Louisiana Chemical Association
Louisiana Chemical Industry Alliance

   

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COVID-19 What You Need to Know

Recent Announcements:

  • 4/28/20 - OSHA Provides Guidance on Respirator Reuse and Decontamination
    • OSHA has issued an interim guidance document defining the proper methods to sanitize filtering facepiece respirators, such as N95s, for reuse following decontamination. Note that this guidance is targeted to healthcare workers who are in direct contact with persons who have tested positive for COVID-19; however, we have recently seen OSHA issue revised guidance documents to all employers after issuing guidance that originally targeted healthcare workers only. 
  • 4/27/20 - Stay at Home Order Extended to May 15  
    • Governor John Bel Edwards extended his statewide Stay-At-Home order until May 15 on Monday afternoon. The order maintains the status quo of essential businesses remaining operational and businesses deemed "non-essential" will remain closed, or open with some stringent regulations. 
  • 4/22/20 - Summary Of Available COVID-19 OSHA And NIOSH Resources 
    • OSHA has compiled a listing of all of the COVID-19-related resources on its webpage, along with resources provided by other federal agencies as well. These resources are grouped both by agency and by industry. Please feel free to share this information as broadly as possible.
  • 4/22/20 - OSHA Enforcement Discretion Policy
    • OSHA has issued an interim guidance that advises OSHA compliance officers to evaluate an employer’s good faith efforts during the COVID-19 epidemic. OSHA understands that some employers may face difficulties complying with OSHA standards due to the ongoing health emergency, and that business closures, restrictions on travel, limitations on group sizes, facility visitor prohibitions, and stay-at-home or shelter-in-place requirements may limit the availability of employees, consultants, or contractors who normally provide training, auditing, equipment inspections, testing, and other essential safety and industrial hygiene services. As such, the Agency has given OSHA compliance officers the discretion to assess employers' good faith efforts to comply with standards that require annual or recurring audits, reviews, training, or assessments. 
  • 4/15/20 -OSHA issued an Interim Enforcement Response Plan for Coronavirus Disease 2019 (COVID-19)
    • This guidance provides instructions and guidance to OSHA Area Offices and compliance safety and health officers (CSHOs) for handling COVID-19-related complaints, referrals, and severe illness reports. The scope of this guidance covers all investigations and inspections specifically related to the workplace hazard of COVID-19. 
  • 4/14/20 - EPA proposed to keep the existing particulate matter NAAQS in place
    • The Trump administration’s proposal suggests that the 12 ug/m3 primary standard and all other PM limits including the secondary environment-based thresholds meet the Clean Air Act’s mandate that NAAQS be set at a level requisite to protect human health with an adequate margin of safety.
  • 4/10/20 - 
  • 4/10/20 - Centers for Disease Control issues guidance regarding critical infrastructure workers who have been exposed to COVID-19
  • To ensure continuity of operations of essential functions, CDC advises that critical infrastructure workers may be permitted to continue work following potential exposure to COVID-19, provided they remain asymptomatic and additional precautions are implemented to protect them and others. Critical infrastructure workers who have been exposed to COVID-19 but remain asymptomatic should implement the following best practices as laid out by the CDC:
    • Pre-Screening.
    • Regular Monitoring.
    • Wearing a Mask.
    • Social Distancing.
    • Disinfecting and Cleaning work spaces
  • 4/9/20OSHA issues guidance on COVID-19
    • OSHA has confirmed that COVID-19 can be a recordable work-related illness that must be documented on an employer’s OSHA 300 log in certain circumstances.
    • Previously, OSHA issued temporary enforcement guidance on respiratory protection fit testing requirements for healthcare employers. The purpose of the guidance was to ensure that respirators are being used where they are needed most. Yesterday, OSHA expanded that guidance to apply to all workplaces where the use of respirators is required.
    • Given the shortage of respirators, OSHA has also indicated that it will exercise additional enforcement discretion if an employer switches to an equivalent-fitting make, model, size, or style filtering respirator without first performing an initial fit test. 
  • 4/5/20 - The Alliance Safety Council has COVID-19 training located in the website's Course Catalog
    • The training is titled "Coronavirus Disease 2019 (COVID-19)"
    • Another webinar is available through GBRIA, click here to access it. 
  • 4/1/20 - Webinar: Putting the CARES Act to Work for Your Business
    • The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) is the largest economic stimulus bill in U.S. history and provides businesses with important resources to alleviate financial hardship.  Optimizing the appropriate provisions of the CARES Act can help businesses endure this challenging time and assist business operations and employees. 
