test Centers for DEPARTMENT OF HEALTH & HUMAN SERVICES Centers for Disease Control and Prevention (CDC) Date: June 9, 2020 From: Mark Methner, PhD, CIH, CDC National Institute for Occupational Safety and Health Jorge Alvarez, MD, MPH, CDC Team Lead To: Doug Nicholas, Vice-President and Chief Operating Officer, Nicholas Meats, LLC Copy: Dr. Jeffrey Miller, Pennsylvania Department of State Health Services Region 1 Dr. Betsy Schroeder, Pennsylvania Public Health Veterinarian Subject: Strategies to reduce transmission of SARs-Cov-2, the virus that causes COVID-19, among workers at the Nicholas Meats Plant, Loganton, Pennsylvania Background On May 8, 2020, the Pennsylvania Department of Health (PA DOH) requested technical assistance from the Centers for Disease Control and Prevention (CDC) for an assessment of strategies to help mitigate transmission of SARs-Cov-2, the virus that causes COVID-19, among workers in six food processing and distribution facilities in northcentral, southcentral, and southeastern Pennsylvania. On May 13, 2020, a CDC field team traveled to Harrisburg, Pennsylvania. On May 14, 2020, the CDC team met with staff from the (PA DOH) and the Pennsylvania Department of Agriculture (PDA) to gain a better understanding of their current epidemiological data and results from a previous site assessment performed by PDA. The CDC team worked with PA DOH staff to determine the deployment objectives. On May 15, 2020, the team visited one of the selected sites, the Nicholas Meats, LLC beef processing facility in Loganton, PA, to evaluate existing health and safety controls implemented to prevent transmission of SARs-Cov-2 and provide recommendations to help prevent and mitigate the spread of COVID-19 between workers. The team included a physician, an industrial hygienist who specializes in occupational safety and health, an epidemiologist, an environmental health officer, and a community health behavior and education specialist/epidemiologist. The observations provided in this report are based on this site visit, and conversations with the Chief Operating Officer (COO) and plant manager. The recommendations are steps Nicholas Meats, LLC should consider implementing to address items identified at the plant. Setting and Facility Description At the time of our visit, the plant had a total of 52 documented cases of COVID-19 with one resulting in hospitalization. The plant began operating in 1993 and currently processes 600 animals per day, which management considers a normal production number. The facility is currently undergoing an expansion. The plant was running one processing shift per day (day shift) and an overnight shift that focused on sanitation, each with staggered start and end shift times. Maintenance personnel are onsite 24 hours a day, 5 days per week. There are 330 employees at this plant, including 120 working on the fabrication floor and 109 on the harvest floor. Security and medical services are provided via contract. An estimated 7-10 United States Department of Agriculture/ Food Safety Inspection Service (USDA/FSIS) staff are assigned to this plant. Languages spoken by workers include Spanish (45-50%), Haitian Creole (30-35%), and English (15-25%). The majority of the Spanish speaking workers are from Central America and the Dominican Republic. Workers usually commute by personal vehicle, but some groups choose to carpool. Average commuting times range from 30-45 minutes. This plant is not unionized. During the site visit, the COO mentioned that they are almost back to full production and have staffed up to 130% of employment capacity to mitigate production decline in case workers become ill. Plant management implemented “natural cohorting” through their hiring practices by assigning workers who live or commute together to the same shift and/or department. Our team observed the fabrication and harvesting processes operating normally with no reduction in line speed. The harvesting area is where animals are stunned, eviscerated, and processed into beef halves. The fabrication area processes the beef carcasses into final products that are boxed for shipment. We observed areas outside of processing, focusing on locations where workers might congregate, including the security building, building entry, locker rooms, laundry drop off and pick up, cafeterias, smoking areas, and livestock delivery areas. We discussed topics that include worker screening, contact tracing, communications, sick leave policies, worker and supervisor training, managing workers who are determined to be symptomatic or exposed, and the establishment of a working relationship with a local hospital. The plant layout is designed so workers from the harvest and fabrication sides do not need to use the same common areas, except for outdoor break tents designed for social distancing and smoking break areas. There are separate locker rooms for harvest and fabrication workers. Observations and Discussion This report is not intended to document every observation and intervention that occurred at the plant. It is a summary of the plant’s implementation of the CDC Interim Guidance: Meat and Poultry Processing Workers and Employers: Interim Guidance from CDC and the Occupational Safety and Health Administration (OSHA). We observed that the plant implemented several recommendations prior to our site visit. We discussed preliminary recommendations with plant managers while onsite to facilitate their timely implementation. We also discussed the observations and recommendations with PADOH partners prior to issuing this report. Visitor Screening Screening for visitors is conducted in a temporary trailer office external to the plant. Persons with a temperature equal to or