COVID-19 WORKPLACE HEALTH AND SAFETY PLAN

INTRODUCTION

The Institute of Museum and Library Services’ (IMLS) COVID-19 Workplace Health and Safety Plan (“Plan”) establishes a framework of operating status guidelines the agency will implement to fulfill the requirements of Executive Order on Protecting the Federal Workforce and Requiring Mask-Wearing (EO 13991), as supplemented by the Office of Management and Budget (OMB) Memorandum M- 21-15, COVID-19 Safe Federal Workplace: Agency Model Safety Principles.

This IMLS Plan is based on the most recent COVID-19 guidelines from the Centers for Disease Control and Prevention (CDC) as well as the updated federal implementing guidance by the Safer Federal Workforce Task Force (SFWTF). IMLS expects further updates to this Plan to maintain compliance with ongoing adjustments to CDC and SFWTF requirements and heed stakeholder and Task Force feedback, as well as other health guidance changes.

This IMLS Plan supersedes the IMLS Reopening Strategy and Punchlist and restructures its provisions to adhere to and comply with the detailed requirements of OMB Memo 21-15, as well as the most updated CDC and Task Force guidelines. Protecting IMLS staff and stakeholders from the effects of COVID-19, while responsibly maintaining the agency’s readiness to fulfill its mission, remain the foundational principles of this Plan.

Throughout the COVID-19 pandemic, IMLS has consistently followed federal guidance, incorporating information provided by the CDC and the Task Force into agency practices and protocols to protect the health and safety of IMLS employees. IMLS implemented a maximum telework approach, along with protective operational safeguards, in the course of facilitating the agency’s work processes to accomplish its mission. Proactive, consistent communication among leadership, management and employees has been and will continue to be a key component of the IMLS’s COVID-19 response.

The IMLS COVID-19 Workplace Health and Safety Plan applies to all IMLS Office Space, as well as all common areas adjacent to IMLS Office Space, unless otherwise specified within the Plan. Mask requirements, contact tracing, symptom monitoring, workplace operations, as well as health and safety procedures and protocols apply to everyone accessing the IMLS Office Space; this includes employees, contractors, grantees, visitors, and any other onsite personnel.

COVID-19 COORDINATION TEAM

IMLS has established a cross-agency COVID-19 Coordination Team responsible for the preparation, revision and implementation of the COVID-19 workplace health and safety plan and protocols, as well as all human resources flexibilities available during the pandemic. The Team is responsible for ensuring both that IMLS leadership is apprised of the Plan requirements and contents and that the Plan’s policies and practices are in line with OMB, CDC, SFWTF and other federal guidance. If you have questions, please contact the Coordination Team Lead Chris Catignani.

AGENCY WORKFORCE OPERATING STATUS

Maximum Telework
Since the outset of the COVID-19 pandemic, IMLS has instituted an operating status of maximum telework, encouraging employees to maximize telework to the fullest extent possible, while expanding work hours and workweek flexibilities. Consistent with CDC and Safer Federal Workforce Taskforce guidance, IMLS continues its posture of maximizing the use of telework. As IMLS leadership develops its phased reentry plan in accordance with OMB and Task Force guidelines, the agency will remain in a maximum telework status and maintain work hour and scheduling flexibilities, while seeking employee input and examining the various considerations necessary to develop the agency’s reentry plan.

In its current operational posture of maximum telework, IMLS has implemented a One-Day Office Access Request Process for approving daily entry, which is authorized and monitored by the Chief Operating Officer and Human Resources Director, with support from the Chief Financial Officer. See Symptoms Screening and Office Access Section below. Unless for operational business necessity, occupancy in IMLS workspaces may not exceed 25% of normal capacity during periods of high community transmission. For IMLS, community transmission is assessed by determining the transmission rates across the cities and counties within the commuting area of our Office. When IMLS changes its operational posture, employees will be given advance written notice and a six- week transition period before being required to return to the physical Office Workspace.