  • 3/27/20 - DEQ has issued its second amended emergency order concerning COVID-19
    • In this amended order, DEQ extends the deadline for Title V semiannual monitoring and deviation reports and annual compliance certifications from March 31st to May 1st. Please see a copy of the order below. 
  • 3/26/20 - EPA's COVID-19 enforcement guidance
  • 3/25/20 - Governor John Bel Edwards issues a state-wide Stay At Home Order
    • The Order directs all Louisiana residents to shelter at home and limit all movement outside of their homes unless it is for essential needs. Additionally, only essential employees needed to operate essential businesses should report to those sites for work.
  • 3/22/20 -Gov. Edwards Issues Statewide Stay at Home Order to Further Fight the Spread of COVID-19 in Louisiana
    • The Executive Order goes into effect at 5 p.m. Monday, March 23, to further fight the spread of COVID-19 in Louisiana, as the number of confirmed cases have topped 800 and spread to more than half of Louisiana parishes. The Order does provide exceptions for essential workers, which include critical manufacturing em Given the shortage of respirators, OSHA has also indicated that it will exercise additional enforcement discretion if an employer switches to an equivalent-fitting make, model, size, or style filtering respirator without first performing an initial fit test.  ployees (chemicals, energy, transportation, food, medical supply chains, as well as petroleum, natural and propane gas workers. 
    • See the full Executive Order.
  • 3/19/20 - U.S. Cybersecurity and Infrastructure Security Agency (CISA) Issues Guidance on Essential Critical Infrastructure Workers During COVID-19 Response
    • The President issued updated Coronavirus Guidance for America. This guidance states that, "If you work in a critical infrastructure industry, as defined by the Department of Homeland Security, such as healthcare services and pharmaceutical and food supply, you have a special responsibility to maintain your normal work schedule." 
    • The Guidance identifies workers supporting the chemical and industrial gas supply chains as essential, including workers at chemical manufacturing plans, workers in laboratories, workers at distribution facilities, as well as workers who transport basic raw chemical materials to the producers of industrial and consumer goods. 
  • 3/19/20 -LDEQ Secretary Dr. Chuck Brown: Declaration of Emergency and Administrative Order
    • The Executive Order issued does several things, including allowing electronic submittals to the Dept. for permitting related purposes, with hard copies submitted no later than 30 days following the expiration of the Order. It also allows for DocuSign and other e-signatures from responsible officials until the Order's expiration. 
    • See the full Executive Order.
  • 3/19/20 - ACC: "Essential" for Industry to Continue Operations During COVID-19 Outbreak
    • The chemical industry is vital in helping to contain the coronavirus COVID-19 outbreak and must continue production, the American Chemistry Council said this week in a letter to federal and state leaders. Signed by more than 60 industry groups, the letter laid out two immediate asks for state and federal governments:
      • to "expeditiously" put together a coordinated framework showing how manufacturers are exempt from state and local gathering and curfew bands.
      • create a federal exemption, if needed, for "human, animal and pet food manufacturing facilities, as well as facilities that produce essential commercial goods critical to mitigating the spread of COVID-19." 
  • 3/17/20 - Gov. Edwards Requests SBA Economic Injury Disaster Loans for Orleans and Jefferson Parish
    • Gov. Edwards requested the Small Business Administration provide Economic Injury Disaster Loans for Orleans and Jefferson parishes as a result of the COVID-19 pandemic. While this request is specific to the two parishes with the highest number of cases in Louisiana at this time, Gov. Edwards will request SBA assistance for all 64 parishes in the state. 
    • Read the letter here.
  • 3/16/20 - Gov. Edwards Expands Proclamation Aimed to Slow the Spread of COVID-19 in Louisiana
    • The updated proclamation calls for a limit to gatherings of no more than 50, and all bars, movie theaters and fitness centers and casinos will close. Restaurants will not be allowed to have patrons on-site, rather they will be limited to drive-thru, pick-up and delivery orders only. Additionally, the order addresses emergency procurement measures and the use of video or teleconferencing for public meetings. It suspends various prescriptive periods and legal deadlines and allows for the chief law enforcement officer of a parish to set a curfew, among other things. 
    • Read the proclamation here.
  • 3/16/20 - Mayor Cantrell Signs Proclamation to Take Further Steps in Response to COVID-19 Outbreak
    • Mayor Cantrell took further steps to protect residents and respond even more aggressively to the COVID-19 outbreak. The Mayor filed a proclamation with the Civil District Court that called for several actions, effective 3/17/20, including the closure of all bars, casinos, health clubs, gyms, movie theaters and malls. Restaurants will be required to end dine-in service and provide take-out and delivery only. 
    • Read the proclamation here.
Resources:

