Hamel | COVID-19 Operation Plan

April 2020

(Revised May 11, 2020)

This plan provides guidance to Hamel employees through a widespread outbreak of illness or disease in order to maintain the continuity of our business and remain a viable entity during a potential crisis. The elements of this plan will help to minimize the impact of this pandemic on the company and provide guidance for a safe workplace for all our employees and subcontractors. This plan temporarily replaces normal operations as enacted by Hamel. This pandemic operation plan is meant to supplement normal operations and/or other specialized planning required for operations during a pandemic that has affected the normal operations and construction practices.

I. Background

COMPANY – Founded in 1988, Hamel has earned a reputation for excellence in multifamily construction and renovation having completed and delivered over 35,000 units of workforce, affordable, market-rate, adaptive reuse, senior living, historic, and mixed-use housing, including over 6,000 resident-in-place renovations. With offices in Elkridge, Maryland, and Washington, DC, Hamel's diverse team is comprised of over 150 employees. Hamel’s personnel run and operate on average 20 to 25 construction projects concurrently in the Maryland, Virginia, and District of Columbia region.

COVID-19 – Coronavirus disease 2019 (COVID-19) is an infectious disease caused by severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2). The disease was first identified in December 2019 in Wuhan, the capital of China's Hubei province, and has since spread globally, resulting in the ongoing 2019–20 coronavirus pandemic.

A pandemic is a global outbreak of disease. Pandemics happen when a new virus emerges to infect people and can spread between people sustainably. Because there is little to no pre-existing immunity against the new virus, it spreads worldwide.

On March 11, 2020, the COVID-19 outbreak was characterized as a pandemic by the World Health Organization. The United States declared the COVID-19 pandemic a National Emergency on March 13, 2020.

II. Safe Work

At Hamel, Safety is the top priority for all our workers and subcontractors across our projects. This is particularly critical during the current pandemic as the construction industry is fortunate to be an essential business. This plan follows and adopts available guidelines from the U.S. Center for Disease Control and Prevention (“CDC”) and the Occupational Safety and Health Administration (“OSHA”) guidance on COVID-19.

III. COVID-19 Response Team

Hamel has established a COVID-19 Response Team to oversee the response, to anticipate impacts to projects and operations, and to assist with developing strategies to minimize the effects of the pandemic.

The COVID-19 Response Team is comprised of the following:

IV. Responsibilities

A. Responsibilities of Managers and Supervisors

All managers and supervisors must:

1. Be familiar with this plan and be ready to answer questions from employees.
2. Set a good example by following this plan at all times. This involves practicing good personal hygiene and jobsite safety practices to prevent the spread of the virus.
3. Encourage the same behavior from all employees.
4. Evaluate and implement project-specific COVID-19 steps as agreed to and developed with clients, management companies, etc.
5. Provide fact-based information only and promptly report issues to the COVID-19 Response Team.

B. Responsibilities of Employees and Workers

Hamel asks every employee to help with prevention efforts while at work. In order to minimize the spread of COVID-19 at jobsites, everyone (employees and all workers alike) must be vigilant of their surroundings and take personal responsibility. As set forth below, Hamel has instituted various housekeeping, social distancing, and other best practices at our jobsites. These are to be followed by all workers.

Everyone’s health and well-being are of utmost importance. If someone is sick, feeling sick, caring for someone who is sick, or has been in direct and prolonged contact with someone who is sick, we urge you to stay home, notify your supervisor and follow the recommendations of the CDC and health professionals. If anyone is concerned with the health of themselves or others, we recommend that they refer to the CDC Risk Assessment tools, the CDC Apple COVID-19 Screening App, or their supervisor for guidance.

