July 9, 2020    To:  JBS USA    From:  Kristen Fedak, Colorado Department of Public Health and Environment      CC:  Jill Hunsaker Ryan, Colorado Department of Public Health and Environment  Trevor Jiricek, Weld County Department of Public Health and Environment  Val Smith, Weld County Department of Public Health and Environment  Matt Bauer, Weld County Department of Public Health and Environment  Rachel Herlihy, Colorado Department of Public Health and Environment  Rachel Jervis, Colorado Department of Public Health and Environment  Amanda Metz, Colorado Department of Public Health and Environment  Kim Cordova, President, UFCW Local 7 Union  Valerie Clay, District Manager, USDA-FSIS    Re:  Follow up on strategies to reduce COVID-19 transmission at the JBS Greeley Beef Plant    Background  On May 1, 2020, Rachel Jervis and Kristen Fedak (Colorado Department of Public Health and  Environment--CDPHE) and Val Smith (Weld County Department of Public Health and  Environment--WCDPHE) visited JBS Greeley to observe the changes made by JBS since  previous visits by CDC National Institute for Occupational Safety and Health (NIOSH) on April  14 and 16, 2020; and WCDPHE visits on April 8 and 23. Key findings and recommendations  from CDC NIOSH related to reducing COVID-19 transmission were outlined in the memo dated  April 20, 2020. The plant ceased operations from April 15 through April 24, when harvesting  began again; on April 27, fabrication re-opened. A memo was sent to JBS on May 8th  documenting observations and recommendations from the May 1 visit.     On June 22, 2020, Kristen Fedak (CDPHE) returned to JBS Greeley for an unannounced visit,  accompanied by Matt Bauer, the regional epidemiologist for WCDPHE. This visit was in  response to media inquiries received by CDPHE regarding conditions at the JBS Greeley  facility and alleged concerns from employees that were received by media correspondents.  Dr. Fedak and Mr. Bauer were unaware of the specific allegations, and conducted an unbiased  and thorough inspection related to all areas and policies of the workplace. JBS management  1 (including Health & Safety manager Donald Shine and Community Health manager Neil  Timmerman) were welcoming and accommodating to provide a walk through of the full  facility and discuss practices at the facility.    Observations  In accordance with the CDC NIOSH, WCDPHE, and CDPHE recommendations that were made in  April and May, JBS has enacted additional changes to their pre-shift worker screening,  encouragement for physical distancing among employees while working and during breaks,  supplementary infection control measures, employee mask/face covering policies, and  education and company policies.    The notes that follow are regarding additional changes that have been made since the CDPHE  visit on May 1, as well as continued implementation of the policies and changes that were in  place already on May 1.    Worker Screening  ● Pre-shift screening continues to be implemented in a temporary “tunnel” of  approximately 30 feet x 10 feet constructed of structured tents, that is at the junction  of the workers’ parking lot and the entrance to the plant.   ○ The screening process remains unchanged from prior. At the entrance of the  chute, there is an employee who asks all workers to confirm they are not  experiencing fever, cough, or shortness of breath, and that they generally do  not feel ill, using a pictorial sign and thumbs up/thumbs down system to aid in  language barriers. Workers who indicate experiencing any of the symptoms or  feeling sick are sent to secondary screening; workers who are not experiencing  symptoms and feel well continue along the chute to walk through the  viewscape of an infrared camera to monitor temperature; workers with  elevated temperatures are sent to secondary screening. Secondary screening  remains unchanged from prior.   ○ Following the temperature check, all employees are handed a surgical mask  and proceed to walk past touch-free hand sanitizer stations, then continue to  walk through the tunnel between the parking lot and enter the plant as per  normal.   ○ Screening is conducted in English, but language line is available if  interpretation is needed.  ● Based on the timing of the visit, Dr. Fedak was unable to observe the screening  process during a shift change. Mr. Bauer was invited to return later in the day during  peak shift-change time.   ○ He reported to CDPHE that he observed minimal clustering of employees in the  parking lot prior to entering the screening area. He noted approximately 10 to  20 employees maximum were waiting in line to enter the screening area, but  that these employees were generally maintaining social distancing while  waiting. He observed ​a few instances where a group of 2-4 were not social 2 ● distancing while waiting to be screened, but that JBS management were also observing and requesting people to distance.   ○ Mr. Bauer reported that JBS management releases employees at the end of  their shift staggered by work groups/ areas, so they are able to manage  employees exiting over about 30-45 minutes to avoid large bottle necks. Mr.  Bauer noted some brief congregation of employees within less than 6 ft during  this end-of-shift exodus, but noted it was brief and employees were wearing  masks.  ○ Unchanged from prior, to ensure valid temperature readings from the infrared  camera, employees are prompted to remove any face covering or mask they  are wearing and look up at the camera as they walk through (by auditory  reminders from management operating the screening process, and through a  pictorial smiling face painted on the ground prior to the camera viewscape).  