I. Purpose & Scope

To provide an outline of requirements to ensure safe performance of all workers.

II. Definitions

N/A

III. Policy

A. Responsibility

1. The Injury and Illness Prevention Program (IIPP) administrator, the Safety and Health Director, has the authority and responsibility for implementing the provisions of this program for MGE Underground. (1)
2. All managers and supervisors are responsible for implementing and maintaining the IIPP in their work areas and for answering worker questions about the IIPP.

B. Compliance

1. Management is responsible for ensuring that all safety and health policies and procedures are clearly communicated and understood by all employees. Managers and supervisors are expected to enforce the rules fairly and uniformly.
2. All employees are responsible for using safe work practices, for following all directives and policies and procedures, and for assisting in maintaining a safe work environment. (2)
3. Our system of ensuring that all workers comply with the rules and maintain a safe work environment include:
   • Informing workers of the provisions of our IIPP.
   • Evaluating the safety performance of all workers.
   • Recognizing employees who perform safe and healthful work practices.
   • Providing training to workers whose safety performance is deficient.
   • Disciplining workers for failure to comply with safe and healthful work practices.
4. Our Program meets minimum state and federal requirements and is reviewed and updated to ensure most current requirements are in compliance. 

C. Communication

1. We recognize that open, two-way communication between management and staff on health and safety issues is essential to an injury-free, productive workplace. The following system of communication is designed to facilitate a continuous flow of safety and health information between management and staff in a form that is readily understandable and consists of the following items:
   • New worker orientation, including a discussion of safety and health policies and procedures.
   • Review of our IIPP.
   • Workplace safety and health training programs.
   • Regularly scheduled safety meetings.
   • Effective communication of safety and health concerns between workers and supervisors, including translation where appropriate.
   • Posted or distributed safety information.
   • A system for workers to anonymously inform management about workplace hazards. (4)
   • The safety team that meets regularly, reviews results of the periodic scheduled inspections, reviews investigations of accidents and exposures and makes suggestions to management for the prevention of future incidents, reviews investigations of alleged hazardous conditions, and submits recommendations to assist in the evaluation of employee safety suggestions. (3)

D. Hazard Assessment

1. Periodic inspections to identify and evaluate workplace hazards shall be performed by the area safety representatives.
2. Periodic inspections performed according to the following schedule:
   • Weekly during job site visits.
   • When we initially established our IIPP.
   • When new substances, processes, procedures or equipment which present potential new hazards are introduced into our workplace.
   • When new, previously unidentified hazards are recognized.
   • When occupational injuries and illnesses occur.
   • Whenever workplace conditions warrant an inspection. (5)

E. Accident/Exposure Investigations

1. Procedures for investigating workplace accidents and hazardous substance exposures include:
   • Visiting the accident scene as soon as possible.
   • Interviewing injured workers and witnesses.
   • Examining the workplace for factors associated with the accident/exposure.
   • Determining the cause of the accident/exposure.
   • Taking corrective action to prevent the accident/exposure from reoccurring.
   • Record the findings and corrective actions taken. (6)

F. Hazard Correction

1. Unsafe or unhealthy work conditions, practices or procedures shall be corrected in a timely manner based on the severity of the hazards. Hazards shall be corrected according to the following procedures:
   • When observed or discovered.
   • When an imminent hazard exists that cannot be immediately abated without endangering employee(s) and/or property, we will remove all exposed workers from the area except those necessary to correct the existing condition. Workers necessary to correct the hazardous condition shall be provided with the necessary protection.
   • All such actions taken and dates they are completed shall be documented on the appropriate forms.
2. Employee are encouraged and required to participate in incident investigation root cause analysis, weekly safety meetings to cover previous incidents and corrective actions and have access to anonymous hazard reporting. 