greater than 99.6 F (a more protective temperature threshold the company decided to implement) are denied entry to the facility. Truck/delivery drivers are screened in a separate office away from other visitors. The screening area allows for one-way entry and exit and does not allow for congregating. There were some worn visual markers on the sidewalk leading to the screening area to maintain social distancing. Upon arrival, visitors were required to sanitize hands prior to completing a health screening questionnaire, signing the visitor log, and receiving a temperature check prior to receiving a visitor safety vest and hard hat. The screening questions include: 1) Travel outside of the country in the last 14 days; 2) COVID-19 symptoms; and 3) Close contact with a known positive COVID-19 case. Body temperature is taken by the security guard using a hand-held, non-contact Page 2 of 11 thermometer pointed at the forehead. The guard wore a disposable facemask and nitrile gloves during all screening efforts. The thermometer was not sanitized after use because it does not contact the person undergoing the screening. Worker Screening The plant has a contracted medical service provider that is onsite from 5:00 am - 8:30 am and 2:30 pm 6:30 pm to perform temperature checks of workers at the start of each shift. There is no onsite medical provider coverage for the overnight sanitation shift. The security guard conducts all screening when the medical service provider is not onsite. Workers arrive at the plant by personal vehicle or carpool. Company-sponsored transport is not offered. When workers arrive onsite, they walk down a long, uncovered sidewalk to enter the screening area. According to management, the plant adheres to the State of Pennsylvania guidelines of temperature screening and asking about symptoms before each shift. Since the team was not onsite during shift change, we did not observe the worker temperature screening. Reportedly, workers are temperature screened in the same building as visitors by a contracted medical service. Workers with a temperature equal to or greater than 99.6F or experiencing symptoms are not allowed to enter the plant. Instead, they are immediately instructed to contact their healthcare provider (HCP) and request a SARs-Cov-2 test. The facility has a relationship with a local hospital to provide emergency care. The plant does not have an onsite occupational health clinic. Workers receive disposable facemasks if they don’t have a cloth face covering and are always required to wear them while on duty. If a worker’s mask becomes soiled during a shift, they receive a replacement disposable facemask. In the screening area, there are no posters or information posted about temperature screening or types of questions asked during screening. Management has instituted a contact tracing process if a worker is absent or tardy; a supervisor interviews the employee about travel, COVID-19 symptoms, and potential exposure to COVID-19. If a worker reports that they traveled outside of the state, the supervisor automatically puts them in a potential "exposed" category. This category requires the employees to have three temperature checks (made during breaks) during their shift and one upon leaving the plant. The plant does not currently have direct communication with local public health officials. When there is a confirmed case in a worker, modified contact tracing is performed by the human resources (HR) department, who also acts as the onsite COVID-19 coordinator. They determine close contacts at work, carpooling occupants, and household members. Through this modified contact tracing, management can identify potential exposure to others. Management initiated contact tracing when cases at the plant were increasing as well as to investigate clusters. Through additional questions to absent COVID-19 positive employees, the employer can identify additional cases and/or inter-household spread. Additionally, management is actively monitoring case count by county of residence and work department. If case counts increase, they reportedly have a plan to mitigate spread. We did not review this plan and it has not been shared with PA DOH. Occupational Health and Worker Benefits If any worker is absent from work due to quarantine or COVID-19 symptoms, they are provided 80 hours full pay. Management informed us that they do not require any formal documentation for workers to receive this benefit, but they encourage workers to provide some type of documentation, if possible, for their absence by their 14th day away from work. Management expressed frustration that requiring documentation to return to work is difficult because physicians are not writing medical clearance notes due to liability issues. The plant requires a negative COVID-19 test result and two days without a fever Page 3 of 11 before an employee can return to work. The 80-hour pay is extended to employees awaiting test results as well as those on a 14-day quarantine. Increasing Distance Between Workers During Work and Breaks Adjustments to schedules have been implemented to further decrease the density of workers and promote social distancing in the cafeteria during lunch and break times. The cafeteria tables are long with plexiglass dividers extending up to 30” in height installed vertically in-between seats and down the center of the table. Workers stored lunch boxes on the seats where they expected to sit. There were no visual markers placed on the seats to indicate which seats workers should use to maximize social distancing. Management acknowledged that the microwave ovens used to heat food are a congregation point during breaks because they are clustered together and oriented