cannot equally compare the driving history of a driver who has only had a driver’s license for a year to a more experienced driver as the exposure level is much different. Keep in mind the less experienced driver's safety performance may be for a limited driving exposure of possibly 10,000 miles or less. The confidence level for correlating past performance to future results is reduced when the candidate has only been driving a short period. When you run an MVR and see no citations, be sure to put it into perspective relative to how long they have been driving.

Experience with similar equipment – Experience refers to actual time operating similar equipment of the same size and arrangement you are hiring them for. If a driver applicant will be required to have a commercial driver’s license (CDL), determine how long the driver has had the required license type and endorsements. Driving a 50,000-pound snowplow in foul weather is a far different experience than driving a passenger car. In evaluating experience, you need to carefully look at the driver’s application to see what type of equipment they were operating. Also consider how long it has been since they have operated the equipment. Determine the percentage of time spent driving versus other duties. Consider the driving environment the applicant was operating in. Factor in if the driving results were compiled in rural areas or highly congested urban areas and what environment they will be driving in for you.

Driving record – Past moving violations and citations should also be evaluated in context. Be sure to look at the type of citation and give a heavier weighting to more serious violations. Citations that may be considered more serious include:

  • Operating a vehicle under the influence of alcohol or narcotics (DUI or DWI)
  • Refusal to submit to substance testing
  • Felony traffic violations
  • Driving with a suspended, revoked, or invalid license
  • Reckless driving or negligent driving
  • Drag racing
  • Hit and run, leaving the scene of an accident
  • Eluding a law enforcement officer

Accident history – A driving record with no accidents is even more impressive if it was accomplished over a longer time period while driving similar equipment and under similar conditions for the driving position you are trying to fill . The required safe vehicle stopping times and distances are significantly different between a passenger vehicle and a commercial vehicle requiring a CDL. The maneuverability and obstructed views are also more challenging with a larger vehicle. Also, look at the driver action that contributed to the accident and don’t overlook the significance of past incidents that resulted in minor repair costs. Give a heavier weighting for accidents that had the potential for a more serious outcome. For example, an accident involving improper lane change, failure to yield, or running a red light may easily have resulted in a much more serious outcome under slightly different circumstances.

In conclusion - Using driver quality hiring standards is not a new concept. However, making sure the data is analyzed in the proper context can improve the probability of making a successful hiring decision. When evaluating candidates for a driving position, make sure you are comparing apples to apples. Be sure to consider if the candidate’s driving history has been achieved while driving under relevant conditions, for an adequate time period, and at a higher level of performance.


Submitted: Joe Gehrts, Senior Loss Control Consultant


Wednesday, May 20, 2020

Clear Communication at Yard Waste and Organics Recycling (Compost) Sites

“What we’ve got here is failure to communicate…”

That iconic line from the movie “Cool Hand Luke” can be the root of frustration for both the workers and the residents dropping off materials at municipal yard waste and organics recycling sites. Clearly communicating the site’s rules and regulations on both the city’s website and on signage displayed at the compost site can:
  • Reduce frustration for citizens who were unaware of restrictions.
  • Reduce time and resources spent removing unauthorized materials.
  • Reduce confrontations between city employees and the residents.
  • Provide a more enjoyable/hassle-free experience for the workers and visitors.

COVID-19 pandemic safety considerations
While operating during the COVID-19 pandemic the city should make the public aware of the following procedures that will be required for the safety of the workers and the public.
Visitors to the site should:
  • Practice social distancing and stay at least six feet away from others at compost sites.
  • Plan for extra time as social distancing measures may restrict the number of people who can safely unload at one time and may create delays during peak hours.
  • Stay in vehicles until they reach the unloading site and it is their turn to unload.
  • Stay in designated areas and avoid the six-foot restricted areas painted on pavement at dump area (if applicable and more than one party is allowed to unload at a time).

Resident FAQS for yard waste sites
Q.  Is this compost site for me?  When are you open?
Let the residents know in advance:
  • What identification is required to use compost site.
  • Your operating hours and seasonal fluctuations to hours.
  • Whether commercial use is allowed or not.

Q. What can I drop off?
Clearly communicate the acceptable versus unacceptable materials. Make sure unloading sites are clearly marked with what item is accepted and where. Acceptable materials will vary from city to city, but once you determine your policy clearly communicate:
How items are sorted.
  • What is accepted.
  • What is prohibited.
  • What fees will be charged broken down by material and quantity.