G. Training and Instruction

1. All workers, including managers and supervisors, shall have training and instruction on general and job-specific safety and health practices. Training will cover the access and right to obtain a copy of the IIPP. Training and instruction shall be provided as follows:
   • When the IIPP is first established.
   • To all new employees when they onboard.
   • To all workers given new job assignments for which training was not previously provided.
   • Whenever new substances, processes, procedures or equipment are introduced to the workplace and represent a new hazard.
   • Whenever the employer is made aware of a new or previously unrecognized hazard.
   • To supervisors to familiarize them with the safety and health hazards to which workers under their immediate direction and control may be exposed.
   • To all workers with respect to hazards specific to each employee’s job assignment.
2. Workplace safety and health practices for all industries include, but are not limited to, the following:
   • Explanation of the employer’s IIPP and measures for reporting any unsafe conditions, work practices, injuries and when additional instruction is needed.
   • Use of appropriate clothing, including gloves, footwear, personal protective equipment.
   • Information about chemical hazards to which employees could be exposed and other hazard communication program information.
   • Availability of toilet, hand-washing and drinking water facilities.
   • Provisions for medical services and first aid, including emergency procedures.
3. In addition, we provide specific instructions to all workers regarding hazards unique to their job assignment, to the extend that such information was not already covered in other training.

H. Employee Access to the IIPP

1. Our employees – or their designated representatives – have the right to examine and receive a copy of our IIPP. This will be accomplished by providing unobstructed access through a company server or website, which allows an employee to review, print and email the current version of the program.
2. Unobstructed access means that the employee, as part of their regular work duties, predictably and routinely uses the electronic means to communicate with management or coworkers.

I. Recordkeeping

1. The following steps will be taken to implement and maintain our IIPP:
   • Records of hazard assessment inspections, including the person(s) conducting the inspection, the unsafe conditions and work practices that have been identified and the action taken to correct the identified unsafe conditions and work practices, are recorded on a hazard assessment and correction form; and
   • Documentation of safety and health training for each worker, including the worker’s name or other identified, training dates, type(s) of training, and training providers is recorded on a worker training and instruction form. We also include the records relating to worker training provided by a construction industry occupational safety and health program approved by Cal/OSHA.
   • Inspection records and training documentation will be maintained for one year.
   • OSHA Targets and goals are documented monthly and reviewed during the Safety Meeting and Management meeting for review. 

J. COVID-19 Procedures Addendum

COVID-19 is a workplace hazard and therefore is addressed under this Injury Illness Prevention Program (IIPP). “COVID-19” means the disease caused by SARS-CoV-2 (severe acute respiratory syndrome coronavirus 2).

Evaluation of COVID-19 Hazards

1. An employee is potentially exposed to COVID-19 hazards when near other persons, whether or not the employee is performing an assigned work task. MGE Underground will treat all persons as potentially infectious, regardless of symptoms, vaccination status, or negative COVID-19 test results.
2. COVID-19 will be considered a hazard specific to an employee’s job assignments and job duties if those assignments and/or duties bring the employee near other persons.
3. When determining measures to prevent COVID-19 transmission and to identify and correct COVID-19 hazards, MGE Underground will continue to review applicable orders and guidance related to COVID-19 from the state of California and the local health department with jurisdiction over the workplace and will treat COVID-19 as an airborne infectious disease.
4. COVID-19 prevention controls include remote work, physical distancing, reducing the density of people indoors, moving indoor tasks outdoors, implementing separate shifts and/or break times, restricting access to the work area, and other prevention measures, in additional to the requirements from applicable law and regulation.

Investigation of COVID-19 Cases and Illnesses

1. MGE Underground has established procedures to investigate COVID-19 cases in the workplace. These procedures include:
   • Determining the day and time the COVID-19 case was last present in the workplace.
   • Identifying the date of the positive COVID-19 test(s) and/or diagnosis, and the date the COVID-19 case first experienced symptoms, if applicable.
   • Effectively identifying and responding to individuals with COVID-19 symptoms in the workplace.
   • Encouraging employees to report COVID-19 symptoms and to stay home when feeling unwell.

Responding to COVID-19 Cases in the Workplace

1. MGE Underground has established procedures for responding to COVID-19 cases in the workplace, in accordance with applicable law. These procedures include:
   • Immediately excluding any COVID-19 cases and employees who are excluded under outbreak and major outbreak scenarios from the workplace.
   • If a local or state health official orders an employee to isolate, quarantine, or exclude themselves from work, they cannot return to work until the order is lifted or the period of isolation/quarantine is completed.
   • Employees may be excluded from the workplace if they test positive for COVID-19 or have had close contact with someone who has tested positive. MGE Underground will provide these employees with information about any COVID-19 related benefits they may be entitled to, such as legally mandated sick leave, workers’ compensation, local governmental requirements, MGE Underground’s leave policies, and leave guaranteed by contract.