in a fashion that did not support social distancing. During the visit conducted by PDA on May 11, 2020, the site assessors recommended alternating seating. Alternated seating was not observed during this visit. In fact, we observed some workers sitting next to each other and leaning back beyond the partitions to converse while eating. Additional outdoor tents equipped with 6-foot tables and four chairs each were set up to allow workers to maintain social distancing and decrease the density of the workers in the cafeteria. Use of this area required workers to heat their food in the cafeteria and walk outside the gate of the plant. There was no signage in the tent area. An additional external seating and smoking area had plexiglass partitions and was observed being cleaned between worker use. Management reported using “social distancing champions” who perform some spot monitoring of social distancing, primarily during breaks. In the harvesting area, workstations are approximately 6 feet apart. However, in the fabrication area, workstations are less than 6 feet apart with no partitions due to lack of space and the need for workers to be able to turn when cutting meat. Management expressed that there is no feasible way to modify the fabrication production line or install partitions. This facility is currently hiring. We observed the orientation room which has a reduced number of seats to promote social distancing measures. There is a PowerPoint presentation to inform new employees how to protect themselves from COVID-19 while at and outside of work. This presentation includes information about carpooling, using cloth face coverings and disposable facemasks, avoiding large gatherings, and social distancing. It was unclear if this training is also extended to all current employees on an ongoing basis. All managers are instructed to monitor social distancing and cloth face covering/disposable facemask compliance among employees. Supplementary Infection Control Measures Pump-top hand sanitizer dispensers were present throughout the plant. Hand sanitizer stations are present in high-touch areas and at the ends of hallways and stairwells. Newly installed portable no-touch handwashing stations were placed adjacent to the temporary tents. We observed minimal use of the newly installed handwashing stations during an approximately 3-hour period when we were meeting in one of the adjacent tents. There are additional cleaning staff who sanitize commonly touched surfaces five times per day. Items cleaned include: handrails, doors and door handles, lockers, and lunch tables, using a bleach mixture (1/3 cup of 11% sodium hypochlorite in 2 gallons of water) or quaternary ammonium compound (800 –1600 ppm). Manufacturer recommended contact times were followed. The plant also uses slow release chlorine Page 4 of 11 dioxide gas throughout the plant to sanitize areas. We observed cleaning and wiping of outside break tables and the cafeteria with a chlorine solution. Use of Face shields and Face Coverings During our visit, we observed most workers wearing their cloth face covering or disposable facemask correctly. However, we observed several employees improperly wearing their facemasks (e.g., mask pulled down below the nose). We observed most workers leaving for break with a disposable facemask. Some employees were observed in the parking lot removing their mask and congregating in the same van without masks during breaks. Face shields mounted on hard hats are provided to workers in positions where social distancing or the installation of partitions is not feasible. Some employees opted to wear safety glasses instead of a face shield. Workers are trained on proper donning and doffing of all PPE. All workers wear a cotton long-sleeved overcoat that extends to the knees. These coats are collected and laundered daily by an offsite laundry contractor. Educating Workers on COVID-19 Risks, Prevention, and Company Policies Informational flyers with pictures representing COVID-19 symptoms, social distancing, and hand hygiene were placed on walls and/or displayed on television monitors in common areas of the plant. Most signage was well-organized on the walls. There are no visual markers installed on the floor every 6 feet in areas of the plant (e.g., plant entrance, cafeteria walkways) to maintain social distancing. There were opportunities for more signage in some common areas, such as locker rooms or the cafeteria. There also were opportunities for increased messaging on the television monitors in the cafeteria in multiple languages. Signage posted in the cafeteria contained informational material with pictures representing COVID-19 symptoms, social distancing, and hand hygiene in English and Spanish, along with additional CDC and OSHA guidance. Haitian Creole signage was not displayed. Additionally, the HR department routinely posts the date of confirmed COVID-19 cases within the facility and also the number of positive COVID-19 cases in the county where the employee resides. Management indicated that posting information on television monitors and walls is the primary way that they communicate with workers. Conclusion The company has implemented many controls at the plant to help reduce and mitigate the spread of SARSCoV-2 among workers while in the plant. In addition, implementation of several additional controls is in progress. Additional recommendations are provided below to help management, workers, PA DOH, and strategic community partners potentially limit virus transmission among workers in the plant. The company should consult with USDA/FSIS staff at the plant to determine if proposed controls are acceptable with regards to food safety and sanitation. Recommendations