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OCOM’s Exposure Risk Assessment
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Exposure Risk Assessment Form

Employer Name: Oregon College of Oriental Medicine

Completed by (name): Amber Appleton, Director of Human Resources; Phil Lundberg, VP of Operations.

Date: 12/02/2020

Contact Information: 503.253.3443 x 106

Employee job classifications evaluated in this assessment:

Administrative and support staff

Faculty - clinical and didactic

Teaching Assistants

Work Study

  1. Can employees telework or otherwise work remotely? How are employees encouraged or empowered to use those distance work options to reduce COVID-19 transmission at the workplace?

The majority of staff who are employed with OCOM are able to work remotely. For those who physically must be on campus, schedules will be arranged so as to limit the number of people in a given physical area at one time. No one should share an office simultaneously. Where office space is shared, all surfaces should be cleaned with proper supplies and techniques at the beginning and end of each shift. Employees should clean door knobs and other surfaces that may be touched by others frequently during the day.

  1. What are the anticipated working distances between employees? How might those physical working distances change during non-routine work activities?

Every effort has been made to allow at least six feet separation between employees and students. In the practical skills classrooms, treatment tables have been spaced so nearly twice that distance is maintained. Where a distance of six feet or more cannot be maintained, either plexiglass barriers have been put up, or masks and face shields are required.

  1. What is the anticipated working distance between employees and other individuals? How might those working distances change during non-routine work activities?

        See the response to Question 2.

  1. How have the workplace or employee job duties, or both, been modified to provide at least 6-feet of physical distancing between all individuals?

Everyone who can perform their work remotely is encouraged to do so. Any course that can be taught online is being taught in that format. Employees that share workspaces and must be on campus are scheduled so as to not be in the space at the same time. Signs on the floor have been afixed throughout the campus to indicate the minimum required six foot separation.

  1. How are employees and other individuals at the workplace notified where and when masks, face coverings, or face shields are required? How is this policy enforced and clearly communicated to employees and other individuals?

Masks are required of everyone who is on campus at all times unless they are alone in a private office with a door that can be closed. Face shields are required in addition to masks where six feet cannot be maintained and/or in all instances of direct patient contact. Notification of these policies was done by repeated email; repeated employee, faculty, and student town halls; and by reminder signage. Faculty and clinical supervisors are responsible for enforcing this policy. They are empowered to exclude a patient or student from class or clinic if they don’t comply. Supervisors are empowered to have an employee removed from campus if they don’t comply.

  1. How have employees been informed about the workplace policy and procedures related to reporting COVID-19 symptoms? How might employees who are identified for quarantine or isolation as a result of medical removal under this rule be provided with an opportunity to work at home, if such work is available and they are well enough to do so?

Everyone who enters the campus is screened for symptoms and for possible COVID-19 exposure. Individuals who fail the screening are not allowed on campus. If symptoms appear after the person has entered campus, they will be asked to leave and encouraged to make contact with their primary care provider. If they are able to do the essential elements of their job remotely and if they are well enough to do so, that is encouraged.

  1. How have engineering controls such as ventilation (whether portable air filtration units equipped with HEPA filters, airborne infection isolation rooms, local exhaust ventilation, or general building HVAC systems) and physical barriers been used to minimize employees exposure to COVID-19?

The HVAC system is a state of the art LEED certified system with multiple redundant filters. It receives preventive maintenance quarterly to ensure it is operating appropriately. Appropriately. The system has been set to maximize the number and volume of air exchanges. Each treatment room has its own individual HVAC unit. Additionally, separate HEPA filtering machines have been placed in each classroom and in the common areas where students have to pass on the way to or from class.

  1. How have administrative controls (such as foot-traffic control) been used to minimize employee exposure to COVID-19

In order to minimize employee exposure to COVID-19 we have implemented a number of administrative controls: maximizing remote working; scheduling employees in the same work so they are not on campus at the same time; limiting the number of people who can use an elevator at any time; changing use of stairs so that, except in an emergency one set of stairs is for going up and one for going down; changing the use of entrances so that everyone has to come into the building through the front doors and be screened before they can progress in the building; placing plexiglass in areas where six feet separation cannot be maintained between an employee and those they serve (e.g.cashier); closing off water in drinking fountains, except for filling bottles; changing kitchen areas so that employees and students have to bring their own utensils and plates; setting up classrooms to maintain six feet separation in lecture classes and nearly twice that in practical skills classes where students have to move around a treatment table; and placing floor markings throughout the campus to indicate where to stand to maintain six feet separation.

  1. What is the procedure or policy for employees to report workplace hazards related to COVID-19? How are these hazard reporting procedures or policies communicated to employees?

Employees and students are encouraged to report workplace hazards to HR or to members of the COVID-19 OHSA Task Force. These reporting procedures and policies were communicated originally by distributing the written COVID-19 Response Plan, by holding a series of mandatory town hall meetings where a PowerPoint presentation about the plan was presented; and by sending out to all community members a copy of that PowerPoint. Since that initial rollout, the plan has been reinforced by periodic emails from the President and from the COVID-19 Task Force and by repeated discussion in staff meetings.

  1. How are sanitation measures related to COVID-19 implemented in the workplace? How have these sanitation practices been explained to employees and other individuals at the workplace?

Proper sanitation is maintained by having the building professionally cleaned every night and by having employees cleaning their personal work areas every day and by interns cleaning the treatment rooms after each patient visit. Further, there are signs around the campus about the importance of frequent hand washing or use of hand sanitizer. These practices are explained through the use of videos for which mandatory viewing was required. Cleaning of treatment rooms and classrooms is monitored by faculty members or clinical supervisors.

  1. How have the industry-specific or activity-specific COVID-19 requirements in Appendix A of this rule and applicable guidance from the Oregon Health Authority been implemented for workers? How will periodic updates to such Oregon Health Authority guidance documents incorporated into the workplace on an on-going basis?

The industry and activity specific COVID-19 requirements from the Oregon Health Authority (OHA) were built into the original response plan. The Task Force meets monthly at which time it considers whether modifications to the plan are needed to stay in compliance with the OHA and OSHA  requirements. Where more urgent action is required (to be responsive to an Executive Order by the Governor for instance) the Task Force Co-chairs meet with the President, review the new requirements and determine if immediate action is needed or if it can wait for the whole Task Force to consider action at its next meeting.

  1. In settings where the workers of multiple employers work in the same space or share equipment or common areas, how are the physical distancing; mask, face covering, or face shield requirements; and sanitation measures required under this rule communicated to and coordinated between all employers and their affected employees?

        This does not apply to Oregon College of Oriental Medicine.

  1. How can the employer implement appropriate controls that provide layered protection from COVID-19 hazards and that minimize, to the degree possible, reliances on individual employee training and behavior for their efficacy?

The COVID-19 Task Force included representation from all of OCOM’s constituencies. Next, after a written plan and a PowerPoint were developed, all members of our community were trained and received copies of both the plan and PowerPoint. Training videos were developed and all members of the community were trained on aspects of the plan that were pertinent to their roles. Finally, the Task Force meets monthly and responds to issues and or changes in guidance that have arisen.