LCA COVID-19-Related Activities:

  • LCA is in regular contact with our members and our partners at the state and federal level, coordinating among all segments of the value chain. Our staff is working collaboratively with Gov. Edwards' administration, LDEQ, LDNR, LDH, the State Legislature and other stakeholders to communication the needs of our members during the unique challenges of the coronavirus outbreak.
  • We are participating in daily LMOGA COVID-19 calls at 8:30 a.m.
  • LCA is hosting COVID-19 calls (plant managers, environmental, health & safety, security, government affairs committees invited) on Mondays and Wednesdays at 10 a.m. 
  • Our team is participating in DHS's Cybersecurity and Infrastructure Security Agency (CISA) and FEMA's Office of Response and Recovery Logistics Management Directorate hosting a Cross-Sector Business and Infrastructure Conference Call on Tuesdays and Thursdays at 10 a.m.
  • We are updating members regularly via email with Executive Orders from state and federal officials.
  • LCA is providing resources and best practices from members via email and on private side of LCA website.
  • Our team is talking to legislators about issues facing their districts along with what issues may or may not arise if/when the legislative session reconvenes.
  • We are participating in Department of Homeland Security and Infrastructure Security Agency (CISA) and FEMA Response and Recovery Conference call on Tuesdays and Thursdays at 2:00 p.m.

LCA is sending regular updates on pertinent information via email, social media and the LCA website (both public and private sides).

Best Industry Practices:
It is important that chemical facility sites emphasize the importance of site process safety, occupational safety, and environmental compliance as a priority that should not be compromised by any operational manpower changes or social distancing protocols.  Management of shift changes, EH&S interventions, compliance activities, and permit management should be conducted while minimizing contact. 

The following are a compilation of industry best practices to protect employees and maintain business continuity:LCA is in regular contact with our members and our partners at the state and federal level, coordinating among all segments of the value chain. Our staff is working collaboratively with Governor Edwards administration, LDEQ, LDNR, LDH, the State Legislature and other stakeholders, to communicate the needs of our members during the unique challenges of the coronavirus outbreak.

