Airborne Infectious Disease Exposure Prevention Plan

 This plan is being activated as designated by the New York State Commissioner of Health. 

Syracuse University’s Air Borne Infectious Disease Prevention Plan (the “plan”) is prepared in accordance with the New York Health and Essential Rights Act (Hero Act) enacted May 2021.  This plan is intended to mirror and incorporate all substantive components of the  NYS Department of Labor’s Airborne Infectious Disease Exposure Prevention Standard and Model Airborne Infectious Disease Exposure Prevention Plans.

This plan applies only when the Commissioner of Health designates an airborne infectious agent or disease as a highly contagious communicable disease that presents a serious risk of harm to the public health (“declared airborne infectious disease”). This plan is not applicable to any seasonal or endemic infectious agent or disease, such as the seasonal flu, that has not been designated by the Commissioner of Health as a highly contagious communicable disease presenting a serious risk of harm to the public health.   The websites of NYS Departments of Health and Labor should be referenced for up-to-date information on whether a designation has been put into effect, as any such designation will be prominently displayed.

1.     Purpose

The purpose of this plan is to provide information and outline the range of actions Syracuse University may take to eliminate or minimize employee exposures to airborne infectious agents in the event of a declared airborne infectious disease outbreak.  Syracuse University is not required to put a plan into effect absent such a designation by the Commissioner of Health.  This plan is subject to any additional or greater requirements arising from a declaration of a state of emergency due to an airborne infectious disease, as well as any applicable federal, state, and local standards.

Employees should report any questions or concerns with the implementation of this plan to the designated contact(s) listed in Section III of this plan.


2.    Applicability

This plan applies to all Syracuse University employees working at Syracuse University owned/operated worksites in New York State.

This includes all full- or part-time faculty and staff, individuals working for digital applications or platforms, staffing agencies, contractors or subcontractors on behalf of Syracuse University at any individual Syracuse University work site, as well as any individual delivering goods or transporting people at, to or from a Syracuse University worksite on behalf of Syracuse University, regardless of whether delivery or transport is conducted by an individual or entity that would otherwise be deemed an employer. The term does not include employees or independent contractors of the state, any political subdivision of the state, a public authority, or any other governmental agency or instrumentality.


3.   Responsibilities

This plan requires commitment to ensure compliance with all plan elements aimed at preventing the spread of infectious disease. The following Syracuse University employee(s) are designated to enforce compliance with the plan. Additionally, these employees will act as the designated contacts unless otherwise noted in this plan:

Name Title Location Phone
Andrew Gordon (or designee) Chief Human Resources Officer 640 Skytop Road 315-443-4042
Peter Sala (or designee) Vice President & Chief Campus Facilities Officer 1320 Jamesville Avenue 315-443-3517
Michael Haynie (or designee) Vice Chancellor for Strategic Initiatives and Innovation 101 Waverly Avenue 315-443-0149

4.   Minimum Exposure Controls During a Designated Outbreak

During a declared airborne infectious disease outbreak, Syracuse University will follow New York State Department of Health (DOH), Center for Disease Control (CDC) and/or local public health agency guidance, as relevant to University operations, and consider the following minimum controls:

A.     General Awareness

Syracuse University employees may be advised to:

  • Maintain physical distancing
  • Exercise coughing/sneezing etiquette
  • Wear face coverings, gloves, and personal protective equipment (PPE), as appropriate.
  • Limit what they touch
  • Stop social etiquette behaviors such as hugging and hand shaking
  • Wash hands properly and often

B.      Stay at Home Policy

Employees experiencing signs or symptoms associated with the declared airborne infectious disease outbreak, may be advised:

  • Not to come to work, and if they are at work, to leave and go home immediately.
  • Notify their supervisor and/or another University contact identified by the University following the declared airborne infectious disease outbreak, that they are experiencing signs or symptoms.
  • Contact their health care provider and follow their guidance and any guidance from New York State Department of Health, CDC, and local public health agencies regarding obtaining medical care and isolating.

Additional Stay at Home requirements and guidance may be provided by the University and communicated to employees after an airborne infectious disease is declared.

