As we begin to start operations in this all new environment we have developed an action plan to prepare, prevent and respond using the guidance available to us from the CDC and OSHA. Our hope is to maintain a safe and responsible work place for our employees and the customers we serve. 

UPDATED 5/11/2020





Will wear a facemask

Practice social distance

Limit contact

Keep hands clean

Sanitize all “HTS” in workplace

Monitor personal health closely

Stay home if symptoms arise 


Will wear a facemask

Practice social distance

Limit contact

Keep hands clean

Be patient & respectful of the rules

Monitor personal health closely

Stay home if symptoms arise 



I. Responsibilities of Managers

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

 II. Responsibilities of Employees

Shadow Art is asking every one of our employees and contractor’s employees (hereinafter “employee” or “employees”) to help with our prevention efforts. In order to minimize the spread of COVID-19 at our job-sites and shop, everyone must play their part. As set forth below, Shadow Art has instituted various housekeeping, social distancing, and other best practices at our job-sites. All employees and contractors must follow these. In addition, employees are expected to report to their manager if they are experiencing signs or symptoms of COVID-19, as described below. If you have a specific question about the plan or COVID-19, please ask your manager.

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

• Frequently wash your hands with soap and warm water for at least 20 seconds.

• Only 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.

• Follow appropriate respiratory etiquette.

• Avoid close contact with people who are sick.

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

• Coughing

• Fever

• Shortness of breath or difficulty in 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, STAY AT HOME and call your manager and healthcare provider right away. Likewise, if you come into close contact with someone showing these symptoms, call your manager and healthcare provider right away.

III. Job Site Protective Measures

The Company has instituted the following protective measures at all jobsites:

A. General Safety Policies and Rules

• Any employee/contractor/client showing symptoms of COVID-19 will be asked to leave the job-site and return home.

• All paperwork must be provided electronically in lieu of hard copies to the fullest extent possible.

• All employees will be screened every shift, prior to entering buildings and/or job-sites. Employees that answer “yes” to any one of the following questions will not be allowed to access the building and/or job-site:

♦ Have you been confirmed positive for COVID-19 within the last 14 days?

♦ Are you currently experiencing, or experienced in the last 14 days, any

acute respiratory illness symptoms such as:

•Fever over 100.4 F


•Shortness of Breath

•Other cold/flu symptoms

•Have you been in close contact with any persons who has been confirmed positive for COVID-19 within the last 14 days?

NOTE: Close proximity contact is defined as contact within six (6) feet.

• Employees should limit the use of co-workers’ tools and equipment. To the extent tools must be shared, clean tools before and after use with and EPA approved disinfectant. When cleaning tools and equipment, consult manufacturing recommendations for proper cleaning techniques and restrictions.

• If practicable, each employee should use/drive the same vehicle every shift. To the extent that vehicle must be shared, disinfect equipment, including all touch points, with EPA approved disinfectant before and after every shift and/or change in operator.

• Employees must avoid physical contact with others and shall direct others (coworkers/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, or electronically (Zoom, Teams, etc.).

• Due to the nature of our work, access to running water for hand washing may be impracticable. In these situations, use alcohol-based hand sanitizers and/or wipes.

• Employees are encouraged to minimize ride-sharing. If no other transportation option is available, while in vehicles with multiple passengers, employees must ensure use of face covering and adequate ventilation.

B. Working In Occupied Buildings

• Working within occupied office buildings, and other establishments, present unique hazards with regards to COVID-19 exposures. Everyone working within such establishments should follow posted building guidelines, and evaluate the specific hazards of their work tasks when determining best practices related to COVID-19.

• During this work, employees must sanitize work areas upon arrival, throughout the workday, and immediately before departure.

• Employees should ask other occupants to keep a personal distance of six (6) feet at a minimum. Workers should wash or sanitize hands immediately after using the restroom, smoking, eating, drinking, and before and after work activities.

• Occupancy of elevators should be no more than one passenger for 12 square feet of floor space. All passengers must wear face masks while in elevators at all times.

C. Personal Protective Equipment and Work Practice Controls

• In addition to regular PPE for various tasks (fall protection, hard hats, hearing protection. Etc.), the following is required:

♦ Face masks such as surgical masks, cloth masks, or masks otherwise consistent with the CDC’s recommendations, must be worn by all employees and clients while indoors, unless their use creates a separate safety hazard.