WORKPLACE OPERATIONS

Office Space Occupancy
As of the date of this Plan’s issuance, IMLS continues to limit Office Space occupancy to those requiring access for business necessity. IMLS continues to monitor and limit workspace access in order to safeguard the health and safety of all occupants. The IMLS workforce generally has been in a maximum teleworking posture throughout the COVID-19 pandemic. In accordance with Task Force guidance, IMLS continues to examine all aspect of its reentry planning to determine whether its posture on Office Occupancy should change.

‘Fully Vaccinated Status’
The CDC defined persons having “Fully Vaccinated Status” as those who at least two weeks ago received either: (a) the 2-dose Pfizer-BioNTech or Moderna vaccine series; or (b) the single-dose vaccine Johnson and Johnson (J&J)/Janssen. There is currently no post-vaccination time limit on fully vaccinated status. Executive Order 14043 required that all federal employees become Fully Vaccinated no later than November 22, 2021.

The Task Force continues to issue information to clarify for Federal Agencies how to comply with both the CDC guidance and OMB Memorandum M-21-15. Executive Order 13991 instructs Federal agencies to adhere to current public health measures as provided in CDC guidance, including with respect to mask wearing, physical distancing, and other safety measures. In short, the Task Force clarified that Federal employees, onsite contractors and visitors must continue to wear a mask and physically distance consistent with CDC guidance and OMB Memorandum M-21-15.

Under this CDC guidance and per Task Force instruction, IMLS will post signs making clear the IMLS masking and physical distancing requirement, as well as other specified health and safety measures.

Travel protocols also address issues involving Fully and Not Fully Vaccinated Status consideration, discussed near the end of this Plan.

If you have a condition or are taking medication that weakens your immune system, you may NOT be fully protected even if you are fully vaccinated. Talk to your healthcare provider. Even after vaccination, you may need to continue taking additional precautions.

COVID-19 Community Levels
The CDC recently set recommendations related to COVID-19 Community Levels, which measure the impact of COVID-19 illness on health and healthcare systems and inform the appropriate prevention strategies to utilize at a given time. The CDC tracker measures each U.S. county’s Community Level as Low, Medium or High. See the CDC COVID-19 Community Level Check Tool.

As of Friday, March 4, 2022, Federal agencies are required to apply this new Community Level measure only to Workplace Health and Safety procedures for Masking and Screening Testing. Simply stated, the CDC has defined the “Community” in “Community Level” to mean the county in which a given Federal agency facility is located, regardless of the wider commuting area where employees may reside. Applying this framework, the Principal IMLS Office is located in the county of Washington, DC for purposes of the CDC’s county-level COVID-19 Community Level tracker.

Pursuant to the latest CDC and SFWTF guidance, Federal agencies must weekly consult the CDC’s applicable county-wide data to determine whether the COVID-19 Community Level for a given facility has changed in a manner that requires changes to agency COVID-19 workplace safety protocols for the upcoming week.

The CDC anticipates updating its Community Level Tracker between 2-4pm every Thursday. Every Friday between 9-10am, the IMLS Workplace Safety Coordination Team will consult the CDC Community Level tracker to determine whether any changes in workplace safety procedures will be implemented for the following week. Every Friday afternoon as necessary, the Coordination Team will provide updates to all staff regarding any changes to agency COVID-19 workplace safety protocols for the upcoming week.

Face Coverings or “Masking”
In accordance with the most recent CDC and SFWTF guidance issued February 28, 2022, IMLS requires all staff working onsite, as well as any other persons in IMLS’s Office space, to wear a face covering, or “mask,” only when the Washington, DC COVID-19 Community Level is High, regardless of a person’s vaccination status.

Wearing a mask, in conjunction with physical distancing, can slow the spread of COVID-19 transmission and remains a critical step for ensuring a safe and healthy workplace when the Washington, DC COVID-19 Community Level is High. The IMLS workplace has non-medical disposable masks available at the Main entrance reception desk counter to any person entering the IMLS facility without a mask, including visitors. Signage posted at Main Entrance remind occupants that non-medical disposable masks are available at the Main entrance reception desk counter.