A. COVID-19 Cases

1. COVID-19 cases who do not develop COVID-19 symptoms may not return to work during the infectious period.
2. Employees who have contracted COVID-19 and are experiencing symptoms should not come back to work until the earlier of two timeframes: the duration of their infectious period or 10 days after the onset of symptoms. Additionally, they must be fever-free without the use of fever-reducing medication for at least 24 hours.
3. In the workplace, anyone who has tested positive for COVID-19 must wear a face covering regardless of their vaccination status, previous infection history, or whether they are showing symptoms. They must wear the face covering for a period of 10 days starting from the date their COVID-19 symptoms began or, if they did not experience symptoms, from the date of their first positive COVID-19 test.
4. These requirements must be followed by all employees regardless of whether an employee has previously been excluded or other precautions were taken in response to an employee’s close contact or membership in an exposed group.

B. COVID-19 Close Contacts

1. MGE Underground will adhere to the current guidance from CDPH and Cal/OSHA regarding individuals who have had close contact with someone who has COVID-19, including any measures that can be taken to reduce the spread of the virus.
2. MGE Underground will also comply with the current CDPH and Cal/OSHA guidance on excluding employees who have had close contact and determining when they can return to work.
3. For employees who have had close contact with someone with COVID-19 in the workplace, MGE Underground will provide free COVID-19 tests during paid work hours, except for those who have already tested positive and recovered. Additionally, MGE Underground will provide these employees with information about the benefits described above.

C. Notice of COVID-19 cases

1. MGE Underground will provide required notices of COVID-19 cases and close contacts in accordance with the requirements of Cal/OSHA regulations, Labor Code section 6409.6 and/or any other applicable law.

D. Face Coverings

1. MGE Underground will provide face coverings and ensure they are worn by employees when required by a CDPH regulation or order, or by an order of a local public health department. When a CDPH regulation or order requires face coverings indoors, that includes spaces within vehicles. Face coverings must be clean, undamaged, and worn over the nose and mouth.
2. When employees are required to wear face coverings the following exceptions apply:
   • When an employee is alone in a room or vehicle.
   • While eating or drinking at the workplace, provided employees are at least six feet apart and, if indoors, the supply of outside or filtered air has been maximized to the extent feasible.
   • While employees are wearing respirators required by the employer and used in compliance with existing law.
   • 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. Such employees must wear an effective non-restrictive alternative, such as a face shield with a drape on the bottom, if the condition or disability permits it.
   • During 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.
3.  If an employee is not wearing a face covering pursuant to the last two exceptions above, MGE Underground will assess COVID-19 hazards and take action as necessary.
4. MGE Underground will not prevent any employee from wearing a face covering, including a respirator, when not required by law, unless it would create a safety hazard.
5. Upon request, MGE Underground will provide respirators for voluntary use to all employees who are working indoors or in vehicles with more than one person. When providing a respirator for voluntary use, MGE Underground encourages their use and will ensure that employees are provided with a respirator of the correct size and that employees are trained how to properly wear the respirator provided; how to perform a user seal check according to the manufacturer’s instructions each time a respirator is worn; and the fact that facial hair interferes with a seal.

E. Ventilation

1. For indoor work locations, MGE Underground has reviewed CDPH and Cal/OSHA guidance regarding ventilation, including “Interim Guidance for Ventilation, Filtration, and Air Quality in Indoor Environments.”
2. MGE Underground has developed, implemented, and maintained effective methods to prevent transmission of COVID-19 including one or more of the following actions to improve ventilation:
   • Maximize the supply of outside air to the extent feasible, except when the United States Environmental Protection Agency (EPA) Air Quality Index is greater than 100 for any pollutant or if opening windows or maximizing outdoor air by other means would cause a hazard to employees, for instance from excessive heat or cold.
   • In buildings and structures with mechanical ventilation, filter circulated air through filters at least as protective as Minimum Efficiency Reporting Value (MERV)-13, or the highest level of filtration efficiency compatible with the existing mechanical ventilation system.
   • Use High Efficiency Particulate Air (HEPA) filtration units in accordance with manufacturer’s recommendations in indoor areas occupied by employees for extended periods, where ventilation is inadequate to reduce the risk of COVID-19 transmission.
3. MGE Underground will ensure that employees maximize the supply of outside air in vehicles to the extent feasible. However, this will not be required if doing so would expose employees to inclement weather or cause a hazard to employees.