1. OSHA and the CDC have provided the following control and preventative guidance for all workers, regardless of exposure risk:
   1. Frequently wash your hands with soap and water for at least 20 When soap and running water are unavailable, use an alcohol-based hand rub with at least 60% alcohol.
   2. Avoid touching your eyes, nose, or mouth with unwashed hands.
   3. Follow appropriate respiratory etiquette, which includes covering your face for coughs and sneezes.
   4. Avoid close contact with people who are sick.
2. In addition, employees and workers must familiarize themselves with the symptoms of COVID-19, which include the following:
   1. Coughing;
   2. Fever;
   3. Loss of sense of smell or taste;
   4. Shortness of breath, difficulty breathing; and
   5. Early symptoms such as chills, body aches, sore throat, headache, diarrhea, nausea/vomiting, and runny nose.

If you develop a fever and symptoms of respiratory illness, such as cough or shortness of breath, DO NOT GO TO WORK and call your supervisor and healthcare provider right away. Additionally, if you believe that you have come into prolonged, close contact with someone showing these symptoms, call your supervisor and healthcare provider right away.

V. Information and Communication

With the constant changes related to the COVID-19 pandemic, continuous communication and the distribution of pertinent information is critical between all levels at Hamel. The following process is to ensure that communication is accurate and efficiently distributed:

A. Information shared on Hamel’s behalf is to be approved by the COVID-19 Response Team, before it is sent to owners/clients, Hamel’s offices, Hamel’s projects, and subcontractors.

B. Use reputable sources for information such as:

1. Centers for Disease Control (cdc.gov)
2. Occupational Safety and Health Administration (osha.gov)
3. Local health departments / organizations related to specific projects

C. If requests for information or action regarding COVID-19 are made by owners/clients, the request must be submitted to the COVID-19 Response Team prior to replying to the owner/client.

D. Certain worker information – anything regarding medical evaluations, testing, treatment, or status is protected by Federal Law and must be treated as confidential. Only approved personnel are to collect and disseminate this information – no information may be shared with anyone that is not approved to receive it.

VI. Jobsite Protective Measures

Hamel has instituted the following protective measures at all project sites:

A. General Safety Policies and Rules

1. EVERYONE MUST WEAR FACE COVERING AT ALL TIMES.
2. EVERYONE IS STRONGLY ENCOURAGED TO WEAR PROTECTIVE EYEWEAR AT ALL TIMES.
3. JOBSITE TRAILER MUST REMAIN LOCKED AT ALL TIMES AND VISITORS ARE PROHIBITED.
4. MEETINGS AT JOBSITE TRAILERS ARE PROHIBITED.
5. Any employee/contractor/visitor showing symptoms of COVID-19 will be asked to leave the jobsite and return home.
6. Safety/Subcontractor meetings will be by telephone or other virtual means, as feasible. If safety/subcontractor meetings are conducted in-person, they will be held outdoors or large open area, attendance will be collected verbally and the superintendent will sign-in each attendee. Attendance will not be tracked through passed-around sign-in sheets or mobile devices. ALL MEETINGS WILL BE LIMITED TO 10 people and participants must remain at least six (6) feet apart.
7. Employees must avoid physical contact with others and direct employees/contractors/visitors to increase personal space to at least six (6) feet, where possible.
8. For jobsite trailer use, only necessary employees should enter the trailers and all employees MUST maintain six (6) feet social distancing while inside the trailers.
9. All in-person meetings will be limited. To the extent possible, meetings will be conducted by virtual means (i.e. MS Teams, Zoom, WebEx, etc.).
10. Employees will be encouraged to stagger breaks and lunches, if practicable, to reduce the size of any group at any one time to less than ten (10) people.
11. Employees and workers must follow the CDC and OSHA guidelines for constant hand washing.
12. Where access to running water for hand washing may be impracticable, a Handwashing Station will be provided. In addition, whenever available, alcohol-based hand sanitizers and/or wipes will be provided.
13. Tools MUST NOT be shared.
14. Due to limited availability and the need to prioritize N95 respirators to First Responders, the use of N95 masks will be limited to when required by OSHA guidelines. Additionally, whenever possible the use of N95 masks will be reduced by using engineering and work practice controls to minimize dust. Such controls include the use of water delivery and dust collection systems, as well as limiting exposure time.
15. Employees and all workers are encouraged to minimize or eliminate ridesharing. While in a vehicle, employees and workers must ensure adequate ventilation and wear a face covering.
16. If practicable, employees should use/drive the same truck or piece of equipment every shift.
17. In lieu of using a common source of drinking water, such as a cooler, employees should use individual water bottles.
18. Jobsites will be staged for access and flow to minimize worker’s contact by implementing One-Way stairwells, creating “Entry Only” and “Exit Only” points, etc.
19. Lunch breaks will be staggered to reduce the congregation of workers and larger spaces, where possible, will be provided for lunch breaks.