The CDC recommends the following: Non-medical disposable masks, masks that fit properly (snugly around the nose and chin with no large gaps around the sides of the face), masks made with breathable fabric (such as cotton), masks made with tightly woven fabric (i.e., fabrics that do not let light pass through when held up to a light source), masks with two or three layers, and masks with inner filter pockets. IMLS will not allow novelty/non-protective masks, masks with ventilation valves, or face shields as a substitute for masks.

When masks are required due to a high community level, masks must be worn by all persons – whether Fully Vaccinated or Not Fully Vaccinated -- in all areas inside the IMLS workplace (with the limited exception stated below), including all common spaces, cubicle bays, hallways, meeting rooms, stairwells, restrooms and elevators. The mask requirement applies to all persons accessing IMLS facilities -- employees, contractors, grantees, and all visitors. While in IMLS facilities, masks may be removed when working alone in a private office (office not used for meetings) with floor to ceiling walls and a closed door in accordance with CDC guidelines. Any exception to this mask-wearing policy must be submitted to the COVID-19 Coordination Team for review and approval.

Employees needing a related reasonable accommodation (e.g., modified face covering for interpreters, individuals with pulmonary difficulties, etc.) should consult with their supervisor for a modification or feasible alternative. In accordance with guidance issued by the Equal Employment Opportunity Commission (EEOC), an agency may legally require employees to wear a mask while physically in the workspace to reduce COVID-19 transmission; and an employee who fails to follow this requirement may be subject to disciplinary action. Supervisors should contact the Office of Human Resources should any issues arise. The appropriate Contracting Officer’s Representative or Contracting Officer should be contacted if onsite contractors are not in compliance with this mask requirement.

Physical Distancing
IMLS requires all persons working onsite to adhere to the CDC physical distancing guidance by keeping six feet between other people to help prevent the spread of COVID-19. Signage will be posted at IMLS workspace entry points and high traffic areas encouraging employees, contractors, grantees, and visitors to maintain six feet of physical distance in all common areas. Markings on the floor have been added to high-traffic areas such as entryways and the elevator lobby. Signage and floor markings will be continuously evaluated and augmented as needed.

Environmental Cleaning
Custodial contracts include daily disinfection of all common areas such as restrooms, pantries, and stairwells. High touchpoint areas such as elevator buttons, door handles, and handrails are disinfected multiple times daily. All products used for cleaning/disinfecting comply with CDC cleaning requirements. Cleaning supplies are available for on-site staff to disinfect their workspace.

Hygiene
Hand sanitizers also are available at the IMLS entrance lobby and in the mail room and outside the west end pantry. Hand sanitizer stations (with at least 60% ethanol) are located throughout the office and disinfecting spray or disinfecting wipes are provided at the front door and outside of the west-end pantry. and staff are encouraged to wipe down surfaces before and after any in person meetings. Staff is encouraged to disinfect all contact work surfaces in their cubicles and offices daily. The IMLS workspace also includes signage encouraging frequent handwashing.

Ventilation and Air Filtration
An important approach to lowering the concentrations of indoor air pollutants or contaminants, including any viruses that may be in the air, is to increase ventilation – the amount of outdoor air coming indoors. Using a heating, ventilation and air conditioning (HVAC) system to ensure proper ventilation with outside air can help reduce the concentration of airborne contaminants, including viruses, indoors. The degree to which outdoor air can be brought into any building varies depending on the age and capacity of its HVAC systems.

Air handling units should be outfitted with the highest efficiency level of filtration that does not significantly diminish air flow using the existing filter rack, fan, and other limiting factors of the air handling units. The filters should be well sealed, so that all air passes only through the filter, without bypassing them. GSA has responsibility on behalf of and in coordination with IMLS for coordinating with the Building Lessor operating and maintaining HVAC systems and working with the Lessor to ensure appropriate operations and maintenance in federally leased buildings.  Because HVAC operations include taking steps to increase ventilation and improve air filtration in accordance with CDC guidelines, this Coordination Team will be working with our GSA Facility Manager for more information on the specific steps taken in our facility.

