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COVID-19 Safety Plan 8.17.21 Update
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August 18, 2021

COVID-19 Safety Plan


COVID-19 Prevention Program (CPP)

  1. Purpose:

The purpose of the School’s COVID-19 Prevention Program (“CPP”) is to provide employees a healthy and safe workplace consistent with the California Occupational Safety and Health Act (“Cal/OSHA”) (Lab. Code §§ 6300, et seq.) and associated regulations (8 C.C.R. § 3205).

Nothing in this CPP precludes the School from complying with federal, state, or local laws or mandates, or public health orders or guidance that may recommend or require measures that are more prescriptive and/or restrictive than those that are provided herein.

  1. Scope

Unless one of the exceptions provided below applies, this CPP shall apply to all School employees (hereinafter referred to as “employees”), including those who are “fully vaccinated”.

The following employees are exempt from coverage under the CPP: (1) Employees who are teleworking from home or a location of the employee’s choice that is not under the control of the School; (2) Employees who are working in or at a work location and do not have contact with any other individuals; and (3) Employees who because of their tasks, activities, or work location have with occupational exposure as defined by the Aerosol Transmissible Diseases (“ATD”) regulation (i.e., 8 C.C.R. § 5199).

  1. DEFINITIONS:

For the purposes of the CPP, the following definitions shall apply:

“Close contact COVID-19 exposure” means being within six (6) feet of a COVID-19 case for a cumulative total of 15 minutes or greater in any 24-hour period within or overlapping with the “high-risk exposure period” as defined here. This definition applies regardless of the use of face coverings. Employees who were wearing a respirator as required by the School and who used such respirator in compliance with Title 8 Section 5144 during contact with a COVID-19 case will be deemed not to have had close contact COVID-19 exposure.

“COVID-19” means coronavirus disease, an infectious disease caused by the severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2).

“COVID-19 case” means a person who either: (1) Has a positive COVID-19 test as defined in this section; (2) Is subject to COVID-19-related order to isolate issued by a local or state health official; (3) Has a positive COVID-19 diagnosis from a licensed healthcare provider; or (4) Has died due to COVID-19, in the determination of a local health department or per inclusion in the COVID-19 statistics of a county.

“COVID-19 hazard” means potentially infectious material that may contain SARS-CoV-2, the virus that causes COVID-19. Potentially infectious materials include airborne droplets, small particle aerosols, and airborne droplet nuclei, which most commonly result from a person or persons exhaling, talking or vocalizing, coughing, or sneezing, or from procedures performed on persons which may aerosolize saliva or respiratory tract fluids. This also includes objects or surfaces that may be contaminated with SARS-CoV-2.

“COVID-19 symptoms” means one of the following: (1) fever of 100.0 degrees Fahrenheit or higher or chills; (2) cough; (3) shortness of breath or difficulty breathing; (4) fatigue; (5) muscle or body aches; (6) headache; (7) new loss of taste or smell; (8) sore throat; (9) congestion or runny nose; (10) nausea or vomiting; or (11) diarrhea, unless a licensed health care professional determines the person’s symptoms were caused by a known condition other than COVID-19.

“COVID-19 test” means a viral test for SARS-CoV-2 that is both: (1) Approved by the United States Food and Drug Administration (“FDA”) or has an Emergency Use Authorization (“EUA”) from the FDA to diagnose current infection with the SARS-CoV-2 virus; and (2) Administered in accordance with the FDA approval or the FDA EUA as applicable.

“Exposed group” means all employees at a work location, working area, or a common area at work, where a COVID-19 case was present at any time during the high-risk exposure period. However, if the COVID-19 case visited a work location, working area, or a common area at work for less than 15 minutes during the high-risk exposure period, and all employees were wearing face coverings at the time the COVID-19 case was present, other people at the work location, working area, or common area would not constitute part of the exposed group. Common areas at work include bathrooms, walkways, hallways, aisles, break or eating areas, and waiting areas. However, places where employees momentarily pass through while everyone is wearing face coverings, without congregating, is not a work location, working area, or a common area at work.

“Face covering” means a surgical mask, a medical procedure mask, a respirator worn voluntarily, or a tightly woven fabric or non-woven material of at least two layers. A face covering has no visible holes or openings, and must cover the nose and mouth. A face covering does not include a scarf, ski mask, gaiter, balaclava, bandana, turtleneck, collar, or single layer of fabric.

“Fully vaccinated” means the School has documented that the person received, at least 14 days prior, either the second dose in a two-dose COVID-19 vaccine series or a single-dose COVID-19 vaccine. Vaccines must be FDA approved; have an emergency use authorization from the FDA; or, for persons fully vaccinated outside the United States, be listed for emergency use by the World Health Organization (WHO).

“High-risk exposure period” means the following: For COVID-19 cases who develop COVID-19 symptoms: from two (2) days before they first develop symptoms until each of the following are true: (1) it has been ten (10) days since symptoms first appeared; (2) 24 hours have passed with no fever, without the use of fever-reducing medications; and (3) symptoms have improved.  For COVID-19 cases who never develop COVID-19 symptoms: from two (2) days before until ten (10) days after the specimen for their first positive test for COVID-19 was collected.

“Respirator” means a respiratory protection device approved by the National Institute for Occupational Safety and Health (“NIOSH”) to protect the wearer from particulate matter, such as an N95 filtering facepiece respirator.

“Worksite,” for the limited purposes of COVID-19 prevention regulations only, means the building, store, facility, agricultural field, or other location where a COVID-19 case was present during the high-risk exposure period. It does not apply to buildings, floors, or other locations of the School that a COVID-19 case did not enter.

  1. Program

  1. System for Communicating with school employees

  1. Reporting COVID-19 Symptoms, Possible COVID-19 Close Contact Exposures, and Possible COVID-19 Hazards at School Worksites and Facilities

The School requires that employees immediately report to their manager or supervisor or to the COVID-19 Team (at covid19@ljcds.org) any of the following: (1) the employee’s presentation of COVID-19 symptoms; (2) the employee’s possible COVID-19 close contact exposures; (3) possible COVID-19 hazards at School worksites or facilities.

The School will not discriminate or retaliate against any employee who makes such a report.