The following actions are recommended to reduce the spread of COVID-19 between workers. With ongoing community transmission, COVID-19 cases among staff may continue. However, a combination of control measures with ongoing education and training could help reduce transmission in the workplace. Interim recommendations for meat and poultry processing industries are available (CDC Interim Guidance Meat and Poultry Processing Workers and Employers) and should be considered in developing or refining plant COVID-19 response plans. The recommendations in this report are specific to the Nicholas Meats, LLC beef processing plant. Plant management, PA DOH, and community partners should continue to Page 5 of 11 work together to implement recommendations and plans at the facility and among its workers to further reduce the spread of COVID-19. Hierarchy of Controls The following recommendations should be implemented according to the hierarchy of controls. Hierarchy of controls is an approach to hazard intervention which ranks the controls perceived to be most effective first, followed by those considered least effective. In most cases, the preferred approach is to eliminate a hazard or exposures, install engineering controls, and implement appropriate sanitation and cleaning to reduce worker exposure. Until such controls are in place, or if they are not adequately effective or feasible, administrative measures, personal protective equipment (PPE), and source controls may be needed. Entry Screening Screening workers for COVID-19 symptoms is a strategy to help ensure that symptomatic workers or visitors do not enter the facility. Screening policies and procedures should be developed in consultation with state and local health officials and occupational medicine professionals. Actions to improve existing screening policies and processes include: 1. Consider modifying the plexiglass barrier inside the screening trailer office so that only papers or other flat objects can be passed through. 2. Consider placing visual markers on the floor of the screening trailer office and across common areas to clearly indicate where workers should stand to maintain social distance (6 feet). 3. Consider posting large pictograms in the screening area to increase effectiveness of non-verbal communication if language or literacy challenges exist. Contact Tracing Contact tracing is important for identifying workers who have been exposed to a person with COVID-19, so they can be excluded from the workplace and monitored for symptom onset. Policies and procedures for contact tracing should be developed in consultation with state and local health officials. Engage or consult with the state and local health department to appropriately trace or follow cases in your facility to inform exclusion criteria. Management mentioned the possibility of hiring a nurse to be onsite to initiate contact tracing, serve as a liaison between the plant and the health department, and provide support with other COVID-19-related activities such as health education and health communication. Actions to improve existing policies and procedures include: 1. Continue to conduct a contact investigation for each COVID-19 case by identifying close contacts of the case while at work during the time the worker had symptoms and 2 days prior to symptom onset, as defined by the CDC Interim Guidance for Implementing Safety Practices for Critical Infrastructure Workers Who May Have Had Exposure to a Person with suspected or Confirmed COVID-19. These might include co-workers who work in the same area of the plant, take breaks together, ride to work together, or live in the same household. 2. Workers determined to be a close contact of a confirmed case may be permitted to continue working, provided they remain asymptomatic and additional precautions such as increased Page 6 of 11 temperature and symptom checks are performed for 14 days after last exposure. 3. employee develops symptoms during the day, they should be sent home immediately. If any 4. Consider posting or sharing the cumulative number of cases within the facility by date with workers to increase transparency and awareness among workers. 5. Work with state and local public health authorities to determine the appropriate role of workplace contact tracing following CDC guidance. Social Distancing In addition to everyday steps to prevent COVID-19, keeping space between individuals (social distancing) is one of the best strategies to avoid being exposed to the virus and slowing its spread. In addition to work areas, social distancing should be emphasized in all areas where workers congregate, such as break rooms, parking lots, hallways and corridors, entrance/exit areas, and locker rooms. Barriers are one method to physically separate workers in areas of the plant where social distancing is not possible. Physical barriers should not be used as a replacement for social distancing and should only be used when distancing is not possible, due to work design or task to be completed (e.g., two people needing to work together on a single carcass or trimming tasks that need to be done next to one another). Consider the following actions to improve the existing social distancing procedures in common areas: 1. Continue employing “social distancing champions” to reinforce proper social distancing and disposable facemask use in parking lots, throughout screening, in hallways, locker rooms, cafeteria and break areas, and any other spaces in your plant where workers congregate. This is especially important in areas like the locker rooms where social distancing is harder given the physical space. 