    For example, some cities may have the following policy on accepted and prohibited items:

Acceptable Materials
Unacceptable Materials
Spring and fall lawn rakings and thatch
Grass clippings, lumber, sod, and soil
Leaves
Stumps
Soft, vegetative garden waste
Christmas trees
Tree waste
Retaining wall blocks, lumber, rocks, and dirt


Q. What else do I need to know?
Post any additional yard waste site policies on both the website and at the site. For example:
  • Paper leaf bags need to be hauled away by visitor.
  • No plastic bags may be left on site.
  • No yard waste may be left outside facility.
  • No chain saws or wood splitters may be used on site.

Q. But why?
Knowing the reasoning behind why items are prohibited, or some restriction are in place can reduce complaints from yard waste site visitors. To ease frustration for users, post why these policies are in place. For instance:
  • During early spring and late fall, the amount of available daylight is decreased, especially when daylight saving time ends in early November. The site closes earlier during those seasons for the safety of residents who may be backing up vehicles and trailers in the dark.
  • Dirt, rocks, and lumber can cause damage to equipment.
  • Compost site size limitations does not allow for the accommodation of grass clippings.

Provide solutions when possible for alternative disposal options for restricted materials. Suggestions may include:
  • Contract your waste hauler to see if Christmas trees can be collected at curbside.
  • Contact forestry staff at (###) ###-#### about diseased tree disposal.
  • Grass clippings can be disposed of at ….

Q. How do I contact you? Where are you located?
Your website should provide the visitor contact information including:
  • Site names
  • Addresses
  • Phone numbers
  • Map graphics

Keeping your yard waste site secure
In addition to improved communication, here are a few measures your city might consider that could deter after-hours dumping and unauthorized site access:
  • Install a gated entrance to compost site.
  • Fence in the compost site.
  • Only open during staffed hours.
  • Operate security cameras at the compost site.

In summary
Clearly communicating the city yard waste and organics recycling site’s scope of operations, policies, and restrictions will set accurate expectations, reduce confusion, avoid confrontations, and provide a more enjoyable experience for all. 


Submitted by: Joe Gehrts, Senior Loss Control Consultant

Monday, May 18, 2020

Playground Equipment Sanitizing and Signage

As parks begin to reopen, we still need to take precautionary measures to keep the public safe during the COVID-19 pandemic. Posting signs is one way the city can provide additional information on how to reduce the risk of contracting or transmitting the virus.

Regardless of whether the equipment is sanitized or not, a sign posted onsite where it can be easily seen by visitors is appropriate. The sign should simply state:

“Equipment is not/is sanitized.

Play at own risk.”

Even if the city is disinfecting the equipment, it’s not a guarantee the equipment is safe. Consider adding an informational reference about coronavirus on your sign for visitors to review, such as http://www.cdc.gov/coronavirus or https://mn.gov/covid19/.
Photo Credit: Sarah Soucie Eyberg

You may also want to consider translation of these simple messages into any languages that may better serve your community.

If your city is sanitizing your playground equipment, follow the CDC guidelines on cleaning the equipment prior to disinfecting as a best practice. The League has a blog on Sanitizing your Playground Equipment During COVID-19 for additional guidance. If there is a concern of damaging the playground equipment, refer to the manufacturer for guidance and warranty information. 

If you need design or production assistance, check with your local businesses for a sign company that can offer a template or who can make one for your  city. There are also free templates available online. If you have additional questions, please reach out to your city’s loss control consultant.


Submitted by: Julie Jelen, Loss Control Consultant

Public Works Week May 17-23, 2020

It's Public Works Week, and that means around the state, cities and residents are celebrating all of the things you do to keep our cities functioning. We at the League of Minnesota Cities would like to once again thank you for taking care of our streets, sidewalks, water, wastewater, and parks.
Thank you!

Friday, May 15, 2020

Understanding the Difference Between Alternative Masks and Respirators

As city facilities and businesses begin to reopen, the question of whether to require people to wear a mask or allow it to be voluntary becomes particularly important, as does the difference between “respirators” and other cloth filter masks.

Because of the short supply of surgical masks and high-efficiency respirators (N95 and higher), the CDC has recommended using cloth masks as an alternative to allow for the short supply to go to medical personnel and first responders. These cloth filter masks are not intended to replace or be substituted for the other masks, but are the second best option available to protect the general public.

Commonly asked questions about cloth masks, respirators, and OSHA


Q1. What does OSHA consider to be a mask or a respirator, and does this cover simple cloth or surgical masks?