  1. Accommodations Process for Employees

The School provides an accommodation process for employees to request an accommodation who (1)  can demonstrate that they remain at increased risk of severe illness from COVID-19 despite being fully vaccinated; or (2) can demonstrate that they are precluded from being fully vaccinated against COVID-19 due to disability, medical condition, or a sincerely held religious belief.

To request an accommodation under the School’s policy, employees may make a request with the director of human resources.

  1. COVID-19 Testing

The School possesses authority to require that employees who report to work at School worksites or facilities be tested for COVID-19. 

Where the School requires testing, the School has adopted policies and procedures that ensure the confidentiality of employees’ medical information and comply with the Confidentiality of Medical Information Act (“CMIA”). Specifically, the School will keep confidential all personal identifying information of COVID-19 cases or persons with COVID-19 symptoms, unless expressly authorized by the employee to disclose such information or as other permitted or required under the law.

  1. COVID-19 Hazards

The School will notify employees and subcontracted employees of any potential COVID-19 exposure at a School worksite or facility where a COVID-19 case and employees were present on the same day. The School will notify employees of such potential exposures within one (1) business day, in a way that does not reveal any personal identifying information of the COVID-19 case.

The School will also notify employees of cleaning and disinfecting measures the School is undertaking in order to ensure the health and safety of the School worksite or facility where the potential exposure occurred.

  1. identification and evaluation of covid-19 hazards at school worksites and facilities

  1. Screening Employees for COVID-19 Symptoms

The School possesses authority to require that employees self-screen for COVID-19 symptoms.

The School provides that employees will self-screen for COVID-19 symptoms prior to reporting to any School worksite or facility.

  1. Responding to Employees with COVID-19 Symptoms

Should an employee present COVID-19 symptoms during a self-screen, the employee must remain at or return to their home or place of residence and not report to work until such time as the employee satisfies the minimum criteria in order to return to work (as discussed in Section IV.J. of this CPP).

The School will advise employees of any leaves to which they may be entitled during this self-quarantine period, including, but not limited to COVID-19 Supplemental Paid Sick Leave (“SPSL”).

Further, the School has adopted policies and procedures that will ensure the confidentiality of employees and comply with the CMIA, and the School will not disclose to other employees the fact that the employees presented COVID-19 symptoms.

  1. School’s Response to COVID-19 Cases

In the event that a School employee tests positive for COVID-19 or is diagnosed with COVID-19 by a healthcare provider, the School will instruct the employee to remain at or return to their home or place of residence and not report to work until such time as the employee satisfies the minimum criteria to return to work (as discussed in Section IV.J. of this CPP).  

The School will advise the employee of any leaves to which they may be entitled during this self-isolation period, including, but not limited to SPSL.

The School shall comply with all reporting and recording obligations as required under the law, including, but not limited to, reporting the COVID-19 case to the following individuals and entities as required based on the individual circumstances: (1) The local health department; (2) Cal/OSHA; (3) Employees who were present at a School worksite or facility when a COVID-19 case was present; (4) Employee organizations that represent employees at the School worksite or facility; (4) Employers of any subcontracted employees who were present at the School worksite or facility; and (5) The School’s workers’ compensation plan administrator.

If possible, the School will interview the COVID-19 case(s) in order to ascertain the nature and circumstances of any contact that the employee(s) had or may have had with other employees during the high-risk exposure period. If the School determines that there were any close contact COVID-19 exposures, the School will instruct those employees who are unvaccinated to remain at their home or place of residence and not report to work until such time as the employees satisfy the minimum criteria to return to work (as discussed in Section IV.J. of this CPP).

The School has adopted policies and procedures to promote the confidentiality of employees and comply with the CMIA. Specifically, the School will not disclose to other employees, except for those who need to know, the fact that the employee(s) tested positive for or were diagnosed with COVID-19. Further, the School will keep confidential all personal identifying information of COVID-19 cases or persons, unless expressly authorized by the employees to disclose such information or as other permitted or required under the law.  

  1. Workplace-Specific Identification of COVID-19 Hazards

The School will periodically conduct workplace-specific assessments of all interactions, areas, activities, processes, equipment, and materials that could potentially expose employees to COVID-19 hazards.

As part of this process, the School identified places (e.g., work locations, work areas, and common areas) and times when employees and individuals congregate or come in contact with one another, regardless of whether employees are performing an assigned work task or not, including, for example, during meetings or trainings, in and around entrances, bathrooms, hallways, aisles, walkways, elevators, break or eating areas, cool-down areas, and waiting areas.

The School will provide notice of any such potential workplace exposure to all persons at School worksites and facilities, including employees, employees of other entities, members of the public, customers or clients, and independent contractors. The School considered how employees and other persons enter, leave, and travel through School worksites and facilities, in addition to addressing employees’ stationary workspaces or workstations.

As part of this process, the School treated all persons, regardless of symptoms or negative COVID-19 test results, as potentially infectious.

  1. Maximization of Outdoor Air and Air Filtration

For indoor School worksites and facilities, the School evaluates how to maximize the ventilation of outdoor air; provide the highest level of filtration efficiency compatible with the worksites and facilities’ existing ventilation systems; and whether the use of portable or mounted High Efficiency Particulate Air (“HEPA”) filtration units, or other air cleaning systems, would reduce the risk of COVID-19 transmission.

  1. Compliance with Applicable State and Local Health Orders

The School monitors applicable orders and guidance from the State of California and the local health department related to COVID-19 hazards and prevention.

The School shall comply with all applicable orders and guidance from the State of California and the local health department.

  1. Evaluation of Existing COVID-19 Prevention Controls and Adoption of Additional Controls

Periodically, the School evaluates existing COVID-19 prevention controls at the workplace and assesses whether different and/or additional controls may be needed.

This includes evaluation of controls related to the correction of COVID-19 hazards, physical distancing, face coverings, engineering controls, administrative controls, and personal protective equipment (PPE) (as discussed at Section VI, subsections D, and F-H of this CPP).

  1. Periodic Inspections

The School will conduct periodic inspections of its worksites and facilities as needed to identify unhealthy conditions, work practices, and work procedures related to COVID-19 and to ensure compliance with the School’s COVID-19 policies and procedures, including, but not limited to this CPP.