Staggered Work Times and Cohort-based Scheduling
At this time, IMLS is only authorizing one-day access for business necessity; all other personnel are instructed to utilize maximum telework and work schedule flexibilities. Team Lead Chris Catignani tracks staff entry in order to monitor employee workspace density. Staggered work times and cohort-based scheduling will be developed if necessary.

Elevators
The elevator floors are marked to identify the location to stand to support physical distancing within the elevator cab. IMLS’s Lessor has implemented procedures to ensure that occupancy limits follow physical distancing guidelines. In the IMLS elevator lobby floor, proper markings identify where individuals waiting for an elevator or riding in elevators should stand to maintain physical distancing.

Shared Spaces
Employees should not congregate in areas including, but not limited to, entry and exit doors, hallways, lobbies and foyers, elevators, stairwells, corridors, restrooms, pantries/kitchens, break rooms, photocopy and printer areas.

Hand sanitizer, disinfecting spray or wipes and disposable gloves are located in all office space common areas. Staff is encouraged to wipe down surfaces before and after any in-person meetings and to disinfect all contact work surfaces in their cubicles/offices and shared electronics daily (including copiers, printers, fax machines, etc.)

Signage is posted at conference room doors with the maximum capacity for physical distancing. Meeting planners should monitor seating arrangements to ensure six-foot separation between attendees.

Restrooms have a posted maximum occupancy, depending on the size (usually no more than two people). There are also multiple health & safety signs within restrooms encouraging handwashing and physical distancing.

Entry into pantries and kitchen areas is limited depending on the size of the space; and signage is posted accordingly.

SCREENING AND DIAGNOSTIC TESTING

Please note the following definitions as you read this section:

  • Fully Vaccinated: An individual is “fully vaccinated” who at least two weeks ago received either: (a) the 2-dose Pfizer-BioNTech or Moderna vaccine series; or (b) the single-dose vaccine Johnson and Johnson (J&J)/Janssen). [This definition also appears above.]
  • Up-to-Date: An individual is up to date with COVID-19 vaccines who has received all recommended COVID-19 vaccines, including recommended booster shots when eligible (and additional primary shots for some immunocompromised people).

Screening Test Program
Screening tests only apply to employees and contractors working onsite who are not “fully vaccinated” as defined above. Screening testing only takes place when the Washington, DC COVID- 19 Community Level is Medium or High. The CDC COVID-19 Community Level Check Tool is to be used to determine the community transmission level. Screening helps to identify unknown cases so that measures can be taken to prevent further transmission and safeguard the federal workplace.

IMLS’s COVID-19 screening testing program applies to employees and contractors for whom all of the following are true: (1) who are not fully vaccinated, (2) who are asymptomatic and do not have known, suspected, or reported exposure to SARS-CoV-2, and (3) who will be working onsite or interacting in person with members of the public as part of their job duties. (Screening testing also applies to unvaccinated employees and/or contractors with pending or approved request for exception or extension from the COVID-19 vaccination requirement.)

When the Washington, DC COVID-19 Community Level is Medium or High, these employees and contractors are required to produce a current (administered within the past 3 days) negative test result from an FDA authorized viral COVID-19 test prior to the start of each of their day(s) of entry. Depending on the frequency the employee is onsite, IMLS does not anticipate screening tests of anything greater than a bi-weekly basis. IMLS will pay and/or reimburse the cost of screening testing for employees; IMLS can arrange to ship the required FDA authorized viral COVID-19 test beforehand or provide reimbursement following employee purchase of a home kit or a test administered by a third party. The time required for employees subject to the screening requirement to obtain and undertake testing (including travel time to/from a site preapproved by the agency) is on-duty time.

Supervisors will verify but not collect test result information. Screening testing may not be both self-administered and self-read by the employee unless observed by the agency or an authorized telehealth provider. Any employee or contractor who must present screening test results should communicate in advance with their first-line supervisors (for contractors, their Contracting Officer Representative or delegate) to determine the on-duty time allotted for testing and the process for verifying test result information (i.e., whether the supervisor or a third-party health provider will observe the test). Supervisors may verify test results by either reviewing dated third party results or observing from beginning to end self-administered tests via video call or as otherwise arranged.