2. Empower workers to provide corrective guidance to other workers about improper social distancing and cloth face covering and disposable facemask use. 3. Add more visual cues at 6-foot intervals (e.g., floor markings, wall markings, signs, traffic cones) in the building entries, screening areas, cafeterias, locker rooms, and other areas where lines or groups may form. 4. Increase the distance between seating stations in the cafeterias. Block off some seats at tables to facilitate more space between workers while eating lunch. We observed workers sitting next to each other and leaning back beyond the partitions to speak to each other while eating and also talking to one another without disposable facemasks. It might be necessary to use the social distancing champions to remind workers during lunch to adhere to the social distancing recommendations. 5. Consider conducting training online, by video, or using other methods to assure social distancing is maintained between workers while receiving annual and ad hoc training and initial orientations. 6. Consider developing and implementing a procedure for sanitizing and disinfecting face shields instead of relying on employees to do it. Also, do not allow employees to take face shields home. Instead, create a clean storage area for properly disinfected face shields. 7. Consider the following actions to improve the existing social distancing procedures in production areas: Page 7 of 11 a. Continue staggering shifts, start times, and break times as much as feasible to decrease the number of workers in locker rooms, break areas, and cafeterias at one time. If feasible, strictly prescribe the time that the next shift can come into the plant so that these workers are not congregating in the locker rooms and cafeteria for long periods of time before their shifts start. b. Install additional touchless clock in/out stations to reduce crowding and congregating at these areas. Face coverings (cloth face coverings and disposable facemasks) Source control is a term used to describe measures intended to prevent infected individuals from spreading disease. Evidence suggests that COVID-19 may be spread by workers who are not showing symptoms or asymptomatic individuals prior to being diagnosed. In the context of this COVID-19 pandemic, source control refers to the practice of wearing a mask to reduce the likelihood of transmitting the virus. Cloth face coverings or disposable facemasks are generally recommended as an addition to social distancing for source control as they help keep the person wearing the cloth face covering or disposable mask from spreading respiratory droplets when talking, sneezing, or coughing. Cloth face coverings and disposable facemasks are meant to protect other people in case workers are infected but not symptomatic. Face shields also can serve as a second level of source control when worn with cloth face coverings and disposable facemasks. Consider the following actions to improve source control: 1. Continue to enforce your policy of requiring either cloth face coverings or issuing disposable facemasks to all workers and visitors. Continue to ensure cloth face covering use meets CDC guidelines. a. Cloth face coverings and disposable facemasks should allow for breathing without restriction, not be touched after putting on to prevent transferring infected materials and be discarded and replaced when dirty or wet. b. Have replacement cloth face coverings and disposable facemasks available in case a worker’s cloth face covering or disposable facemask becomes wet or soiled. This will be important in areas where the work is wet, dirty, or hot. c. Educate workers to avoid touching their faces, including their eyes, noses, and mouths, particularly until after they have thoroughly washed their hands upon completing work and/or removing PPE. This includes adjusting their cloth face coverings or disposable facemasks once they have been donned. d. Instruct workers to talk with their supervisor if their cloth face covering or disposable facemask needs to be adjusted frequently or if it interferes with their job-specific PPE. Supervisors should work to address these issues. 2. Continue reinforcing proper cloth face covering and disposable facemask use and social distancing in parking lots, throughout screening, in hallways, locker rooms, cafeteria and break areas, and any other spaces in your plant where workers congregate. 3. Continue requiring all workers and visitors to wear disposable facemasks properly covering their nose and mouth in all areas of the plant (including break areas and locker rooms, except when Page 8 of 11 removing briefly to eat or drink). 4. Continue with the plan that all workers wear a disposable facemask and a face shield anytime they are at work, if their job task prevents the use of barriers. The face shield is being used in this plant to supplement the use of the disposable facemasks, not to replace them. a. Consider developing a facility-managed process for decontaminating face shields during and after each shift. 5. Continue to train management and supervisors to educate and encourage workers to follow these guidelines. 6. Distribute disposable facemasks in a contactless manner while allowing for control of the number of disposable facemasks distributed. For example, consider placing disposable facemasks on a table and having workers step forward one at a time while another worker oversees the process. a. The worker distributing disposable facemasks should follow appropriate social distancing and wear appropriate PPE (gloves) and a cloth face covering or disposable facemask. 7. Work with USDA/FSIS partners to communicate any new COVID-19 policies and practices being rolled out in the plant. 