  1. investigating and responding to covid-19 cases at school worksites and facilities

  1. Procedure to Investigate COVID-19 Cases

The School developed a procedure for investigating COVID-19 cases in the workplace, which provides for the following: (1) requesting information from employees regarding COVID-19 cases; (2) contact tracing of employees who may have had a close contact COVID-19 exposure; (3) requesting COVID-19 test results from employees who may have had a close contact COVID-19 exposure; (4) requesting information from employees regarding the presentation of COVID-19 symptoms; and (5) identifying and recording all COVID-19 cases. 

  1. Response to COVID-19 Cases

As provided above at Section IV.B.3., in the event that an employee tests positive for COVID-19 or is diagnosed with COVID-19 by a health care provider, the School will instruct the employee to remain at or return to their home or place of residence and not report to work until such time as the employee satisfies the minimum criteria to return to work (as discussed in Section IV.J. of this CPP).

  1. Contact Tracing

If possible, the School will interview the COVID-19 case(s) in order to ascertain the following information: (1) the date on which the employee(s) tested positive, if asymptomatic, or the date on which the employee(s) first presented COVID-19 symptoms, if symptomatic; (2) the COVID-19 case(s) recent work history, including the day and time they were last present at a School worksite or facility; and (3) the nature and circumstances of the COVID-19 case(s)’ contact with other employees during the high-risk exposure period, including whether any such contact qualifies as a close contact COVID-19 exposure.

If the School determines that there was or were any close contact COVID-19 exposures, the School will instruct those employees to remain at their home or place of residence and not report to work until such time as the employees satisfy the minimum criteria to return to work (as discussed in Section IV.J. of this CPP). Further, the School will instruct those employees to be tested for COVID-19, and that the School will provide for such testing during paid time, as discussed in subsection c. below. 

  1. Reporting the Potential Exposure to Other Employees

The School shall comply with all reporting and recording obligations as required under the law, including, but not limited to, reporting the COVID-19 case to the individuals and entities described below.

Within one (1) business day of the time the School knew or should have known of a COVID-19 case, the School will give written notice of a potential workplace exposure to the following individuals: (1) All employees at the worksite or facility during the COVID-19 case’s high-risk exposure period; (2) Independent contractors at the worksite or facility during the COVID-19 case’s high-risk exposure period; and (3) Other employers at the worksite or facility during the COVID-19 case’s high-risk exposure period. The School will provide notice by either personal service, email, or text message.

The School’s notice(s) will not reveal any personal identifying information of the COVID-19 case. The notice will include information about the School’s disinfection plan.

  1. Offer of Free COVID-19 Testing Following a Close Contact COVID-19 Exposure

The School makes COVID-19 testing available at no cost to employees and to all employees who had a close contact COVID-19 exposure at a School worksite or facility. The School will offer employees COVID-19 testing during paid time, whether during the employee’s regular work schedule or otherwise, and will provide compensation for the time that the employee spends waiting for and being tested.

The School will also provide free COVID-19 testing if needed to the following two (2) classes of employees: (1) Employees who were fully vaccinated before the close contact COVID-19 exposure and who do not have COVID-19 symptoms, and (2) COVID-19 cases who returned to work pursuant to the criteria set forth in Section K of this CPP and have remained free of COVID-19 symptoms, for 90 days after the initial onset of COVID-19 symptoms or, for COVID-19 cases who never developed symptoms, for 90 days after the first positive test.

  1. Leave and Compensation Benefits for Close Contact Exposures

The School provides employees that had a close contact COVID-19 exposure with information regarding COVID-19-related benefits to which the employees may be entitled under applicable federal, state, or local law, the School’s own leave policies, and leave guaranteed by contract. These benefits include, but are not limited to, SPSL.

The School will continue and maintain these employees’ earnings, seniority, and all other employee rights and benefits, including the employees’ right to their former job status, as if the employees had not been removed from their jobs.

The School may require that these employees use School-provided employee sick leave benefits for this purpose and consider benefit payments from public sources in determining how to maintain earnings, rights and benefits, where permitted by law and when not covered by workers’ compensation.

  1. Investigation to Determine Whether Workplace Conditions Contributed to COVID-19 Exposure

The School will conduct an investigation in order to determine whether any workplace conditions could have contributed to the risk of COVID-19 exposure and what could be done to reduce exposure to such COVID-19 hazards, if any.

  1. Confidential Medical Information

The School will protect the confidentiality of the COVID-19 cases, and will not disclose to other employees the fact that the employees tested positive for or were diagnosed with COVID-19.

The School will keep confidential all personal identifying information of COVID-19 cases unless expressly authorized by the employees to disclose such information or as other permitted or required under the law.

  1. Correction of covid-19 hazards at school worksites and facilities

The School will implement effective policies and/or procedures for correcting unsafe or unhealthy conditions, work practices, policies and procedures in a timely manner based on the severity of the hazard.

This includes, but is not limited to, implementing controls and/or policies and procedures in response to the evaluations conducted related to the identification and evaluation of COVID-19 hazards and investigating and responding to COVID-19 cases in the workplace. This also includes implementing controls related to physical distancing, face coverings, engineering controls, administrative controls, and personal protective equipment (PPE).

  1. training and instruction of employees

  1. COVID-19 Symptoms

The School provides employees training and instruction on COVID-19 symptoms, including advising employees of COVID-19 symptoms, which include the following: (1) fever of 100.0 degrees Fahrenheit or higher or chills; (2) cough; (3) shortness of breath or difficulty breathing; (4) fatigue; (5) muscle or body aches; (6) headache; (7) new loss of taste or smell; (8) sore throat; (9) congestion or runny nose; (10) nausea or vomiting; or (11) diarrhea, unless a licensed health care professional determines the person’s symptoms were caused by a known condition other than COVID-19.

The School monitors and adheres to guidance issued by the CDC concerning COVID-19 symptoms, including guidance provided at the following web address: https://www.cdc.gov/coronavirus/2019-ncov/symptoms-testing/symptoms.html. The School will advise employees in the event that the CDC revises the symptoms that its associates with COVID-19.