Mr. Bauer noted that a​bout half of the employees were not masked when approaching the temperature check. He noted that JBS management noted that they used to provide masks prior to screening to any individual who came up to the screening tunnel from the parking lot without their own mask, but found people would often throw them on the ground, since they had to be removed part way through screening for the temperature check. Management therefore changed their process to give masks after the screening is completed. It is noted that the amount of time it takes for employees to move through the full screening process is a few minutes.   Management informed us that they have continued with their policy that all visitors to  the plant are screened by the same process as employees (we were screened by this  process as well). Contractors enter through the same screening tunnel as plant  employees. Trucks/delivery drivers are screened at the two back gates where trucks  enter. We did not observe this delivery area screening process. Management informed  us that if a driver does not pass the screening, they are turned away without being  allowed to deliver their product. They noted that this has occurred on at least one  occasion in the past month.      Increasing Distancing Between Workers during Work and Breaks  ● We observed that the visual aids and rope barriers for social distancing and  unidirectional flow throughout the plant and break areas remain in place. Additionally,  some hallway areas that previously had rope barriers or ground markings to designate  directional flow and encourage “right side” passing now have hanging tarp barriers  added to further split the hallway into directional sections.  ● In the outdoor break areas, tables with individual chairs have been replaced with  picnic tables with connected bench seating. Management noted that they were  observing workers moving the table and chairs, which could result in less spacing  between individuals. The permanent, unmovable picnic tables now in place eliminate  the ability for workers to rearrange seating.  3 ● ● ● In the fabrication area of the plant, stainless steel barriers were previously installed to  separate spacing for employees where 6ft distance is not achievable. Additionally,  these barriers now have hooks for workers to hang their personal equipment and  clothing (jackets, etc.), which eliminates the need for these workers to use a common  hook area that can result in more congregation.   Management informed us that breaks are continuing to be taken in shifts based on  group, with the production line slowed to allow only 50% of the workers to maintain  work. Management stated that the change to two half-staff breaks (rather than one  break time where the line shuts down) reduces congestion in bathrooms/locker rooms  and break areas and has been favored by employees. We observed break areas during  a break, and observed sufficient availability of space for employees to distance.   Management described to us that they are currently operating at approximately 90%  capacity, which is increased from May. However, they have changed the work hours to  maintain longer time for transition between shifts A and B which allows for employees  of shift A to have more time to exit the facility post-shift without as much crowding  from employees of shift B entering; additionally, the employees from shift B have a  longer window to enter the facility, which reduces crowding at pre-screening and in  locker rooms.     Use of Masks and Other Face Coverings  ● As was occurring at our prior visit, management provides surgical masks to all  employees entering the plant. Supervisors also carry masks and employees can ask for  additional masks, if needed. On this visit, we noted an increased level of mask  availability inside the plant. We observed multiple supervisors offering masks to  individuals coming and going from break areas and bathrooms and a manager stationed  at the entrance of the indoor lunch room handing new masks to all employees  entering.  ● We observed nearly 100% compliance with wearing of face masks (majority of which  were surgical masks rather than cloth masks) throughout all parts of the plant. Within  break areas, we observed individuals wearing masks when not actively eating or  drinking.   ● Face shields are a new protection added since our previous visit, with use encouraged  while on the production floors but not required when in break areas. We observed near  100% compliance of wearing face shields while on the production floors and observed  many employees voluntarily wearing the face shield while in break areas.   ● On our last visit, management shared with us a phone app they are using to conduct  “mask-wearing audits” when they are on the harvesting and fabrication floor. The app  allows the manager to enter in the number of total employees they observe, the  number who are/are not wearing masks, and the behavior of the mask violation such  as not wearing over the nose or pulled down below the face. On this visit,  management told us that they now also have an audit app for the use of face shields  and that both apps allow the manager to not which employee was not following the  policies, so that if they become aware of specific employees who regularly are not  4 following the policies they can follow up with those individuals specifically about the  importance of wearing the PPE.     