A1. First, OSHA breaks down masks into two categories:
  • Respirators: A respirator is a device that protects employees from inhaling particles or other dangerous substances. Typically, these are fitted closely to the wearer’s face and do not allow air to flow between the sides of the mask and the user’s nose and mouth. Facial hair is not permitted when respirators are required because it prevents a tight seal from occurring. With these types of masks, any air movement is required to pass through the filters. When respirators are mandatory, then all of the OSHA Respiratory Standard requirements must be followed. Granted, OSHA has made some temporary exceptions to fit testing and extended use, but these are also just temporary.
  • Personal Protective Equipment (PPE): Loose-fitting masks which are not intended to filter air are PPE. A surgical mask or the masks that individuals are making at home in response to COVID-19 are not considered respirators because they do not filter the air. These loose-fitting masks, however, are still subject to the OSHA PPE Standard, which requires proper protection if necessary to prevent a job related injury or impairment.

Q2. Is there a difference if an employer requires employees to wear a loose-fitting face mask or merely permits employees to wear a loose-fitting face mask?


A2. Yes – there are significant differences between requiring employees to wear a mask and permitting an employee to wear a mask, even if the employer provides the mask to the employees.

Under the OSHA PPE Standard, which applies to all PPE including loose-fitting cloth face masks, if an employer requires employees to wear PPE, the employer must perform a hazard assessment, consider other alternative options to protect employees such as installing a barrier between workers or workers and customers, identify and provide appropriate PPE for employees, train employees in the use and care of PPE, clean and replace PPE as needed, and create a plan that is periodically reviewed. If employees are considered “medium risk” for COVID-19 exposure because, for example, they have frequent contact with individuals within six feet, then using a mask may be required. This decision is based on your own hazard assessment of the job being performed.

However, if the employer allows the employees to voluntarily wear a loose-fitting mask, none of these rules apply. Even if the employer pays for the masks and provides them to employees, it can still be a voluntary program. The employer should tell the employees, preferably in writing, that the masks are not required and that wearing one is voluntary on the part of the employee.

Q3. What is the actual difference between respirators identified in the OSHA standard and all the masks and homemade masks that the CDC is recommending?

A3. First it is important to understand what a cloth filter mask can and cannot do. 

The primary purpose of a cloth face mask is really to limit the individual from spreading the COVID-19 virus to other people and nearby surfaces by containing the individual’s coughs and sneezes within the mask. That is not to say that these do not also provide a basic level of protection to the wearer if exposed to an individual who has or may have COVID-19, but that is not their primary function.

These cloth face masks do not function like conventional respirators because they are not tight fitting, do not prevent leakage, nor are they designed to filter air. The cloth filter masks, whether commercially purchased or made at home, do not require any type of medical evaluation or fit testing to make sure they work for the individual wearer.

To add to this confusion, some of the terminology used in the OSHA standard can be confusing.  A basic paper dust mask is considered a respirator because it is tight fitting and by design also filters air. 

Q4. But I thought that cloth filter masks are considered an administrative control and not PPE?

A4. That is partially correct. If you look at OSHA’s hierarchy of controls, at the base is PPE and the next step in the hierarchy is administrative.  When reading the description of administrative control, it would appear as though cloth filter masks could be viewed more as an administrative control because of how they are being used to help protect the workforce.  But many administrative controls also involve other aspects of the hierarchy of controls, in this case PPE. Again, this falls back to your hazard assessment conclusions. If your hazard assessment does not indicate that masks are needed but you mandate the use of these anyway you will, in all likelihood, fall under OSHA obligations and will need to comply with those training requirements. That is one reason some businesses have made wearing cloth filter masks a voluntary option but are strongly encouraging their employees to wear them. 

Q5. OSHA recommends extended use and only basic cleaning of a respirator, while you can and should launder cloth filter masks regularly. Why is that?

A5. Regular respirators have a lot of components. Any excessive cleaning can damage the straps, the molded seals around the edge of the respirator etc., which in turn can negatively impact the air filtering capabilities of the respirator to form a tight seal. That is why you cannot have facial hair if wearing a respirator with few exceptions. But these still require some very basic cleaning, disinfecting, and storage practices which should be followed as outlined in your respiratory protection program.

Cloth filter masks, by contrast, do not have many of these components and by design are not tight fitting, so washing these will not create any deformation or negative consequences. Quite the opposite applies here. The wearer may have unknowingly contacted the COVID-19 virus at some point in time during the day — proper cleaning removes the contaminant. 

There are several very good YouTube videos dealing with how to properly clean cloth filter masks. In reality, many of these masks require nothing more than a simple laundering. The key thought is to not just continue to reuse a cloth mask without laundering or using another disinfecting option as shown.