In addition to providing training and instruction on COVID-19 symptoms, the School provides information and instruction on the importance of employees not coming to work if they have any COVID-19 symptoms. As discussed below, the School provides information on paid leaves to which employees may be entitled if they are experiencing a COVID-19 symptom and would like to be tested for COVID-19.

  1. COVID-19 Vaccinations

The School provides employees information and instruction on the fact that COVID-19 vaccines are effective at both preventing the transmission of the virus that causes COVID-19 and preventing serious illness or death, and how employees may receive paid leave for reasons related to COVID-19 vaccinations.

As discussed below, the School provides information on paid leaves to which employees may be entitled in order for them to be vaccinated and in the event that they experience any illness or adverse effects as a result of such vaccination.  

  1. School’s COVID-19 Policies and Procedures

The School provides regular updates to employees on the School’s policies and procedures adopted in order to prevent COVID-19 hazards at School worksites and facilities, how such policies and procedures are intended to protect the health and safety of employees and School worksites and facilities, and how employees may participate in the identification and evaluation of COVID-19 hazards in order to make such worksites and facilities healthier and safer for themselves and others.

  1. COVID-19-Related Benefits

The School advises and provides updates to employees on the leaves to which employees may be entitled under applicable federal, state, or local laws as well as the School’s own leave policies. Paid leave benefits include, but are not limited to, SPSL.

Further, when employees require leave in order to receive a COVID-19 test or to be vaccinated or are directed not to report to work by the School for reasons related to the presentation of COVID-19 symptoms, a COVID-19 case, close contact COVID-19 exposure, the School will advise the employees of the leaves to which the employees may be entitled for that specific reason.

  1. Spread and Transmission of the Virus that Causes COVID-19

The School advises and provides updates to employees about the known spread and transmission of COVID-19. The School specifically advises employees of the following: (1) that COVID-19 is an infectious respiratory disease; (2) that the virus that causes COVID-19 can be spread through the air when an infectious person talks or vocalizes, sneezes, coughs, or exhales; (3) that particles containing the virus can travel more than six (6) feet, especially indoors, so physical distancing must be combined with other controls, including face coverings and hand hygiene, including hand washing, in order to be effective; (4) that COVID-19 may be transmitted when a person touches a contaminated object and then touches their eyes, nose, or mouth, although that is less common; and (5) that an infectious person may have present no COVID-19 symptoms or be pre-symptomatic.

  1. Hand Hygiene, and Face Coverings and Respirators

The School advises employees of the importance of physical distancing, face coverings, and hand hygiene, including hand washing, and instructs employees that the combination of physical distancing, face coverings, increased ventilation indoors, and respiratory protection make such preventative measures most effective.

With respect to hand hygiene, the School provides employees information regarding the importance of frequent hand washing, that hand washing is most effective when soap and water are used and the employees washes for at least 20 seconds. The School instructs employees to use hand sanitizer when employees do not have immediate access to a hand washing facility (i.e., a sink) and that hand sanitizer will not be effective if the employee’s hands are soiled.

With respect to face coverings and respirators, the School provides employees information on the benefits of face coverings, both to themselves and to others. The School also provides employees instructions on the proper use of face coverings and the differences between face coverings and respirators.

The School will provide certain employees respirators for their use in certain circumstances, including to individuals who are not fully vaccinated, who are working indoors or in a vehicle with more than one person, and who request the devices for their use at work. At such time as the School provides respirators to employees for their use, it will provide such employees training on the proper use of such respirators, including, but not limited to, the method by which employees may check the seal of such respirator in conformance with the manufacturer’s instructions.  

The School will provide training on the conditions under which face coverings must be worn at the workplace. Employees can request face coverings from the School at no cost to the employee and can wear them at work, regardless of vaccination status, without fear of retaliation.

  1. face coverings

  1. Face Covering Requirement

  1. Vaccinated

The protocols for fully vaccinated faculty and staff who have submitted their vaccination documentation are as follows:  

Fully vaccinated individuals should report and get tested if they are experiencing COVID-19 symptoms. Email covid19@ljcds.org.

  1. Unvaccinated

The protocols for faculty and staff who have not been vaccinated or who have not submitted vaccination documentation are as follows:

Must report if experiencing symptoms or exposure to COVID-19 by emailing covid19@ljcds.org.

The School adheres to the most restrictive or prescriptive federal and state public health orders, mandates, laws, and regulations regarding face coverings, including those from the CDPH, Cal/OSHA, and the local health department, applicable to the School, and will provide face coverings to employees and enforce the wearing of face coverings by employees when so required.

The School requires that employees’ face coverings be clean and undamaged. The School allows employees to use face shields to supplement, not supplant, face coverings.

  1. Limited Exceptions

The School provides for the following exceptions to the face coverings requirement:

1.        When an employee is alone in a room (e.g., alone in an office or another space with walls that extend from the floor to the ceiling and a door that may be closed in order to close the space to others) or vehicle

2.        While eating and drinking at the workplace

3.        Employees wearing respirators required by the School and being used in compliance with the regulatory requirements for the use of such respirators

4.        Employees who cannot wear face coverings due to a medical or mental health condition or disability, or who are hearing-impaired or communicating with a hearing-impaired person

5.        Specific tasks which cannot feasibly be performed with a face covering. This exception is limited to the time period in which such tasks are actually being performed

  1. Required Use of Effective Non-Restrictive Alternative for Employees Exempted from Face Covering Requirement

The School requires that its employees who are exempted from wearing face coverings due to a medical condition, mental health condition, or disability wear an effective non-restrictive alternative, such as a face shield with a drape on the bottom, if their condition or disability permits it.

  1. Physical Distancing Required if Employee Is Not Wearing Face Covering or Non-Restrictive Alternative

The School requires that any employees not wearing a face covering due to either exception number 4 or 5, identified in Subsection 2 above, and not wearing a face shield with a drape or other effective alternative as described in Subsection 3 above, shall remain at least six (6) feet apart from all other persons unless the unmasked employees are tested at least weekly for COVID-19 during paid time and at no cost to the employee or are fully vaccinated.

In situations where a face covering is otherwise required, face coverings must be worn, and the exceptions to face coverings contained in this section no longer apply.