F. Reporting and Recordkeeping

1. MGE Underground will keep records of all COVID-19 cases, including the employee’s name, contact information, occupation, location of work, date of the last day at the workplace, and the date of the positive COVID-19 test and/or COVID-19 diagnosis.
2. MGE Underground will also maintain records of any notices required by Cal/OSHA regulations, Labor Code section 6409.6, or any other applicable law.
3. Personal identifying information of COVID-19 cases or persons with COVID-19 symptoms, as well as employee medical records, will be kept confidential except when required or allowed by law. Unredacted information on COVID-19 cases will be provided immediately upon request by the local health department with jurisdiction over the workplace, CDPH, the Division, and NIOSH, and when required by law.

COVID-19 Outbreaks and Major Outbreaks

1. If three or more employees with COVID-19 visited a worksite (field or office location) during their infectious period within a 7-day period, the following procedures will apply until there is one or fewer new COVID-19 cases detected in the group for a 14-day period (unless a CDPH regulation or order defines an outbreak differently):
   • The Company will immediately provide no-cost COVID-19 testing to all employees within the exposed group, regardless of vaccination status, during paid time. The exception to this is for returned cases and employees who were not present at the workplace during the relevant 10-day period(s).
   • The Company will then provide weekly testing to all employees in the exposed group who continue to work at the workplace.
   • Employees who had close contacts must get a negative COVID-19 test within three to five days after the close contact or follow applicable return-to-work requirements from the date of the last known close contact.
   • Employees in the exposed group, regardless of vaccination status, must wear face coverings when indoors or outdoors when they are less than six feet from another person, except when exceptions apply.
   • The Company will inform employees of their right to request and receive a respirator for voluntary use.
   • The Company will perform a review of potentially relevant COVID-19 policies, procedures, and controls immediately after the identification of three or more COVID-19 cases within an exposed group.
   • Changes will be implemented as needed to prevent further spread of COVID-19, and periodic reviews will be conducted thereafter.
   • The investigation, review, and changes will be documented and will include:
     • Investigation of new or unabated COVID-19 hazards, including the company’s leave policies and practices and whether employees are discouraged from remaining home when sick, COVID-19 testing policies, insufficient supply of outdoor air to indoor workplaces, insufficient air filtration, and insufficient physical distancing.
     • The review will be updated every 30 days in response to new information or to new or previously unrecognized COVID-19 hazards, or when otherwise necessary.
     • Any changes implemented to reduce the transmission of COVID-19 based on the investigation and review, which may include moving indoor tasks outdoors or having them performed remotely, increasing the outdoor air supply when work is done indoors, improving air filtration, increasing physical distancing to the extent feasible, requiring respiratory and other applicable controls.
   • In buildings or structures with mechanical ventilation, MGE Underground will filter recirculated air with Minimum Efficiency Reporting Value (MERV)-13 or higher efficiency filters if compatible with the ventilation system. If MERV-13 or higher filters are not compatible with the ventilation system, MGE Underground will use filters with the highest compatible filtering efficiency. MGE Underground will use High Efficiency Particulate Air (HEPA) air filtration units in accordance with manufacturers’ recommendations in indoor areas occupied by employees for extended periods, where ventilation is inadequate to reduce the risk of COVID-19 transmission.
2. If 20 or more employees with COVID-19 visited a worksite (field or office location) during their infectious period within a 30-day period, the following procedures will apply until there is one or fewer new COVID-19 cases detected in the group for a 14-day period (unless a CDPH regulation or order defines an outbreak differently):
   • All employees in the exposed group must get tested for COVID-19 twice a week, regardless of vaccination status. If the local health department recommends more frequent testing, then that must be followed. Employees who refuse to get tested will be excluded from the workplace and must follow the applicable return-to-work requirements.
   • The Company must report the outbreak to Cal/OSHA.
   • Respirators will be provided for voluntary use to employees in the exposed group, and their use will be encouraged. Employees who choose to use respirators will be trained.
   • For employees in the exposed group who do not use respirators, they must be separated from others by at least six feet of distance, except when that distance is not feasible or when people are moving around. The following methods can be used to maintain physical distance:
     • telework or remote work arrangements;
     • reducing the number of people in an area at the same time, including visitors;
     • using visual cues like signs and floor markings to indicate where employees and others should be located or their direction and path of travel;
     • staggering arrival, departure, work, and break times; and
     • adjusting work processes or procedures to allow more distance between employees.
   •  When it is not possible to maintain a distance of at least six feet, individuals must be kept as far apart as possible.