B. Workers entering an Occupied Building

1. When employees perform construction and maintenance activities within occupied homes, office buildings, and other establishments, these work locations present unique hazards with regards to COVID-19 exposures. All such workers should evaluate the specific hazards when determining best practices related to COVID-19. Workers MUST NOT enter any of these spaces while they are actively occupied.
2. During this work, employees must sanitize the work areas upon arrival, throughout the workday, and immediately before departure.

C. Jobsite Signage

1. COVID-19 posters as provided and/or recommended by CDC, OSHA, local health authorities, and developed by Hamel shall be posted around jobsite access points, outside of jobsite trailer and at building entry points.
2. Whenever possible, all signage will be provided in English and Spanish along with Notices as they might be required from time to time due to policy updates.

D. Activities Separation and Planning

The intent is for each subcontractor crew to remain separated from the other trades in accordance with their planned activities. The flow of the people to and from the work area must include the organization of work crews so that they do not remain together. We recommend social distancing by maintaining six (6) feet of separation for any activity. This includes:

1. A “No Congregation” policy is in effect; individuals must implement social distancing by maintaining a minimum distance of 6-feet from other individuals
2. Anywhere a line can form (bathrooms, elevators, material hoists, trash chutes, etc.), display visible markers on the ground to show required spacing between people (painted lines, tape on the floor, etc.).
3. Entering the jobsite. Where feasible, staggered starts and controlled entry gates to ensure separation best practices are in place.
4. Exiting the site. Where feasible, staggered quit times and controlled entry gates to ensure separation best practices are in place.
5. Working on site. Plan work to eliminate cross-contamination of crews as much as possible while maintaining the 6-foot distancing requirements.
6. When practicable, designate stairwells as up only or down only to avoid passing employees within the 6-foot distancing requirements.
7. When practicable, when walking in hallways employees should step into units to avoid passing within the 6-foot distancing requirements.
8. Taking breaks. Employees will be encouraged to stagger breaks and lunches, if practicable, to reduce the size of any group at any one time to less than ten (10) people.
9. Trade/subcontractor trailers, job boxes, and established work areas are to be separated by at least 6’ of each other.
10. Workers are not to share tools. If more tools are required due to multiple users, additional tools shall be purchased to prevent transfer. If workers MUST share tools, tools must be thoroughly disinfected with a Clorox-type wipe between users.
11. No sharing of PPE for workers.
12. Delivery drivers/visitors are to be managed with the same min 6-foot distancing and separation as needed. Drivers shall remain in the truck cab until designated subcontractor representatives can supervise separation activities during the unloading/loading of materials and equipment. No visitors are allowed on site without prior approval and specific escort.
13. Protocols for entering occupied units:
    1. Entering occupied units will be for essential/emergency services only and in protective gear; such as, gloves, face covering, safety glasses.
    2. Pre-project planning and inspections will no longer occur in occupied units. Delays associated with this should be advised to ownership (example – countertop templating)
    3. Cabinet template measuring will take place only in vacant units.

E. Jobsite Cleaning and Disinfecting

Hamel has instituted regular housekeeping practices, which includes cleaning and disinfecting frequently used tools and equipment, and other elements of the work environment, where possible. Employees should regularly do the same in their assigned work areas.