C.      Health Screening

Employees may be required to be screened for symptoms of the infectious disease daily prior to coming to work and self-monitor throughout their workday.  If an employee develops signs or symptoms, they must notify their supervisor, or a contact designated by the University that they are symptomatic.  An employee showing or reporting signs or symptoms of the declared airborne infectious disease will be advised to follow the Stay at Home Policy.

D.      Face Coverings

Employees may be required to wear face coverings throughout the workday to the greatest extent possible following CDC, NYS Department of Health and/or local public health agency recommendations and any additional University directives. Face coverings and physical distancing may be used together whenever possible.

When face coverings are required, employees will be advised that the face covering must cover the nose and mouth, and fit snugly, but comfortably, against the face. They will also be advised the face covering must be kept clean and sanitary, changed when soiled, contaminated, or damaged and be worn in a manner to not create a hazard (e.g., have features that could get caught in machinery, cause severe fogging of eyewear).

E.      Physical Distancing

Physical distancing will be followed as much as feasible. Employees may be advised to avoid unnecessary gatherings and maintain a distance of at least six feet (or as recommended by the New York State Department of Health, the CDC, and/or local public health agencies for the infectious agent) from each other. To support physical distancing the University will implement the following distancing controls, as deemed necessary and feasible:

  • Restrict or limit visitor entry
  • Limit occupancies and gatherings
  • Reconfigure workspaces
  • Install physical barriers
  • Use signage and floor markings
  • Allow remote work
  • Encourage remote meetings
  • Restrict/limit travel
  • Deliver services remotely or through curbside pickup
  • Other actions that support physical distancing

F.      Hand Hygiene

Employees may be advised to frequently wash their hands with soap and water for at least 20 seconds or use a hand sanitizer with at least 60% alcohol.  This will include washing BEFORE and AFTER:

  • Touching eyes, nose, or mouth
  • Touching mask
  • Entering and leaving a public place
  • Touching an item or surface that may be frequently touched by other people, such as door handles, tables, gas pumps, shopping carts, or electronic cashier registers/screens.

Because hand sanitizers are less effective on soiled hands, wash hands rather than using hand sanitizer when hands are soiled.

G.      Cleaning and Disinfection

See Section VI of this plan.

H.      Respiratory Etiquette

Because infectious diseases can be spread by droplets expelled from the mouth and nose, employees may be advised to exercise appropriate respiratory etiquette by covering nose and mouth when sneezing, coughing or yawning.

I.       Alternative Arrangements for Individuals with Added Risk Factors

Some employees, due to age, underlying health condition, or other factors, may be at increased risk of severe illness if infected. Employees that fall within this group and require workplace adjustments will be advised to inform their supervisor or Human Resources. Employees who require reasonable accommodations for disabilities will also be advised to contact the University’s accommodations specialists in the Office of Equal Opportunity, Inclusion, and Resolution Services (EqualOpp@syr.edu) and the Office of Diversity and Inclusion (diversity@syr.edu).


5.   Advanced Controls During Designated Outbreak

For activities where the minimum exposure controls outlined in Section IV alone will not provide sufficient protection for employees, Syracuse University will evaluate and determine if additional controls from the following hierarchy are necessary.

A.      Elimination

When feasible controls cannot provide sufficient protection for employees, Syracuse University will consider suspending or eliminating certain activities. Examples may include:

  • Limiting or eliminating in person learning
  • Limiting gatherings by location (indoors/outdoors) and scale
  • Limiting or eliminating in person recreational and/or sporting events
  • Limiting or eliminating in person dining
  • Limiting number of people on buses, trolleys, and other University controlled transportation

B.      Engineering Controls

Syracuse University will consider appropriate engineering controls that could be implemented to contain and/or remove the infectious agent, prevent the agent from being spread, or isolate the worker from the infectious agent. Examples of engineering controls that will be considered include:

1. Ventilation

  • Increasing the percentage of fresh air introduced into air handling systems
  • Avoiding air recirculation
  • Using air purifiers and/or ultraviolet light disinfection systems
  • Adding additional local ventilation
  • Opening outside windows and doors
  • Turning off demand ventilation systems
  • Operating restroom exhausts continually
  • Utilizing air filters with a rating of Minimum Efficiency Reporting Value (MERV) 13 or higher, if compatible with the HVAC system(s). If MERV–13 or higher filters are not compatible with the HVAC system(s), use filters with the highest compatible filtering efficiency for the HVAC system(s)

2. Barriers and Partitions

  • Where feasible and necessary, the University will provide and/or install cleanable barriers such as partitions and clear plastic sneeze/cough guards in service and reception areas where close contact with others is necessary and unavoidable.