Supplementary Infection Control Measures  ● Additional hand hygiene stations have been installed since the May 1 visit. This  includes multiple permanent handwashing stations with water, soap, and paper towels  at prominent locations throughout the floor of the fabrication and harvesting areas.  There are also additional touch-free sanitizer dispensers at multiple locations along  high-traffic hallways, entrances, and doorways.   ● The plexiglass barriers to separate multi-seater tables in break areas into individual  spaces and the “clean” vs. “dirty” sign system remains in place. We observed  individuals promptly cleaning spaces after employees got up.   ● We observed that paper towel rolls and soap dispensers in the women’s locker rooms  were adequately stocked at a time between shifts. We observed a manager within the  locker room maintaining stock and offering additional supplies to coworkers as  needed.   ● Vending machines and self-serve food items in the cafeteria (e.g., salad bar) remain  closed. Water refilling stations are closed and employees are not allowed to bring  their own water bottles; throughout the plant (including within the production area)  there are now additional permanent water dispensers with individual paper cups  available.   ● Management informed us that additional UV light sanitizers had been installed  throughout the plant since May 1. THe HVAC system was renovated to include  additional UV disinfection and plasma air purification as part of the system.      Management, Policies, and other Long-Term Changes  ● Several staff members have been promoted into new management positions focused on  COVID safety and policy management. This is in addition to the existing work managers  who, as a part of their job, are responsible for ensuring COVID-related health and  safety policies are being followed on every shift/within every work area.   ○ The new role is focused solely on monitoring and ensuring compliance with  mask wearing, face shield wearing, social distancing, and sanitation policies.   ○ On each shift, there are four COVID safety managers who roam through the  various areas they are assigned to ensure compliance, hand out new surgical  masks, spot clean/sanitize high-contact areas, and offer any COVID-related  education and assistance that is needed to employees on-the-spot.   ○ We observed these managers (identifiable by the color of their hard hats),  prominently and repeatedly during our walk through of the facility, and it was  evidential that they are sufficiently available as a resource and compliance  check on all staff.   ● Workers classified as high risk/vulnerable individuals remain excluded from work;  these employees are receiving full pay. Recently, JBS begun allowing individuals who  5 ● ● ● are within the 60+ age category but without additional high-risk vulnerable status to  return to work voluntarily if cleared to do so following a physical exam by an  independent doctor. They are not requiring those age 60+ return to work.   We discussed with JBS management’s health and safety team that heat is a concern in  the plant’s harvesting area during normal summers. JBS management noted that they  are seeing concerns related to heat earlier this summer than in previous years, which  appears to be because of the additional PPE requirements.   ○ It was noted that JBS has responded to these concerns by enacting their normal  summer heat-concern related changes (increasing fans/ventilation, ensuring  access to water and breaks as needed, etc.) earlier than normal. We discussed  how current best practice recommendations for airflow increases and  modifications for COVID risk (e.g., unidirectional clean-to-dirty flow and  encouraging upward air movement as opposed to lateral) are aligned with  practices already in place within the facility for other common contaminants of  concern such as e. coli.   ○ They have also begun to make long-term structural engineering changes to  mitigate heat due to the understanding that the additional PPE is a long-term  change. For example, they redesigned a portion of the production line to move  the location of a permanent-structure hot water table to a different area of  the floor, which allows for less employees to be incidentally within the vicinity  of this hot piece of equipment.   There is a capital project plan underway to create a permanent structural change to  the facility entrance that will allow the employee screening to be conducted within  this permanent entrance.   ○ Some work has already been undertaken to design the changes and lay out the  construction area, however, full construction has not yet begun.   ○ We discussed with JBS that they have concerns over getting too far down the  line in construction of this permanent structure and then having guidance or  recommendations develop in response to the evolving covid situation and  knowledge state-wide or nationally which would require further modifications.  JBS management is balancing the need for a permanent solution for employee  screening with need to be able to implement any forthcoming  recommendations or guidance.   JBS expressed the desire to see guidance that would help them navigate the upcoming  flu season and how it may intersect with COVID risks, screening, and their employee  health overall. It was noted that all JBS employees receive 6 paid sick leave days per 6  month period standardly, in addition to accommodations that have been made to  allow additional COVID-related sick leave.   6