1. Jobsite trailers and break/lunchroom areas to be cleaned at least once per day. Employees performing cleaning will be issued proper personal protective equipment (“PPE”), such as nitrile, latex, or vinyl gloves, as recommended by the CDC.
2. Any trash collected from the jobsite must be changed frequently by someone wearing nitrile, latex, or vinyl gloves.
3. Any portable jobsite toilets should be cleaned by the leasing company at least twice per week and disinfected on the inside. Hamel will ensure that hand sanitizer dispensers are always filled as often as supplies are available and hand washing stations will be provided. Frequently touched items (i.e. door pulls and toilet seats) will be disinfected frequently.
4. Hamel will ensure that any disinfection shall be conducted using one of the following:
   1. Common EPA-registered household disinfectant;
   2. Alcohol solution with at least 60% alcohol; or
   3. Diluted household bleach solutions (these can be used if appropriate for the surface).
5. Hamel will maintain Safety Data Sheets of all disinfectants used on site.

VII. Separation and Prevention

A. Meetings

1. No office meetings will be held at this time.
2. Toolbox talks and safety orientations are only to be held in groups where at least six (6) feet minimum distance per person is possible and separated by These meetings will be held in outdoor or large site areas with no more than 10 individuals.

B. Practice “Extreme Personal Hygiene”

1. Avoid handshakes and bodily contact with others.
2. Avoid touching eyes, nose and mouth with your hands.
3. It is recommended that all construction workers wear cut-resistant gloves or the equivalent. Reminder that these gloves should be cleaned after each use with soap and water to reduce the spread of the virus.
4. Cover your mouth and nose with a tissue when you cough or sneeze.
5. Dispose of used tissues in the trash or flush down a toilet.
6. If tissues are not available, cough/sneeze into your elbow – not into your hand.
7. To avoid sharing germs, please clean up after Yourself. DO NOT make others responsible for moving, unpacking and packing up your personal belongings.
8. Wash hands thoroughly with warm water and soap after using the bathroom, coughing, sneezing, or encountering people or surfaces.
9. If soap and water are not available and hands are not visibly dirty, an alcohol-based hand sanitizer that contains 60%-95% alcohol may be used. However, if hands are visibly dirty, always wash hands with soap and water.
10. To avoid external contamination, we recommend everyone bring food from home.
11. Stay away from public areas and events if you are not feeling well, have flu-like symptoms and/or have a temperature, stay at home. This includes work! Do not risk infecting others.

C. Communications

1. Posters and signs will be displayed in areas (break areas, restrooms, site gates, etc.) reminding people to stay home if not feeling well, signs and symptoms of COVID-19, proper handwashing.
2. Project teams/offices will continue to receive and communicate the latest procedures, requirements and educational information learned to prevent the spread of COVID-19.
3. Any suspected/actual COVID-19 cases must be reported via email, managed, and closely monitored by Hamel following the guidelines contained within this plan.
4. Each site shall ask their subcontractors to maintain a Daily Log that is submitted to HAMEL that includes an employee roster. Subcontractors should also maintain an emergency contact for each employee.

D. Resources

1. Projects must evaluate and prepare for additional resource and material needs such as cleaning supplies, hand washing stations, PPE, restroom facilities and third-party services to assist with cleaning.
2. All occurrences must be reported to ensure the proper tracking the impacts and effects of this virus on jobsites.

VIII. Protocols for Sick Office or Site Employees

A. Guidance for Sick Employee at the Office or on Construction Project

1. If an employee exhibits COVID-19 symptoms, the employee must remain at home until he or she is symptom free for 72 hours (3 full days) without the use of fever-reducing or other symptom-altering medicines (e.g., cough suppressants). To the extent practical, employees are required to obtain a doctor’s note clearing them to return to work.
2. If Employee visits a doctor and is given medication, doctor recommendations for return to work will be followed.
3. Office area, jobsite trailer, or work areas will be disinfected following the confirmation from an employee who has been tested positive for COVID-19. The area will be certified as disinfected by a cleaning company, experienced in treating contaminated areas and surfaces, before others can enter the space.