  • LCA is in regular contact with our members and our partners at the state and federal level, coordinating among all segments of the value chain. Our staff is working collaboratively with Governor Edwards administration, LDEQ, LDNR, LDH, the State Legislature and other stakeholders, to communicate the needs of our members during the unique challenges of the coronavirus outbreak.
  • Planning:
    • Activate emergency preparedness plans similar to those in effect for hurricane and extreme weather events.
      • Establish trigger points to implement changes to plan(s) based on spread of contagion.
    • Plan for scenarios for symptomatic and positive tests for both operations and maintenance employees.
    • Assess third party impacts on plant operation (utilities, chemicals, logistics, etc)
    • Enhance and test IT network to facilitate telework connectivity, access and security for all employees equipped with company provided laptops.
    • Review and manage product inventories, feed stocks, spare parts and supplies for potential outage or supply chain disruption.
    • Model plans currently under development by an LCA member company:
      • COM – Core Operating Mode –a minimum staffing plan with technical support – evaluated every 2 weeks and adjusted as needed
      • ROM – Rideout Operating Mode and applicable to only certain sites
        • This plan may result in planned shutdown of specified sites
        • Ask an LCA staff member for more information
  • Communications:
    • Activate an employee communication plan, including creation of a dedicated COVID-19 phone number and email address, to quickly identify any potential facility or employee COVID-19 related issues and concerns.
    • Share CDC-recommended actions with employees to reduce exposure and risk of COVID-19.
    • Provide health check-list and self-quarantine guidelines to staff and contractors. 
    • Reach out to employees, neighbors and local community leaders to share health & safety precautions and to provide assistance with equipment and supplies.
    • Evaluate potential for virtual town-hall meetings with leadership and employees.
  • Personnel:
    • Institute new access segregation protocols at all facilities to minimize and screen incoming visitors, contactors and service providers, including drivers and delivery personnel.
    • Direct all non-essential personnel to work from home.
    • Screen all employees, contractors and visitors on site:
      • Questionnaire regarding travel and risk exposure.
      • Temperature scans of all who enter the site.
      • Require employees to self-report temperature daily before coming to work.
    • Limit site access to direct production & maintenance personnel only.
    • Cancel, postpone meetings or host through teleconference
    • Shutdown canteens and on-site cafeterias
    • Isolate operators as much as possible - Separation of Field vs. Control Room
      • Remove permit activities from Control Room
      • Preventive measures must be taken in control rooms to limit person-to-person contact
    • Enhance certain sick leave benefits to remove the financial impediments employees may face in complying with current our “if sick, stay home” directive.
    • Deploy enhanced contractor screening and segregation protocols at facilities that are undergoing construction.
    • Eliminate all overseas travel.
    • Eliminate all domestic air travel, unless specifically approved and authorized in advance.
    • Cancel or postpone all large-scale employee gatherings
    • Expand utilization of web meetings and computer-based training to avoid gatherings.
    • Expand existing telework practices for qualified employees.
    • Limit the number of people in kitchens and break rooms.
    • Ask plant managers and department heads to track employees who are going “above and beyond” for future recognition.
  • Cleaning and Disinfection:
    • Increase sanitation of break rooms and prescriptive guidance for shared use appliances and equipment.
    • Review and enhance existing facility cleaning and sanitation practices.
    • Control room surfaces, kitchens and break rooms are to be wiped down with sanitizing cleaners at the end of each shift
  • Operations:
    • Implemented a daily meeting of the company’s executive leadership team.
    • Proceed only with essential maintenance and project works. 
    • Conduct Critical Activity Assessments at each operating location.
    • Plan-Source-Make-Deliver chain analysis.
    • Alternate staffing plans defined to ensure continued operation of the assets.
    • Continue only with mandatory safety and regulatory projects
    • Control Room protocols:
      • Dayshift personnel are not to enter the control room
      • Contractors and maintenance workers are not to enter the control room
      • Preventive measures must be taken in control rooms to limit person-to-person contact
      • Remove permit activities from Control Room
      • All entry to the units by visitors should interface with either the Master Tag person or other arrangement outside the control room
    • Shift schedule management:
      • Implement modified schedule(s)
      • Segment groups into teams to maximize redundancy and to protect against virus spread.
      • Consider segregating shift rotations into two groups that would work 7 days on and 7 days off schedule (turnaround-like schedule) with an emphasis on keeping these two groups segregated as much as possible to prevent virus exposure.
      • Quarantine of “healthy” employees on the bench
      • Divide critical skills into smaller groups:
        • Control systems
        • High voltage personnel
        • Etc.
      • Shift relief must be made without face-to-face contact 






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