Employees or onsite contractors who miss their required screening test within the time period agreed upon with their first-line supervisors will be denied access to the IMLS Office and such failure by employees may result in disciplinary action.

Diagnostic Testing
Under IMLS diagnostic testing procedures, employees who come into close contact with persons with COVID-19 while working onsite at the IMLS Office will receive diagnostic testing at no cost.

A close contact is interaction “within 6 feet of someone who has probable or confirmed COVID-19 for a cumulative total of 15 minutes or more over a 24-hour period.” Any employee having a close contact must be tested at least five full days after the close contact (unless they were COVID-19 positive within 90 days and subsequently recovered and remain without COVID-19 symptoms, in which case they do not need to get tested after close contact). Quarantining also may apply, as discussed below.

Employees having close contacts onsite at the IMLS Office will receive diagnostic testing at least five full days after they last had close contact. If they test positive or if they at any time develop COVID- 19 symptoms, they should isolate as discussed below.

QUARANTINE AND ISOLATION

The quarantining guidelines for asymptomatic employees or contractors after a close contact varies depending upon their “up-to-date” vaccination status or whether they have had COVID-19 within the last 90 days confirmed by using a viral test.

Avoidance Practices in lieu of Quarantine. Individuals who are up to date on their vaccines and individuals having recovered from COVID-19 within the last 90 days need not quarantine following a close contact so long as they are asymptomatic. However, they should take precautions for ten full days from the date they last had close contact with someone with COVID-19, including by wearing a well-fitting mask when around others, avoiding eating and drinking around others, avoiding environments such as dining facilities and gyms where they may be unmasked around others, avoiding people who are immunocompromised or at high risk for severe disease, and avoiding high- risk settings. If an up-to-date individual is unable to wear a mask, then they should quarantine for 10 days.

Quarantine Practices: Individual who are not up to date with vaccinations (and have not been diagnosed with COVID-19 within the last 90 days) should quarantine at home for at least five full days after their last close contact with someone who has probable or confirmed COVID-19 (the exposure date is day 0, and the first full day after exposure is day 1). They should quarantine for ten full days if they are not able to wear a mask when around others. If an individual who is not fully vaccinated develops any COVID-19 symptoms during quarantine, they should isolate immediately and test, and remain isolated until they receive their test results; if they test positive, the individual should follow CDC isolation recommendations.

If an employee or contractor is subject to quarantine, then they may not gain access to the office during the quarantine period.

The following table tracks what steps “up-to-date” and “not-up-to-date” individuals must take once having a “close contact” and is a summary of the actions in the Quarantine and Isolation section:

Individual Status

Close Contact?

Wear Mask?

Asymptomatic

Symptomatic

Quarantine?

Practices

OK to come
to Office?

Vaccines Up-to-Date OR
Recovered in last 90 days

 

 

Yes

Yes

Yes

No

No

Avoidance

Yes

Yes

Unable

Yes

No

10 days

Avoidance

No

No

No

N/A

N/A

No

N/A

Yes


Vaccines not Up to Date,
no COVID in last 90 days

Yes

Yes

Yes

No

5 days

Quarantine

After quarantine

Yes

Unable

Yes

No

10 days

Quarantine

After quarantine

Yes

Yes

Yes

Yes,
symptoms
develop during
quarantine

10 days+

Quarantine

Only after negative test

No

No

N/A

N/A

No

N/A

Yes

Confidentiality
All medical information collected from personnel will be treated confidentially in accordance with applicable law; such medical information will be maintained separate from general personnel files and accessible only by those with a business need to know in order to protect the health and safety of IMLS personnel. OHR Director Antoine Dotson will serve as the point of contact for all questions related to personal medical data.