B. Guidance for Sick Subcontractor Staff on Construction Project

1. If a subcontractor staff exhibits COVID-19 symptoms, the worker must remain at home until he or she is symptom free for 72 hours (3 full days) without the use of fever-reducing or other symptom-altering medicines (e.g., cough suppressants). To the extent practical and permitted by law, subcontractor must provide evidence that a worker can return to the jobsite.
2. If worker goes to the doctor and is given medication, doctor recommendations for return to work will be followed.
3. The work area will be disinfected by a third-party cleaning crew to reduce the risk of exposure contamination.

IX. Handling Cases of COVID-19

Hamel recognizes the potential of exposure to COVID-19 on our projects and offices and the impact it could have on our people and the company. Accordingly, we have the following plan in place in the event that an individual test positive for COVID-19 and was present on a jobsite or at a Hamel office.

Section 1 - Protect People and Reduce the Spread of COVID-19

A. Communicate with Individual with or suspected of COVID-19

1. Confirm individual is receiving care they need.
2. Confirm areas and people the individual had contact with and during what time.
3. Determine if the individual knows when they might have been exposed.
4. Encourage employee to eliminate contact with other people as much as possible to keep from potentially spreading illness.
5. For Hamel employees who have tested positive, communicate all available resources and benefits available to them.
6. Confirm with an individual that they should not return to work until a doctor confirms it is safe.
7. Employees that test positive and are symptom free may return to work when at least seven (7) days have passed since the date of his or her first positive test, and have not had a subsequent illness.
8. Employees that test positive and are directed to care for themselves at home may return to work when: (1) at least 72 hours (3 full days) have passed since recovery; and (2) at least seven (7) days have passed since symptoms first appeared.
9. Employees that test positive and have been hospitalized may return to work when directed to do so by their medical care provider.
10. Hamel will require an employee to provide documentation from a medical care provider clearing their return to work.

B. Identify Close Contacts

If Hamel learns that an employee has tested positive, Hamel will conduct an investigation into co-workers that may have had close contact with the confirmed-positive employee in the prior 14 days and may direct those individuals that have had close contact with the confirmed-positive employee to self-quarantine for up to 14 days from the last date of close contact with the carrier. If an employee learns that he or she has come into close contact with a confirmed-positive individual outside of the workplace, he/she must alert a manager or supervisor of the close contact and also self-quarantine for 14 days from the last date of close contact with the carrier. Any worker that came into close contact with the infected worker will be asked to leave the job or office and remain home for a period of 14 days. Close contact with an infected person is defined as within six (6) feet for a period of 10 minutes or being in direct contact with secretions (i.e. being coughed on or sneezed on) by an infected person.

Any worker that came into close contact with someone that has a confirmed diagnosis of COVID-19 will be asked to leave the job and remain home for a period of 14 days.

1. If no symptoms, the employee can return to work.
2. If symptoms persist, employee will not be permitted back on the project site until said time of doctor recommendation.

C. Separate & Inform Workers with Close Contact, Provide Direction

Hamel will inform those who were in close contact, both verbally and in writing, of the situation.

1. Keep the identity of the individual with COVID-19 private.
2. CDC recommends that these individuals limit public activities.
3. People (Hamel and subcontractor employees) should self-quarantine and work from home until they are symptom free for 3 days from the day they had contact.

D. Self-quarantine

When people are in self-quarantine, they may have no symptoms, but because there is a possibility that they might have been exposed, the CDC and healthcare leaders indicate they should stay away from others in public settings as well as others in their own home as much as possible. People in self-quarantine should not go to work, school, or any public places where they could have close contact with others.