COVID-19 Prevention in Employer-Provided Housing

1. Employer-provided housing is any place or area of land, any portion of any housing accommodation is located, consisting of:
   • living quarters,
   • dwelling,
   • boardinghouse,
   • tent,
   • bunkhouse,
   • maintenance-of-way car,
   • mobile home,
   • manufactured home,
   • recreational vehicle,
   • travel trailer, or other housing accommodations.
2. Employer-provided housing includes a “labor camp” as that term is used in Title 8 of the California Code of Regulations or other regulations or codes.
3. The employer provided housing may be maintained in one or more buildings or one or more sites, including hotels and motels, and the premises upon which they are situated, or the area set aside and provided for parking of mobile homes or camping.
4. Employer-provided housing is housing is housing that is arranged for or provided by an employer, other person, or entity to their workers, and in some cases to workers and persons in their households, in connection with the workers’ employment, whether or not rent or fees are paid or collected.
5. Employer-provided housing does not include the following:
   • Housing provided for purposes of emergency response, including firefighting, rescue, and evacuation, and support activities directly aiding response such as utilities, communications, and medical operations if
     • the employer is a government entity, or
     • the housing is provided temporarily by a private employer and is necessary to conduct the emergency response operations.
   • Housing in which all residents maintained a household together prior to residing in employer-provided housing, such as family members.
   • Employees with occupational exposure as defined by the Aerosol Transmissible Disease (ATD), when covered by that standard.
   • Employer-provided housing used exclusively to house COVID-19 cases or where a housing unit houses one employee.

A. Assignment of Housing Units

1. To the extent feasible, MGE Underground will assign employee housing to cohorts that travel and work together, separate from other workers. To the extent feasible, residents who usually maintain a household together will be housed in a single housing unit without other persons.

B. Ventilation

1. In housing units, MGE Underground will maximize the quantity and supply of outdoor air and increase filtration efficiency to the highest level compatible with the existing ventilation system. If there is not a Minimum Efficiency Reporting Value (MERV)-13 or higher filter in use, portable or mounted High Efficiency Particulate Air (HEPA) filtration units will be used, to the extent feasible, in all sleeping areas.

C. Face Coverings

1. Upon request, MGE Underground will provide face coverings to all residents and provide information to the residents on when they should be used in accordance with state or local health department orders or guidance.

D. Reporting Symptoms

1. MGE Underground will encourage residents to report COVID-19 symptoms to the company.

E. COVID-19 Testing

1. MGE Underground will establish and maintain effective policies, and procedures for COVID-19 testing of residents who had a close contact or COVID-19 symptoms. These policies and procedures will be communicated to the residents.

F. COVID-19 Cases and Close Contacts

1. Isolation: Any resident who tests positive for COVID-19 will be isolated from all other residents who are not COVID-19 cases. The Company will ensure that COVID-19 cases are housed only with other COVID-19 cases, and that they have a sleeping area and bathroom that are not shared by non-COVID-19 case residents.
2. Quarantine: Any resident who has had close contact with a COVID-19 case will be quarantined from all other residents for the applicable required time period. The Company will ensure that residents who had a close contact have a private bathroom and sleeping area.

COVID-19 Prevention in Employer-Provided Transportation

1. These requirements apply to employer-provided motor vehicle transportation to and from work during the course and scope of employment, which is provided, arranged for, or secured by the employer, regardless of the travel distance or duration involved.
2. These requirements do not apply to:
   • Employees alone in a vehicle, employees taking public transportation, or vehicles in which the driver and all passengers are from the same household outside of work.
   • Employer-provided transportation necessary for the emergency response, including firefighting, rescue, and evacuation, and support activities directly aiding response such as utilities, communications, and medical operations.
   • Employees with occupational exposure as defined by the Aerosol Transmissible Disease (ATD), when covered by that standard.
3. MGE Underground will comply with the aforementioned general COVID-19 requirements and procedures within a vehicle and will respond to a COVID-19 case within a vehicle in accordance with the aforementioned requirements and procedures.
4. To the extent feasible, MGE Underground will assign transportation such that cohorts travel and work together, separate from other workers. To the extent feasible, employees who usually maintain a household together shall travel together.