8. Face shields are not acceptable substitutions for eye protection (such as safety glasses) that are used for impact protection. If needed and feasible, face shields should be used in addition to the eye protection, not as a replacement for jobs requiring eye protection, as identified by the plant’s OSHA PPE hazard assessment (29 CFR 1910.132). Hand Hygiene and Sanitation Hand hygiene and sanitation (infection prevention and control) are important tools to avoid being exposed to the virus and slowing its spread. Follow and frequently monitor the CDC recommendations for cleaning and disinfection during the COVID-19 response for updates. Cleaning and disinfection of surfaces and objects that are frequently touched, especially in common areas, several times per day is an important component to control the spread of COVID-19. Consider the following actions to improve hand hygiene and sanitation: 1. Monitor and encourage employees to use external handwashing and sanitizing stations if they choose to take their break(s) outside. 2. Continue to conduct targeted and more frequent cleaning of high-touch surfaces. 3. Develop and implement a protocol for sanitizing hard hats and face shields used by workers and visitors. Training and Communication When developing training and communication materials, the plant should use current, correct messaging from a trusted source. Training should be reinforced using signage (preferably infographics or simple signs with a single, clear message) placed in strategic locations. Graphics and suggested messages are available from CDC for use on social media profiles and web pages. Print resources and communication guidance also are available from CDC and are available in multiple languages. Videos are also available Page 9 of 11 for use. Use definitions and examples to explain technical terminology and concepts used in training or communications to help improve understanding. CDC’s Interim Guidance for Businesses and Employers to Plan and Respond to COVID- 19 also provides a thorough list of topics for educating workers about how they can reduce the spread of COVID-19. Consider the following actions to improve your training and communication efforts: 1. Continue to provide COVID-19 informational signage throughout the plant. 2. Add additional signage in cafeterias, locker rooms, break areas, cattle gatehouse, and other areas where workers might congregate to remind workers about hand hygiene, social distancing, and cloth face covering and disposable facemask use in multiple languages (English, Spanish, Haitian Creole). 3. Enlarge and simplify COVID-19 signage. 4. Remove outdated signage as much as possible. “Refreshing” messages by putting up new signs (even if they have a similar message) helps make the signs stand out to workers. 5. Do not post signs in spaces that are already congested with other signs or postings, as they are hard to pick out in these settings. 6. Use more pictures/pictograms to increase the percentage of the workforce that engages with signs and messaging. 7. Ensure signage is at eye level and can be easily seen by the workers. Consider hanging signs from the ceiling so that workers do not have to look to the side to see all messaging. 8. Install additional video monitors for displaying messaging to workers throughout the day. Simple, eye catching messages that refresh frequently can be a simple way to provide information to more workers. As with signs, use pictures/pictograms and many languages to increase the percentage of the workforce that engages with this messaging. Consider developing videos in multiple languages using plant workers who speak those languages. 9. Consider alternative sources of information for communicating with your workers. You can send hyperlinks along with your messages to provide additional COVID-19 information. 10. Explore alternate means of group communication used by workers, such as Viber and WhatsApp. Engage with workers and community organizations to understand which apps and methods are most used by plant workers. 11. Increase the number of signs, ensuring use of multiple languages, regarding proper hand hygiene near hand washing stations. 12. Consider developing closed (private) worker-only Facebook or other social media pages and invite workers to follow the page. Post guidance and information on the page in a variety of languages to ensure maximum reach. 13. Develop or provide existing training and messaging (in multiple languages) for social distancing, hand hygiene, donning and doffing, cough and sneeze etiquette (even when wearing cloth face coverings or disposable facemasks), and sanitizing PPE and source controls, and messaging about Page 10 of 11 what to do if you are sick. If workers carpool, consider training in multiple languages on the risks related to carpooling and how to mitigate them. 14. Consider alternatives to traditional in-person trainings for delivery of this information (e.g., videos, phone applications). a. Develop a method to verify worker understanding and participation. b. Partner with community organizations and the local health department to distribute messaging to workers. 15. Provide training to workers, supervisors, and management whenever changes are implemented in the workplace. Refresher trainings should be provided on a regular basis. Updated information and Guidance Check back frequently on the CDC COVID-19 webpage for updated information and guidance on preventing and mitigating the spread of COVID-19 among your workers while they are at work. The company should consult with USDA/FSIS and PDA to determine if proposed controls are acceptable with regards to food safety and sanitation. Continue communicating and working with PA DOH and strategic community partners. End of Memo Page 11 of 11