However, the School does not use COVID-19 testing as an alternative to face coverings when face coverings are otherwise required by this section.

  1. Prohibition on Preventing Employees from Wearing Face Covering

The School does not prevent any employee from wearing a face covering when wearing a face covering is not required by this section, unless wearing a face covering would create a safety hazard, such as interfering with the safe operation of equipment.

  1. Communication to Non-Employees Regarding Face Covering Requirement

The School posts signage to inform non-employees of the School’s requirements concerning the use of face coverings at School worksites and facilities.

  1. other engineering controls, administrative controls and personal protective equipment (ppe)

  1. Maximization of Outdoor Air

As provided above at Section IV.B.5., for indoor School worksites and facilities, the School evaluated how to maximize the quantity of outdoor air.

Further, for School worksites and facilities with mechanical or natural ventilation, or both, the School maximizes the quantity of outside air provided to the extent feasible, except when the Environmental Protection Agency (“EPA”) Air Quality Index (“AQI”) is greater than 100 for any pollutant or if opening windows or letting in outdoor air by other means would cause a hazard to employees, for instance from excessive heat or cold.

  1. Cleaning Procedures

The School undertakes the following cleaning measures:

  1. Identify and regularly clean frequently touched surfaces and objects, such as doorknobs, elevator buttons, equipment, tools, handrails, handles, controls, phone, headsets, bathroom surfaces, and steering wheels;
  2. Inform employees and authorized employee representatives of the School’s cleaning and disinfection protocols, including the planned frequency and scope of cleaning and disinfection; and

3.         Clean areas, material, and equipment used by a COVID-19 case during the high-risk exposure period and disinfection if the area, material, or equipment is indoors and will be used by another employee within 24 hours of the COVID-19 case.

Further, the School requires that cleaning must be done in a manner that does not create a hazard to employees or subcontracted employees who do the cleaning and disinfecting.

  1. Evaluation of Handwashing Facilities

In order to protect employees, the School evaluates its handwashing facilities in order to determine the need for additional facilities, encourage and allow time for employee handwashing, and provide employees with an effective hand sanitizer.

The School encourages employees to wash their hands with soap and water for at least 20 seconds each time.

The School does not provide hand sanitizers with methyl alcohol.

  1. Personal Protective Equipment (PPE)

a.             Evaluation of the Need for PPE

The School evaluates the need for PPE in order to prevent employees from being exposed to COVID-19 hazards.

The School evaluates the need for PPE, such as gloves, goggles, and face shields, to prevent exposure to COVID-19 hazards and provide such PPE as needed.

b.             Provision of PPE When Necessary

The School provides PPE, including, but not limited to, face coverings, respirators, gloves, goggles, and face shields, to and for employees who require such equipment in order to perform their job duties in a healthy and safe manner, including where employees are exposed to procedures that may aerosolize potentially infectious material such as saliva or respiratory tract fluids.

Upon request, the School shall provide respirators to employees for voluntary use to all employees who are not fully vaccinated and who are working indoors or in vehicles with more than one person. Whenever the School makes respirators available for voluntary use, the School will provide employees with a respirator of the correct size and will provide such employees training on the proper use of such respirators, including, but not limited, the method by which employees may check the seal of such respirator in conformance with the manufacturer’s instructions, as discussed in Section IV.E.6.

  1. Testing of Symptomatic Employees Who Are Not Fully Vaccinated

The School makes COVID-19 testing available at no cost to employees with COVID-19 symptoms who are not fully vaccinated. This testing will be made available during the employees’ paid time.

  1. Reporting, recordkeeping and access

  1. Reporting COVID-19 Cases To the Local Health Department

The School reports COVID-19 cases and COVID-19 outbreaks at School worksites and facilities to the local health department. Further, the School provides any related information requested by the local health department.

  1. Maintenance of Records Related To the Adoption of the CPP

The School maintains records of the steps it has taken to implement the provisions described in this CPP.

  1. Availability of the CPP for Inspection

The School will make this written CPP available to employees and employee organizations at School worksites or facilities. Further, the School will make this written CPP available to Cal/OSHA representatives immediately upon request.

  1. Records Related to COVID-19 Cases

The School keeps a record of and tracks all COVID-19 cases with the following information: (1) employee’s name; (2) contact information; (3) occupation; (4) location where the employee worked: (5) the date of the last day at the workplace; and (6) the date of a positive COVID-19 test.

The School keeps employees’ medical information confidential.

  1. exclusion of covid-19 cases and employees who had a close contact covid-19 exposure

  1. Exclusion of COVID-19 Cases from School Worksites and Facilities

The School ensures that COVID-19 cases are excluded from School worksites and facilities until the employee satisfies the minimum return to work criteria, as provided in Section IV.J.

  1. Exclusion of Employees with Close Contact COVID-19 Exposures from School Worksites and Facilities

The School takes steps to exclude employees who had a close contact COVID-19 exposure from School worksites and facilities until the employee satisfies the minimum return to work criteria, as provided in Section IV.J.

The School may allow the following employees to continue to report to School worksites and facilities: (1) Employees who were fully vaccinated before the close contact COVID-19 exposure and who have not developed COVID-19 symptoms since such exposure; and (2) COVID-19 cases who returned to work pursuant to the return to work criteria, as provided in Section IV.J. and have remained free of COVID-19 symptoms for 90 days after the initial onset of COVID-19 symptoms, or, for COVID-19 cases who never developed COVID-19 symptoms, for 90 days after the first positive COVID-19 test.

  1. Provision of Benefits to Employees Excluded from Work as a Result of a Positive COVID-19 Test or Diagnosis or a Close Contact COVID-19 Exposure

  1. Employees Who Are Able To Telework During Isolation or Quarantine Period

The School allows employees who are able to telework to telework during the isolation or quarantine period. The School will provide these employees their normal compensation for the work that they perform for the School during the isolation or quarantine period.