Contact Tracing
IMLS follows procedures and protocols for Contact Tracing in accordance with CDC and Safer Federal Workforce Taskforce guidance. More specifically, IMLS has the employer obligations to (1) report any potential workplace COVID-19 case to the local health authorities and (2) monitor office occupancy in order to both identify potential close contacts and facilitate necessary communications to other Office occupants in the event of reportable COVID-19 case. See https://www.cdc.gov/coronavirus/2019-ncov/daily-life-coping/contact-tracing.html. IMLS’s Contact Tracing guidance also extends to all contractors and visitors to the IMLS workspace.

OFFICIAL TRAVEL, DOMESTIC

The CDC issues specific, evolving travel guidance; all Federal employees are encouraged to consult the Task Force website resources concerning official travel and the CDC travel guidelines at the following link: https://www.saferfederalworkforce.gov/faq/travel/.

Generally, the CDC guidelines instruct all those who are Not Fully Vaccinated to delay travel until reaching Fully Vaccinated Status. The CDC also explicitly prohibits travel for those who have been exposed to COVID-19, have tested positive for COVID-19 or are awaiting results of a COVID-19 test, or are otherwise sick.

Task Force guidance clarifies that there are no government-wide limits on official travel for Federal employees having Fully Vaccinated Status. For employees who are Not Fully Vaccinated, the Task Force clarifies that official Domestic travel is limited to mission critical trips.

At this juncture, IMLS is limiting official travel to mission critical trips in most circumstances, without regard to vaccinated status. IMLS continues to consider the protocols for International official business travel; these protocols will require an update to this portion of the Plan.

At this juncture, all employees must coordinate with their respective managers and this Coordination Team to determine whether any proposed official Domestic travel may be authorized as mission critical.

Additionally, any employee who proposes taking official Domestic travel must assume the responsibility of adhering strictly to CDC guidelines before, during, and after official travel.

Before Travel

All potential travelers should:

  • Check the current COVID-19 situation at your destination.
  • Review and prepare to follow all state, local, and territorial travel restrictions, including mask wearing, testing, or quarantine requirements.
    • For up-to-date information and travel guidance, check the state or territorial and local health department’s website where you are, along your route, and where you are going.
  • If traveling by air, check if your airline requires any testing, vaccination, or other documents.
  • Prepare to be flexible during your trip as restrictions and policies may change during your travel.

For those who are Not Fully Vaccinated (as defined above), the CDC protocols for Domestic travel are as follows:

  • Get tested with a viral test 1-3 days before your trip.

During Travel

While traveling, everyone, whether Fully Vaccinated or Not Fully Vaccinated, must:

  • Wear a mask over your nose and mouth as required on planes, buses, trains, and other forms of public transportation traveling into, within, or out of the United States and while indoors at U.S. transportation hubs such as airports and stations.
  • Travelers are not required to wear a mask in outdoor areas of a conveyance (like a ferry or top deck of a bus).
  • Maintain physical distancing, including by avoiding crowds and staying at least 6 feet/2 meters (about 2 arm lengths) from anyone who is not traveling with you.
  • Wash your hands often or use hand sanitizer (with at least 60% alcohol).
  • Follow all state and local health recommendations and requirements at your destination.

After Travel

For those who are Fully Vaccinated (as defined above), the CDC protocols for Domestic travel are as follows:

  • Self-monitor for COVID-19 symptoms; isolate if you develop symptoms.
  • Follow all state and local recommendations or requirements.

For those who are Not Fully Vaccinated (as defined above), the CDC protocols for Domestic travel are as follows:

  • Get tested with a viral test 3-5 days after travel AND stay home and self-quarantine for a full 7 days after travel.
  • Stay home and self-quarantine for a full 5 days after travel.
  • Follow all state and local recommendations or requirements.

In terms of International Travel, please consult your destination’s COVID-19 situation and travel requirements before planning official travel internationally. Countries may have their own entry and exit requirements. Please also consult the CDC’s guidance at the following link: https://www.cdc.gov/coronavirus/2019-ncov/travelers/international-travel-during-covid19.html

Last updated: August 22, 2022