3. Handwashing and Sanitizing Stations

  • Sanitizing stations will be readily available throughout the University.

4. Contactless Services

  • Where feasible and necessary, action will be taken to implement contactless services to encourage physical distancing and minimize employee interactions.

Subject to changes based on operations and circumstances surrounding the infectious disease, a non-exhaustive list of engineering controls that are anticipated to be used are listed in the following table:

Engineering Controls Utilized Location
Ventilation controls (listed above) Classrooms; dining centers; fitness centers; and other places where groups of individuals typically gather
Barriers and partitions Academic service offices (e.g., Housing and I.D. Cards); tutoring spaces; food service areas; campus retail areas; and other greeting or service points
Handwashing and sanitizing stations Every restroom on campus; and other commonly trafficked spaces such as hallways, entrances/ exits of buildings; and other greeting or service points
Contactless service Academic service offices (e.g., Housing and I.D. Cards); tutoring spaces; food service areas; campus retail areas; and other greeting or service points

 

C.       Administrative Controls

Administrative controls are policies and work rules used to prevent exposure. Syracuse University will consider the following administrative controls to help protect employees from the airborne infectious disease hazard where necessary and feasible:

  • Increasing the space between employees and students
  • Implementing additional disinfecting procedures for specific operations (i.e., food service, highly frequented public areas, buses, and trollies)
  • Providing employee training on this plan and strategies to mitigate the risk of transmission of the airborne infectious disease hazard
  • Identifying and prioritizing job functions that are essential for continuous operations
  • Cross-training employees to ensure critical operations can continue during worker absence
  • Limiting the use of shared workstations and tools. If unavoidable, clean and disinfect after each use.
  • Posting signs reminding of respiratory etiquette, masks, hand hygiene
  • Establishing pods or cohorts of staff and students to limit exposure
  • Utilizing remote learning methods
  • Limiting attendance of in person meetings
  • Hosting meetings outdoors or electronically
  • Requiring daily student health screenings
  • Consider moving to only pre-packaged food and beverage items (no communal food/drink).
  • Preventing the use of drinking fountains
  • Prohibiting eating and drinking in the work area
  • Closing break rooms
  • Rearranging traffic flow to allow for one-way walking paths
  • Providing clearly designated entrance and exits
  • Providing additional short breaks for handwashing and cleaning
  • Minimizing elevator use, post signage of limitations
  • Increasing time between classes to allow for cleaning and ventilation

Subject to changes based on operations and circumstances surrounding the infectious disease, the following nonexhaustive list of specific administrative controls are anticipated to be used:

SignageAt building entrances, exits, and common spacesEnhanced cleaning and disinfectionClassrooms, restrooms, dining halls, recreation spaces, gathering spaces and other high-traffic areas.Increased spacing/physical distancingClassrooms, dining halls, office/work areas, recreation spaces, gathering spacesRemote learning and virtual meetingsWhere feasible at University worksite(s)

Administrative Controls Utilized Locations
Signage At building entrances, exits, and common spaces
Enhanced cleaning and disinfection Classrooms, restrooms, dining halls, recreation spaces, gathering spaces and other high-traffic areas.
Increased spacing/physical distancing Classrooms, dining halls, office/work areas, recreation spaces, gathering spaces
Remote learning and virtual meetings Where feasible at University worksite(s)

 

D.      Personal Protective Equipment

Personal Protective Equipment (PPE) are devices like eye protection, face shields or masks, respirators, and gloves that protect the wearer from infection. Syracuse University will provide PPE to employees following New York State Department of Health, CDC and Occupational Safety and Health Administration recommendations as applicable, based on the hazard assessment conducted for their specific work area and job responsibilities. The PPE will be provided, used and maintained in a sanitary and reliable condition at no cost to the employee.

