COVID-19 Preparedness, Response, Health and Safety Plan

(Updated 8/31/2020)  Bowerman, Bowden, Ford, Clulo & Luyt, P.C. (hereinafter BBFC&L) recognizes the potential impact of Coronavirus (COVID-19) to our producing the highest quality legal work, but more importantly to the lives and well-being of our employees. Therefore, we have developed this plan, using the CDC guidelines, OSHA guidelines, Executive Orders issued by Governor Gretchen Whitmer (including without limitation Executive Orders 2020-91, 2020-92, and 2020-97), and other available resources and recommendations. This COVID-19 Preparedness, Response, Health & Safety Plan also constitutes a COVID-19 preparedness and response plan as described in Section 1(a) of Michigan Governor Gretchen Whitmer’s Executive Order number 2020-91, issued May 18, 2020, as the same may be amended, superseded or supplemented. Events, circumstances, and legal requirements related to COVID-19 are rapidly evolving, and therefore, this Plan is subject to change at any time in the discretion of BBFC&L’s Board of Directors, including without limitation to adapt to new legal requirements or other changes in circumstances.

Goals of Our Plan:

● Keep every employee and everyone in our workplace safe and healthy.
● Keep our employees working if possible while doing so in a safe and productive manner.
● Do what we can to continue operations to safely meet the needs of others who depend on us.

To protect our employees and reduce the spread of this virus, our company will strive to do the following:

● Communicate and follow CDC, OSHA, and Michigan Department of Health and Human Services guidelines to prevent the spread of the illness.
● Continue open dialog with all employees.
● Continually improve as new strategies and guidance become available.

Worksite Supervisors / COVID-19 Response Team

The following individuals are designated as worksite supervisors to implement, monitor, and report on the COVID-19 control strategies developed as a part of this Plan:

Theresa Lhamon
Leslie Jozwiak
Gregory Luyt
Timothy Clulo

If you have any questions or concerns, to notify BBFC&L of any symptoms or a suspected or confirmed diagnosis of COVID-19, to report unsafe working conditions, or if you need to communicate anything else to BBFC&L related to this Plan and/or COVID-19, please communicate with any one of the above worksite supervisors.

Daily Self-screening Protocol:

Every employee that is not working remotely from home is required each work day to fill out the Health Screening Checklist that we will be providing to you. On this form, you are required to document your temperature every day using the on-site thermometer provided by BBFC&L. Answer all questions, sign and date, then email the completed form to Theresa Lhamon every morning immediately upon entering the office.

To protect yourself, your coworkers and our clients, answer all questions honestly and do not come to work if you have identified that you have any symptoms or a fever over 100.4 degrees

All Employees:

Stay home if you are sick and/or are experiencing any of the following symptoms:

● Fever (CDC considers a person to have a fever when he or she has a measured temperature of 100.4 deg. F (38 deg. C) or greater
● Chills
● Muscle Pain
● Cough
● Shortness of breath or difficulty breathing
● Sore Throat
● Nausea/Vomiting/Diarrhea
● Repeated shaking with chills
● New loss of taste or smell

Wash your hands with soap and water or hand sanitizer often. Especially after touching something that has been in the possession or came from another person.