E. Inform People, Client, and Subcontractor Principals

On a project, the Project Executive or Senior Project Manager is responsible for informing client and subcontractors after obtaining approval and guidance from the COVID-19 Response Team.

1. Keep the identity of the individual with COVID-19 private.
2. Hamel shall inform everyone working at the project or office location of the situation. We recommend that people be gathered in small groups to deliver the message and be provided written guidance.
3. Written guidance should follow pre-scripted guidance letters that accompany this plan. Share facts of the situation, Hamel’s response and ongoing steps to protect people.

Section 2 - Sustain Business Operations

A. Immediately Stop Work in Area / Control the Situation

The Project Superintendent is responsible to stop all work directly associated with the area in question. The area should be controlled in such a manner to eliminate the potential for both worker and public exposure.

B. Post Warnings

The Project Superintendent shall post signage, barricades, and other protective measures to ensure the area remains undisturbed.

C. Cleaning

Project team will work with Subcontractors of exposed employee to determine the scope of cleaning needed and locations needing cleaned. Cleaning must comply with the guidance outlined within this plan, OSHA’s standards and follow CDC guidelines for Environmental Cleaning and Disinfection including proper disposal of regulated waste. Post applicable warning notices that alcohol-based cleaning products may be flammable.

X. Recordkeeping

If a confirmed case of COVID-19 is reported, Hamel will determine if it meets the criteria for recordability and reportability under OSHA’s recordkeeping rule. OSHA requires construction employers to record work-related injuries and illnesses that meet certain severity criteria on the OSHA 300 Log, as well as complete the OSHA Form 301 (or equivalent) upon the occurrence of these injuries. For purposes of COVID-19, OSHA also requires employers to report to OSHA any work-related illness that (1) results in a fatality, or (2) results in the in-patient hospitalization of one or more employee. “In-patient” hospitalization is defined as a formal admission to the in- patient service of a hospital or clinic for care or treatment.

OSHA has made a determination that COVID-19 should not be excluded from coverage of the rule– like the common cold or the seasonal flu– and, thus, OSHA is considering it an “illness.” However, OSHA has stated that only confirmed cases of COVID-19 should be considered an illness under the rule. Thus, if an employee simply comes to work with symptoms consistent with COVID-19 but is not a confirmed diagnosis, the recordability analysis is not necessarily triggered at that time.

If an employee has a confirmed case of COVID-19, the Company will assess any workplace exposures to determine if the case is work-related. Work-relatedness is presumed for illnesses that result from events or exposures in the work environment, unless it meets certain exceptions. One of those exceptions is that the illness involves signs or symptoms that surface at work but result solely from a non-work-related event or exposure that occurs outside of the work environment. Thus, if an employee develops COVID-19 solely from an exposure outside of the work environment, it would not be work-related, and thus not recordable.

Hamel’s assessment will consider the work environment itself, the type of work performed, the risk of person-to-person transmission given the work environment, and other factors such as community spread. Further, if an employee has a confirmed case of COVID- 19 that is considered work-related, the Company will report the case to OSHA if it results in a fatality within 30 days or an in-patient hospitalization within 24-hours of the exposure incident.

XI. Confidentiality/Privacy

Except for circumstances in which Hamel is legally required to report workplace occurrences of communicable disease, the confidentiality of all medical conditions will be maintained in accordance with applicable law and to the extent practical under the circumstances. When it is required, the number of persons who will be informed that an unnamed employee has tested positive will be kept to the minimum needed to comply with reporting requirements and to limit the potential for transmission to others. The Company reserves the right to inform other employees that an unnamed co-worker has been diagnosed with COVID-19 if the other employees might have been exposed to the disease so the employees may take measures to protect their own health. The Company also reserves the right to inform sub-contractors, vendors/suppliers or visitors that an unnamed employee has been diagnosed with COVID-19 if they might have been exposed to the disease so those individuals may take measures to protect their own health.

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