PPE anticipated to be used are in the following table:

PPE Required Activity Involved Location
Face masks As recommended by CDC, NYS DOH, or local health department Throughout University work site(s)
Gloves Employees performing duties or using materials where gloves are required or recommended Health center, public health screening/testing areas, food services, custodial/housekeeping, laboratories and other work site locations where duties require use.
Respirators Employees performing duties or using materials where use of a respirator is required or recommended Health center and other work site locations where duties require use.

1 The use of respiratory protection, e.g., an N95 filtering facepiece respirator, requires compliance with the OSHA Respiratory Protection Standard 29 CFR 1910.134 or temporary respiratory protection requirements OSHA allows for during the infectious disease outbreak.
2 Respirators with exhalation valves will release exhaled droplets from the respirators. Respirators are designed to protect the wearer. Surgical masks and face coverings, which are not respirators, are designed to protect others, not the wearer

E.      Exposure Control Readiness, Maintenance and Storage

The exposure controls Syracuse University anticipates using will be obtained, properly stored, and maintained so that they are ready for immediate use in the event of an infectious disease outbreak and any applicable expiration dates will be properly considered.


6.    Housekeeping During a Designated Outbreak

A.      Disinfection Methods and Schedules

Normal housekeeping duties and schedules will continue to be followed during an infectious disease outbreak, to the extent practicable and appropriate consistent with New York State Department of Health, CDC and/or local public health agencies guidance in effect at the time.

Restrooms, food service areas, and surfaces and objects that are frequently touched by multiple individuals, such as door handles, light switches, control buttons/levers, dials, water faucet handles, computers, printers, phones, or handrails will be cleaned frequently with an appropriate disinfectant. The disinfection methods and schedules selected will be based on specific workplace conditions.

The disinfecting product(s) to be used will be selected from the current list of New York State Department of Environmental Conservation and US Environmental Protection Agency approved disinfectants that are effective against many infectious agents (dec.ny.gov and epa.gov/pesticide-registration/selected-epa-registered-disinfectants). Disinfectants will be used based on NYS DOH and CDC guidance and following manufacturer guidance for methods, dilution, use, and contact time.

B.      Adjustments to Normal Cleaning Procedures

As stated above, normal custodial and housekeeping duties and schedules will continue to be followed during an infectious disease outbreak, to the extent practicable and appropriate consistent with New York State Department of Health and/or CDC guidance in effect at the time. Routine procedures will be adjusted, and additional cleaning and disinfecting implemented as deemed necessary and prudent.

Custodial and housekeeping staff may be at increased risk because they may be cleaning many potentially contaminated surfaces. Some custodial and housekeeping activities, like dry sweeping, vacuuming, and dusting, can resuspend into the air particles that are contaminated with the infectious agent. For that reason, alternative methods and/or increased levels of protection may be needed. Rather than dusting, for example, the CDC recommends cleaning surfaces with soap and water before disinfecting them. Conducting custodial and housekeeping activities during “off” hours may also reduce other workers’ exposures to the infectious agent. See cdc.gov for more guidance

Custodial and housekeeping staff will be provided with personal protective equipment (PPE) necessary based on the hazard assessment conducted for their specific work area and job responsibilities.  Best practice dictates that custodians and housekeepers should wear respiratory protection. Respirators will be provided to custodians and housekeeping staff performing duties where use of respirators is recommended/required by CDC, New York State Department of Labor and/or OSHA for protection from airborne infectious agents.  Custodial and housekeeping staff will be trained on how to use the PPE provided and on safety cleaning/housekeeping practices to follow to minimize exposure to the airborne infectious disease.

C.      Cleaning of Areas Where Infected Employees Worked

If an employee develops symptoms of the infectious disease while at work, the work area(s) they worked in for any significant period of time that day will be isolated when feasible in accordance with guidance issued by New York State Department of Health or the CDC, before cleaning and disinfecting. This delay will allow contaminated droplets to settle out of the air and the space to be ventilated.

D.      Handling Trash

As feasible, liners will be used in trash containers and trash containers will be emptied often enough to prevent overfilling. Custodial and housekeeping staff will be advised to not forcefully squeeze the air out of the trash bags before tying them closed since trash containers may contain soiled tissue or face coverings.


7.    Infection Response During a Designated Outbreak

If an actual, or suspected, declared infectious disease case occurs at the University, the following actions will be taken:

  • Instruct the sick individual to wear a face covering.
  • Instruct the sick individual to leave the University and follow New York State Department of Health, CDC or local public health agency(s) guidance.
  • Follow local and state authority guidance to inform impacted individuals.