The School continues and maintains such an employee's earnings, wages, seniority, and all other employee rights and benefits, including the employee's right to their former job status, as if the employee had not been removed from their job.

b.        Employees Who Are Unable To Telework During Isolation or Quarantine Period

The following employees are not entitled to the benefits described below: (1) Employees for whom the School can demonstrate that the close contact COVID-19 exposure was not work-related; and (2) Employees who received disability payments or were covered by workers’ compensation and received temporary disability. Such employees may still use paid sick leave for the purpose of receiving compensation during the isolation or quarantine period if they elect to do so. 

For other employees, the School requires that employees who are unable to telework, but are otherwise able and available to work, the School may use paid sick leave available to the employee, including but not limited to SPSL, for the purpose of continuing and maintaining the employee’s earnings during the isolation or quarantine period. If the employee has exhausted their SPSL entitlement, the School may use the employee’s paid sick leave in order to continue and maintain the employee’s earnings during the isolation or quarantine period.

Employees retain their entitlement to elect not to use other earned or accrued paid leave during this time. The School may provide such employees who are unable to telework, but who do not have any paid sick leave available, paid administrative leave in order to receive compensation during the isolation or quarantine period.

For all employees who are subject to an isolation or quarantine because of a COVID-19 case or a close contact COVID-19 exposure, the School will maintain the employees’ seniority and all other employee rights and benefits, including the employees’ right to their former job status, during the isolation or quarantine period.

  1. Adherence with Laws, Policies, and/or Agreements Providing Excluded Employees Greater Protections

The obligations set forth in this section do not limit any other applicable law or School policy that provides employees with greater protections or benefits.

  1. Provision of Information Concerning Benefits to Excluded Employees

At the time of exclusion, the School provides the excluded employees the information on paid leave benefits to which the employees may be entitled under applicable federal, state, or local laws.

This includes, but is not limited to, COVID-19 Supplemental Paid Sick Leave (“SPSL”) (under Labor Code section 248.2), any paid leave benefits available under workers’ compensation law, Labor Code sections 3212.86 through 3212.88, the School’s own leave policies, and leave guaranteed by contract.

  1. return to work criteria

  1. Minimum Criteria to Return to Work for Symptomatic COVID-19 Cases

The School requires that a COVID-19 case with one or more COVID-19 symptoms remain at their home or place of residence and not report to any School worksite or facility until they satisfy each of the following conditions: (1) At least 24 hours have passed since a fever of 100.0 degrees Fahrenheit or higher has resolved without the use of fever-reducing medications; (2) COVID-19 symptoms have improved; and (3) At least 10 days have passed since COVID-19 symptoms first appeared.

  1. Minimum Criteria to Return to Work for Asymptomatic COVID-19 Cases

School policy requires that COVID-19 cases who tested positive but never developed COVID-19 symptoms not report to any School worksite or facility until a minimum of 10 days have passed since the date of specimen collection of their first positive COVID-19 test.

  1. COVID-19 Testing Not Required in Order To Return to Work

In accordance with CDC guidance concerning symptom-based strategies for the discontinuation of isolation, once an employee has satisfied the criteria to return to work, as provided in this Section, the School will not require that the employee submit to a COVID-19 test or produce a negative COVID-19 test result, in order to return to School worksites or facilities.

  1. Minimum Criteria To Return To Work for Close Contacts

  1. Asymptomatic Employees

Asymptomatic employees that are fully vaccinated are not subject to quarantine.  For unvaccinated employees, an employee who had a close contact COVID-19 exposure, but never developed COVID-19 symptoms may return to School worksites or facilities 10 days following the last known close contact COVID-19 exposure.

  1. Symptomatic Employees

An employee who had a close contact COVID-19 exposure and developed one or more COVID-19 symptom may not return to School worksites or facilities until they satisfy each of the following conditions: (1) At least 24 hours have passed since a fever of 100.0 degrees Fahrenheit or higher has resolved without the use of fever-reducing medications; (2) COVID-19 symptoms have improved; and (3) At least 10 days have passed since COVID-19 symptoms first appeared.

An employee who had a close contact COVID-19 exposure and developed one or more COVID-19 symptom may return earlier if they each of the following conditions: (1) The employee tested negative for COVID-19 using a polymerase chain reaction (“PCR”) COVID-19 test with specimen taken after the onset of symptoms; (2) At least 14 days have passed since the last known close contact COVID-19 exposure; and (3) The employee has been symptom-free for at least 24 hours, without using fever reducing medications.

  1. Minimum Criteria to Return to Work for Employees Directed to Self-Quarantine or Isolate by a State or Local Health Official

If employees are subject to an isolation or quarantine order issued by a state or local health official, the School requires that the employees not report to any School worksite or facility until the period of isolation or quarantine is completed or the order is lifted.

If the relevant order did not specify a definite isolation or quarantine period, then the School will require that employees isolate or quarantine according to the applicable periods and criteria provided for in this Section or as otherwise instructed by the School.


2021 COVID-19 School Guidance Checklist

Name of Local Educational Agency or Equivalent: La Jolla Country Day School

Number of schools: 1

Enrollment: 1,135

Superintendent (or equivalent) Name: Gary Krahn, Ph.D.

Address: 9490 Genesee Avenue, La Jolla, CA 92037

Phone Number: 858-453-3440

Email: gkrahn@ljcds.org 

Date of proposed reopening: Already open

County: San Diego

Current Tier: Yellow

Type of LEA: Independent (Private) School

Grade Level: Tiny Torreys, JK, K, 1, 2, 3, 4, 5, 6, 7, 8, 9,10,11,12

This form and any applicable attachments should be posted publicly on the website of the local educational agency (or equivalent) prior to reopening or if an LEA or equivalent has already opened for in-person instruction. For those in the Purple Tier, materials must additionally be submitted to your local health officer (LHO), local County Office of Education, and the State School Safety Team prior to reopening.

The email address for submission to the State School Safety for All Team for LEAs in Purple Tier is:

K12csp@cdph.ca.gov

LEAs or equivalent in Counties with a case rate >=25/100,000 individuals can submit materials but cannot re-open a school until the county is below 25 cases per 100,000 (adjusted rate) for 5 consecutive days.