♦ Eye protection: Eye protection must 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. Nevertheless, employees must wear N95 respirators if required by the work and if available.

• Due to the current shortage of N95 respirators, the following Work Practice Controls should be followed:

IV. Job Site Cleaning and Disinfecting

Shadow Art  has instituted regular housekeeping practices which include cleaning and disinfecting elements of the work environment, where possible. Employees should regularly do the same in their assigned work areas including:

• All common touch points including door handles, faucet handles, stair rails, grab bars and toilet seats.

• Collect trash frequently wearing nitrile, latex, or vinyl gloves.

• Vehicles and equipment/tools should be cleaned both before and after change in operator or rider.

OSHA has indicated a reliable report that an employee has tested positive for COVID-19 does not typically require an employer to perform special cleaning or decontamination of work environments, unless those environments are visibly contaminated with blood or other bodily fluids. Notwithstanding this, Shadow Art will clean those areas of the job-site that a confirmed-positive individual may have contacted, and it will do so before employees can access that work space again.

• Disinfection shall be conducted using one of the following:

♦ Common EPA-registered disinfectant;

♦ Alcohol solution with at least 60% alcohol; or

♦ Diluted household bleach solutions (if appropriate for the surface).

V. Jobsite Exposure Situations

A. Employee Exhibits 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 feverreducing or other symptom-altering medicines (e.g., cough suppressants).

• Shadow Art will similarly require an employee who reports to work with symptoms to return home until he or she is symptom free for 72 hours (3 full days).

• Moreover, Employees are required to follow the direction of their healthcare provider, and local health department, and obtain clearance from their healthcare provider clearing them to return to work.

B. Employee Tests Positive for COVID-19

• If an employee tests positive for COVID-19, the employee shall immediately notify the manager who will then:

♦ Immediately stop work where the employee was working, and prevent others from entering the area until disinfected.

♦ Contact the health department.

♦ Prepare incident report.

♦ Identify and inform potentially-impacted employees and clients working in close proximity.

♦ Identify and inform employees working on-site, but not in close proximity.

♦ Throughout this process, the confidentiality of the employee must be maintained.

• 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 who test positive and are directed to care for themselves at home may return to work when:

♦ At least 72 hours (3 full days) have passed since recovery*; and

♦ At least seven (7) days have passed since symptoms first appeared.

• Moreover, Employees are required to follow the direction of their healthcare provider, and local health department, and obtain clearance from their healthcare provider clearing them to return to work.

C. Employee Has Close Contact with an Individual Who Has Tested Positive for COVID-19

• Employees who have come into close contact with an individual who has tested positive for COVID-19 (co-worker or otherwise) will be directed to self-quarantine for 14 days from the last date of close contact with that individual. Close contact is defined as contact within six (6) feet for a prolonged period of time.

• Moreover, Employees are required to follow the direction of their healthcare provider, and local health department.

*Recovery is defined as: (1) resolution of fever without the use of fever-reducing medications and (2) improvement in respiratory symptoms (e.g., cough, shortness of breath)

VI. OSHA Recordkeeping

If a confirmed case of COVID-19 is reported, Shadow Art will determine if it meets the criteria for record-ability and report-ability under OSHA’s record-keeping rule. OSHA requires 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 is not a confirmed diagnosis, the record-ability analysis is not necessarily triggered at that time.

If an employee has a confirmed case of COVID-19, Shadow Art 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.

Shadow Art’s assessment will consider the work environment itself, the type of work performed, the 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, Shadow Art 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.

VII. Confidentiality/Privacy

Except for circumstances in which Shadow Art 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 that an unnamed employee has tested positive will be kept to the minimum needed to comply with reporting requirements and to limit the potential for transmission to others. Shadow Art reserves the right to inform other employees that an unnamed co-worker 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. Shadow Art also reserves the right to inform sub-contractors, vendors/suppliers or visitors that an unnamed employee has been diagnosed with COVID-19 if they might have been exposed to the disease so those individuals may take measures to protect their own health.

VIII. General Questions

Given the fast-developing nature of the COVID-19 outbreak, Shadow Art may modify this plan on a case by case basis. If you have any questions concerning this plan, please contact Brett LeBlanc –