8.    Training  and Information During Designated Outbreak

A.      Plan Awareness Information

Syracuse University will inform University employees to make them aware of this plan, including the following:

  1. Existence and location of this plan
  2. The circumstances when the plan can be activated
  3. The New York State Department of Labor airborne infectious disease standard
  4. University specific policies for declared airborne infectious diseases
  5. Employee rights under the HERO Act

B.      Plan Activation Training

When this plan is activated after the declaration of an airborne infectious disease outbreak, Syracuse University Emergency Management and Human Resources will arrange for all University employees to receive training covering all elements of this plan and the following topics:

  1. The infectious agent and the disease(s) it can cause
  2. The signs and symptoms of the disease
  3. How the disease can be spread
  4. An explanation of this Airborne Disease Exposure Prevention Plan
  5. The activities and locations at our worksite that may involve exposure to the infectious agent
  6. The use and limitations of exposure controls
  7. A review of the standard, including employee rights provided under Labor Law, Section 218-B. C.

C.      Training Format

The plan training will be provided to all full and part time University employees1:

  • Verbally in person or through telephonic, electronic, or other means
  • At no cost to the employees
  • During working hours and if training during normal work hours is not possible, employees will be compensated for the training time (with pay or time off)
  • With content and vocabulary appropriate to the employee’s educational level, literacy, and preferred language

1Note: per New York State  DOL’s model plan, the University is not required to provide this training to any individuals working for staffing agencies, contractors or subcontractors on behalf of the employer at any individual work site, as well as any individual delivering goods or transporting people at, to or from the work site on behalf of the employer, where delivery or transport is conducted by an individual or entity that would otherwise be deemed an employer  under this chapter.


9.  Plan Activation and Evaluation During a Designated Outbreak

A.      Plan Activation

When a highly contagious communicable disease is designated by the Commissioner of Health as presenting a serious risk of harm to the public health, Syracuse University will take the following actions:

  1. Review this plan and update the plan, if necessary, to ensure that it incorporates current information, guidance, and mandatory requirements issued by federal, state, or local governments related to the infectious agent of concern
  2. Finalize and promptly activate this plan
  3. Provide the verbal training required by Section VIII of this plan
  4. Make a copy of this plan available to each employee in English or in the language identified as the primary language of such employees, if requested and available. To request a copy of this plan in another language, please contact Environmental Health and Safety Services at ehss@syr.edu.
  5. Post a copy of this plan in visible and prominent locations throughout worksite(s)
  6. Ensure that a copy of this plan is accessible to employees during all work shifts

B.      Plan Evaluation

The employer will review and revise the plan periodically, upon activation of the plan, and as often as needed to keep up to date with current requirements. Changes to the plan will be approved by the Chancellor’s Executive Committee.  Plan revisions will be documented in the table below.

Date Participants Major Changes Approved By

10.    Retaliation Protections and Reporting of Any Violations

Syracuse University or any agent, or person, acting as or on behalf of a hiring entity, or the officer or agent of any entity, business, corporation, partnership, or limited liability company, shall not discriminate, threaten, retaliate against, or take adverse action against any employee for exercising their rights under this plan, including reporting conduct the employee reasonably believes in good faith violates the plan or airborne infectious disease concerns to their employer, government agencies or officials or for refusing to work where an employee reasonably believes in good faith that such work exposes him or her, other workers, or the public to an unreasonable risk of exposure, provided the employee, another employee, or representative has notified the employer verbally or in writing, including electronic communication, of the inconsistent working conditions and the employer’s failure to cure or if the employer knew or should have known of the inconsistent working conditions. Notification of a violation by an employee may be made verbally or in writing, and without limitation to format including electronic communications.

To the extent that communications between Syracuse University and an employee regarding a potential risk of exposure are in writing, they will be maintained by Syracuse University for two years after the conclusion of the designation of a high-risk disease from the Commissioner of Health, or two years after the conclusion of the Governor’s emergency declaration of a high risk disease.

Employees should contact Syracuse University Environmental Health and Safety Services at ehss@syr.edu to report violations of this plan or retaliation.