For Local Educational Agencies (LEAs or equivalent) in ALL TIERS:

I, Gary Krahn, post to the website of the local educational agency (or equivalent) the COVID Safety Plan, which consists of two elements: the COVID-19 Prevention Program (CPP), pursuant to CalOSHA requirements, and this CDPH COVID-19 Guidance Checklist and accompanying documents, which satisfies requirements for the safe reopening of schools per CDPH Guidance on Schools. For those seeking to open while in the Purple Tier, these plans have also been submitted to the local health officer (LHO) and the State School Safety Team.

I confirm that reopening plan(s) address the following, consistent with guidance from the California Department of Public Health and the local health department:

Stable group structures (where applicable): How students and staff will be kept in stable groups with fixed membership that stay together for all activities (e.g., instruction, lunch, recess) and minimize/avoid contact with other groups or individuals who are not part of the stable group.

Please provide specific information regarding:

How many students and staff will be in each planned stable, group structure? (If planning more than one type of group, what is the minimum and maximum number of students and staff in the groups?)

Early Childhood Center

The Early Childhood Center (ECC) follows the current state and county guidelines for preschool aged children. The Tiny Torrey and Jr. Kindergarten programs have up to 14 children with 3 grade-level teachers.  Physical education coaches, Spanish, and art teachers will also be available to students.  Following a bubble model, each class keeps to their assigned locations, and does not interact with any other ECC cohorts. Teachers and staff remain solely with their assigned cohort.

Lower School

Lower School students Grades K-4 will be grouped in grade-level cohorts.  These cohorts will be grouped together each day they are at school to minimize the mixing of student groups throughout the school day. Cohorts will consist of 16-18 students in kindergarten–Grade 2 and 17-20 students in Grades 3 and 4.

 Each cohort will have approximately 6 faculty members who will interact with the students.

Middle School

Middle School students are in Grades 5-6 cohorts and Grades 7-8 cohorts. Enrollment and staff dedicated to each cohort are:

Upper School

Grades 9-12 is a single cohort consisting of 488 students and up to 60 faculty.

Lunch

SAGE Dining Services® remains committed to providing a variety of quality and healthy options that accommodate allergies and dietary restrictions. SAGE is committed to offering three types of entrées: hot foods, cold sandwiches and salads. No pre-ordering necessary.

Students will have lunch in their respective dining area (Lower School Pavilion located on the playground and the main Pavilion for Middle and Upper School).  

Students have the option to bring their own lunch to campus. LJCDS discourages food sharing.

Please note: Food deliveries (e.g., DoorDash, GrubHub, UberEats) are not allowed during regular school hours, but are permitted after school hours from 3:30pm-4:30pm to the table located adjacent to the guard house in the Genesee lot. Students will have lunch in the dining area.

SAGE has implemented additional inspections and precautionary measures of the facility and food preparations to ensure the health and safety of all community members. Visit the LJCDS/SAGE website for more information. Questions? Contact SAGE Food Service Director Saeed Samad at 858-453-3440 ex.187 or ssamad@sagedining.com.

If you have departmentalized classes, how will you organize staff and students in stable groups?

All departmental and elective courses follow the same cohort model as described above to minimize cross grade-level mixing.

If you have electives, how will you prevent or minimize in-person contact for members of different stable groups?

All departmental and elective courses follow the same cohort model as described above to minimize cross grade-level mixing.

Entrance, Egress, and Movement Within the School: How movement of students, staff, and parents will be managed to avoid close contact and/or mixing of cohorts.

Students in the Early Childhood Center will remain in their assigned location throughout the day.  All other students and staff will be allowed to move about the campus subject to the masking rules identified in the next section.

Parents are allowed on campus outside in open space or outside the classroom in open space during drop-off and pickup. Visits will be limited to no later than 8:30 a.m. during drop-off and between 2:45–3:30 p.m. during pickup. Parent volunteers are also welcome but are required to be vaccinated. Upon volunteering, parents must submit proof and get prior approval before coming to campus to volunteer 

Face Coverings and Other Essential Protective Gear: How CDPH’s face covering requirements will be satisfied and enforced for staff and students.

Masks are required in all indoor spaces when students are present. Masks are required for Lower School and Middle School students outdoors. For Upper School students, masks are optional outside when physical distancing is possible. Unvaccinated individuals are highly encouraged to wear a mask outside.

The protocols for fully vaccinated faculty and staff who have submitted their vaccination documentation are as follows:  

The protocols for faculty and staff who have not been vaccinated or who have not submitted vaccination documentation are as follows:

The School provides for the following exceptions to the face coverings requirement:

1.        When an employee is alone in a room (e.g., alone in an office or another space with walls that extend from the floor to the ceiling and a door that may be closed in order to close the space to others) or vehicle;

2.        While eating and drinking.

3.        Employees wearing respirators required by the School and being used in compliance with the regulatory requirements for the use of such respirators.

4.        Employees who cannot wear face coverings due to a medical or mental health condition or disability, or who are hearing-impaired or communicating with a hearing-impaired person.

If an individual does not have a face mask, one will be provided by the school. Cloth face coverings must be made out of breathable cloth materials, cover the entire nose and mouth area, and be secured to the head with elastic ties or straps.  Cloth face coverings are meant to protect other people in case the wearer is unknowingly infected.  Cloth face coverings are not surgical face masks, respirators, or personal protective equipment. However, the School will provide some employees with surgical face masks, respirators, or personal protective equipment dependent (“PPE”) on the employee’s job duties. Acceptable masks include cloth masks, disposable non-surgical grade masks and KN95 respirators. Unacceptable facial coverings include bandanas, gaiters, or similar loose face coverings, and masks with an exhalation valve are not allowed as they do not protect others by preventing the dispersion of aerosols.

Disposable masks are also available upon request.

All members of our community are aware of the public health guidelines, where face coverings are properly fitted over the nose and mouth, they prevent the wearer from dispersing potentially infectious aerosols and droplets into the environment where they can contaminate surfaces or be inhaled by others.

Health Screenings for Students and Staff: How students and staff will be screened for symptoms of COVID-19 and how ill students or staff will be separated from others and sent home immediately.

Students, faculty, and staff are expected to self-monitor and conduct a wellness screening each morning before coming on campus. They are not allowed on campus or to attend in-person campus events or activities when not feeling well.  If symptoms arise during the school day, individuals will be sent home. Symptomatic individuals may return to campus after symptoms have improved, typically 24 hours fever-free without the use of fever-reducing medicine and a negative PCR test.