REMINDER: These types of face coverings supplement other preventive measures, they are not intended as a substitute. They provide an added layer of protection on top of social distancing, good personal hygiene, and other precautions that could be taken.

Q6. I want to mandate the use of cloth filter masks for my employees returning to work. Do I need to comply with all the OSHA requirements concerning fit testing, medical screenings, etc.?

A6. The direct answer to your question is no. Cloth filter masks do not fall into OSHA’s definition of what a respirator is. Therefore, they do not have the same medical screening and fit testing requirements. There still is a level of training and general information sharing which is outlined in the OSHA standard.

We all understand that the intent of cloth filter masks is to really protect the general public more than just the wearer. Recent studies have shown that a significant portion of individuals with coronavirus lack symptoms (“asymptomatic”) and that even those who eventually develop symptoms (“pre-symptomatic”) can transmit the virus to others before showing symptoms. This is why the CDC recommends wearing cloth face coverings in public settings, at work, and during activities when social distancing measures are difficult to maintain.

Most cloth filter masks and any homemade masks are not regulated by the FDA. Remember the CDC has come up with these alternatives in response to a shortage of available respirators and surgical cloth masks, but these alternatives were never intended as a replacement if and when those other forms of PPE are available. If you are requiring these as part of your return to work program, they would then be considered an administrative control and as such, it is reasonable to think that you will need to provide information on the safe use, storage, cleaning, etc. of these masks that is part of the OSHA standards. 

As the employer, when using them as a form of administrative control you would still have obligations
to ensure employees use them safely and understand that these types of masks do not prevent particles from passing through any openings in the mask that occur with or without any facial hair.

If you are purchasing commercially manufactured cloth filter masks, make sure to read the labels. While the vast majority of these are not designed to be “tight fitting,” some are being designed or advertised as such and even have warning labels on the packaging as to who can and cannot wear them without medical screenings.  

Submitted by: Joel Muller, Field Loss Control Manager




Thursday, April 30, 2020

Mother Nature Won’t Stay Home — Flood and Tornado Considerations During the Pandemic

Note: A city should always be reviewing emergency preparedness plans at least annually. The scope of this article is not to be a comprehensive discussion of emergency preparedness plans for tornadoes and floods, but rather to bring attention to how your existing preparedness plans may need to be modified while responding during the COVID-19 pandemic. Operating during the COVID-19 pandemic will present unique challenges and considerations that will have to be accommodated for.

It has not been “business as usual” for some time now and responding to emergencies such as floods and tornadoes during the COVID-19 pandemic will be anything but usual. Cities should be reassessing emergency preparedness plans to determine what alterations may be required under the current environment to effectively respond to floods and tornadoes.   
                                                                              
Here are some items to consider: 

Cities have been operating with skeleton crews and many employees are working off-site. Schedules and priorities have shifted. Will resources including chain saws, pole saws, generators, and mobile equipment be in good operating order? Cities should verify that:

  • Equipment kept in dry storage over the winter are operational and well maintained.
  • Fresh fuel is provided in mobile and portable equipment.
  • Fuel tanks for generators are topped off (take advantage of the record low fuel prices).
  • Chainsaw and pole saw blades have been sharpened, and spare blades available.

Has the city been maintaining emergency alert systems? Make sure to continue:
  • Providing public service announcements regarding municipal weather alerts
  • Testing alert systems on the first Wednesday of each month
  • Verifying the reliability of emergency alert equipment. Check that:
    • Branches are not obstructing sirens.
    • Sirens were not damaged over the winter.
    • Generators and battery backups for alert systems are operational.

Have you considered the impact on human resources available for responding to emergencies? Social distancing measures will need to be incorporated. For example, you may only be able to use one chute of a dual chute sandbagging machine or just the outside chutes of a quad sandbagging machine. Will you still be able to meet sandbagging capacities under these restrictions, or will additional devices be required? Some additional human resource items to consider doing in advance:

  • Verify if mutual aid agreements will still be honored during the pandemic.
  • Identify and provide alternates for key personnel who may not be available during the emergency response event due to illness.
  • Accommodate for the change in availability of volunteers which may be needed for sandbagging and other activities:
    • Determine how to accomplish social distancing with employees and volunteers for various response activities.
    • Identify potential areas of congregation during response.
    • Seek alternative methods such as using mechanical means where possible.
    • Have emergency inventory of face masks and gloves in stock for volunteers and employees.
    • Provide portable hand wash stations with soap or sanitizer dispensers at emergency sites. 

We can’t control natural disasters from happening, but we can control how prepared we are to respond to them.

Additional Resources:


Submitted by: Joe Gehrts, Senior Loss Control Consultant