Scientific research and experience from around the country demonstrate that when both parties are wearing facemasks appropriately at the time of a school-based exposure to COVID-19, in-school transmission is unlikely and students can safely continue in-person learning.  When students remain in school after exposure because the student and the individual with COVID-19 were wearing masks appropriately, this is called modified quarantine. Modified quarantine involves a period of time during which students may continue in-person instruction but should refrain from all extracurricular activities at school, including sports, and activities within the community setting. Testing during modified quarantine provides an additional layer of safety and monitoring.  Modified quarantine allows for less missed days of school and supports in-person education.  Students that meet the criteria for modified quarantine must undergo twice weekly testing (each test at least 3 days apart) and not participate in any program or activity outside of the regular school day, on campus or in a community setting, through Day 10.  The application of a modified quarantine will be determined by our campus COVID-19 task force.

Healthy Hygiene Practices: The availability of handwashing stations and hand sanitizer, and how their safe and appropriate use will be promoted and incorporated into routines for staff and students. 

There are 225 touchless hand sanitizing stations, 12 touchless water dispensers and 137 handwashing stations across campus. All bathrooms and kitchen areas follow the physical distancing guidelines and not all urinals, stalls or sinks are in use. We have physically blocked these off to ensure proper physical distancing and lowered occupancy.

Identification and Tracing of Contacts: Actions that staff will take when there is a confirmed case. Confirm that the school(s) have designated staff persons to support contact tracing, such as creation and submission of lists of exposed students and staff to the local health department and notification of exposed persons. Each school must designate a person for the local health department to contact about COVID-19.

A trained LJCDS staff member will reach out to the individual who contracted COVID-19 to identify other individuals they may have been in close contact with. In the event of infection, contact tracing will occur, CDC protocols and local health guidance will be exercised and close contacts will be quarantined or subject to modified quarantine (students only) as discussed above.

The purpose of contact tracing is to promote public health efforts. The names of positive people will not be disclosed to the individuals with whom they may have had close contacts unless they are household members.

Physical Distancing: How space and routines will be arranged to allow for physical distancing of students and staff.

The CDPH no longer mandates minimum physical distancing when other mitigation strategies (e.g., masking) are fully implemented. However, we will continue to encourage physical distancing.

Please provide the planned maximum and minimum distance between students in classrooms.

Maximum: N/A.

Minimum: N/A.

Staff Training and Family Education: How staff will be trained and families will be educated on the application and enforcement of the plan.

Family Resources located here: www.ljcds.org/return-to-campus for more information for the entire community.

Staff training and information can be found at: https://www.ljcds.org/employee-return-to-work-plan

Testing of Staff: How school officials will ensure that students and staff who have symptoms of COVID-19 or have been exposed to someone with COVID-19 will be rapidly tested and what instructions they will be given while waiting for test results. Below, please describe any planned periodic asymptomatic staff testing cadence.

Asymptomatic Testing Program

La Jolla Country Day School and UC San Diego EXCITE Lab have partnered to implement a reoccurring PCR testing program during the school year for staff on a one-week cycle. The PCR test detects the virus’s genetic material through a nasal swab. The test can be self-administered under the watchful eye of our trained team on individuals 13 years of age and older. The results will be processed within 24-48 hours.

EXCITE is co-led by UC San Diego faculty members Rob Knight, Ph.D., founding director of the Center for Microbiome Innovation and professor of Pediatrics and Computer Science & Engineering, Gene Yeo, Ph.D., MBA, professor of Cellular and Molecular Medicine and co-director of the Bioinformatics and Systems Biology Graduate Program, and Louise Laurent, M.D., Ph.D., professor and vice-chair for translational research in Obstetrics, Gynecology and Reproductive Sciences.

Staff will be tested weekly, but can opt out of asymptomatic testing by providing a copy of their COVID-19 vaccination card.

Symptomatic Testing

The school will continue to test staff who are symptomatic with the rapid antigen test, which can provide results within 15 minutes or the PCR test.

Testing of Students: How school officials will ensure that students who have symptoms of COVID-19 or have been exposed to someone withCOVID-19 will be rapidly tested and what instructions they will be given while waiting for test results. Below, please describe any planned periodic asymptomatic student testing cadence.

Planned student testing cadence for asymptomatic testing will be every two weeks. All students must either participate in on campus testing or submit a negative test result from a test administered by an outside provider during the week they are scheduled.. Students can opt out of asymptomatic testing by providing a copy of their COVID-19 vaccination card.

The school will continue to test students who are symptomatic with the rapid antigen test, which can provide results within 15 minutes or the PCR test.

 Identification and Reporting of Cases: At all times, reporting of confirmed positive and suspected cases in students, staff and employees will be consistent with Reporting Requirements or local public health guidance.

The School continues to access the necessary COVID-19 protocols for the upcoming 2021/2022 school year.  Once the protocols are determined, this checklist will be updated at that time. .

Communication Plans: How the superintendent will communicate with students, staff, and parents about cases and exposures at the school, consistent with privacy requirements such as FERPA and HIPAA.

In addition to county, state, and local health department reporting, confirmed positive cases of employees are reported to our worker’s compensation insurance company, Berkshire Hathaway Homestate Companies (BHHC).  Work-related cases are noted and also reported to Cal/OSHA, as required. 

Consultation: (For schools not previously open) Please confirm consultation with the following groups

☐Labor Organization

Name of Organization(s) and Date(s) Consulted:

Name: ________________________________

Date: ________________________________

☐Parent and Community Organizations

Name of Organization(s) and Date(s) Consulted:

Name: ________________________________

Date: ________________________________

If no labor organization represents staff at the school, please describe the process for consultation with school staff:

N/A

For Local Educational Agencies (LEAs or equivalent) in PURPLE: 

☐ Local Health Officer Approval: The Local Health Officer, for (state County) _______________________________________. County has certified and approved the CRP on this date: __________________. If more than 7 business days have passed since the submission without input from the LHO, the CRP shall be deemed approved.

Additional Resources:

Guidance on Schools

Safe Schools for All Hub