● Avoid contact with people who have apparent respiratory symptoms.
● Avoid touching your eyes, nose or mouth.
● Cover all coughs and sneezes with tissue then discard in trash. If tissue is not immediately available, cover coughs and sneezes with the inside crook of your elbow. Wash hands immediately after any coughs and/or sneezes.
● If you are suspicious of your health, self-quarantine and contact your physician. Notify one of the above worksite supervisors as well.
● Employees who have traveled out of country are not allowed at BBFC&L’s office until the traveler has been symptom free for 14 days from the date they returned.
● All workers who have been diagnosed with COVID-19 or who experience acute respiratory symptoms (cough, shortness of breath or signs of a fever) will be removed and/or barred from the office immediately. They shall remain home for 10 days and must be symptom free (without the aid of pharmaceuticals) for at least 72 hours before returning to work.
● Should symptoms continue or escalate contact a physician and notify one of the worksite supervisors designated above.
● Please notify one of the worksite supervisors designated above if you have tested positive for the virus, or had close contact with an individual who is suspected of having or confirmed to have COVID-19. Close contact includes being a member of the same household or within 6 feet for 10 minutes or longer.
● All confirmed cases may not return to the office until they have remained home for 10 days and have been symptom free for at least 72 hours before returning to work.
● If an employee has had close contact (as defined above) with another person who has tested positive for COVID-19 or who has developed one or more symptoms of COVID-19, the employee must self-quarantine immediately. If an employee is self-quarantined, they may return to work after 14 days if they are symptom free and have remained symptom free for the entire 14 days. If the employee develops one or more symptoms of COVID-19 during the self-quarantine period, then the employee must remain home for at least 10 days following the onset of symptoms, and must be symptom free (without the aid of pharmaceuticals) for at least 72 hours before returning to work.
● In the event an employee has close contact (as defined above) with another person who has tested positive for COVID-19 or who has developed one or more symptoms of COVID-19 and is self-quarantining, all BBFC&L staff will be notified of the quarantine under health department and BBFC&L policies consistent with applicable law and guidance from the health department.
● Social Distance: The employee should maintain 6 feet and practice social distancing at all times.
● Routinely clean and disinfect all frequently touched surfaces in the workplace, such as workstations, keyboards, telephones, handrails, and doorknobs.
● If surfaces are dirty, they should be cleaned using a detergent or soap and water prior to disinfection. For disinfection, most common EPA-registered household disinfectants should be effective. Follow the manufacturer’s instructions for all cleaning and disinfection products (e.g., concentration, application method and contact time, etc.).
● Employees are discouraged from using other workers’ phones, desks, offices, or other work tools and equipment, when possible. If necessary, clean and disinfect them before and after use.
● Disposable wipes or other appropriate cleaning materials will be provided so that commonly used surfaces (for example, doorknobs, keyboards, remote controls, desks, other work tools and equipment) can be wiped down by employees before each use.
● If you must leave work and/or stay home pursuant to the terms of this policy, you will be entitled to leave consistent with BBFC&L’s Paid Time Off policies and applicable federal and state law. No employee will be disciplined, discharged, or retaliated against for absence from work required by this Plan.
● All social gatherings and meetings that do not allow for social distancing or that create unnecessary movement through the office are prohibited.
● BBFC&L will provide disinfecting supplies. All employees must wipe down their work stations at least twice daily.

Office Staff:

● We will provide cloth masks for your use that can be washed regularly. Per Executive Order 2020-91, you are required to wear face shields or masks when workers cannot consistently maintain six feet of separation from other workers. In addition, masks are to be worn at all times you are not in your office with the door closed, including but not limited to any time you are in the hallways, workroom, conference rooms, kitchen area, bathroom, lobby or basement areas.
● We will provide refillable hand sanitizer, use this regularly to clean your hands prior to leaving your office and before using the copy machine, printers, typewriter, postage meter, workroom computer, coffee maker or any other surface that others will touch during the day.
● All employees shall maintain 6 feet separation and practice social distancing at all times in the office
● Avoid in-person meetings and use electronic communication as much as possible.
Client Interaction:
● Avoid in-person meetings and use electronic communication as much as possible.
● For the safety of everyone, all clients will be asked the following questions at the time an appointment is made and at the time of the in person meeting. Please instruct the client that masks are required in our office and if they don’t have one, a mask will be provided to them upon entering our office. The attorney meeting with the client will ask and document the client’s answers to the following questions:
● Has anyone in the home been or felt sick, or experienced coughing, shortness of breath, fever, sore throat or diarrhea?
● Has anyone in the home been diagnosed with or exposed to COVID-19?
● Any travel that is prohibited by the then-currently in force Executive Orders?
● Has anyone in the home been told to self-quarantine by a health care provider or County Health Department?
If anyone is displaying any of the above noted symptoms of COVID-19 when they arrive, do not allow them to enter the office and notify the client’s attorney and/or a worksite supervisor. Maintain six feet of separation to the maximum extent possible when interacting with clients in person.
Protocols and Response Plan in the Event of Positive Diagnosis of COVID-19 in Workplace
In the event of a positive COVID-19 case in the workplace, the following protocols shall be followed, subject to potential revision and supplementation depending on the particular circumstances:
● An employee who is COVID-19 positive or develops symptoms of COVID-19 in the workplace will be immediately isolated from all other employees and sent home to self-quarantine in accordance with all applicable recommendations and guidelines.
● All employees will be sent home and our offices will be closed until such time as the offices have been thoroughly cleaned and disinfected.
● The offices will be cleaned and disinfected thoroughly, with particular emphasis on the affected employee’s workstation and other areas in the office where the affected employee was located or touched surfaces.
● Within 24 hours after an employee is identified with a confirmed case of COVID-19, BBFC&L will notify the local public health department and any co-workers, contractors, or suppliers who may have come into contact with the person with a confirmed case of COVID-19.
● We will notify employees if BBFC&L learns that an individual (including a client, supplier, contractor, or visitor) with a confirmed case of COVID-19 has visited the office.
In order to safely return to work, we need to follow the guidelines of the Governor’s recent executive orders, including without limitation Executive Order 2020-97, all CDC guidelines and all guidelines outlined in this COVID-19 Preparedness, Response, Health & Safety Plan. These guidelines are not suggestions, they are requirements that we all must follow. Please do your part to keep yourself, coworkers and our clients safe.

Thank you,
Bowerman, Bowden, Ford, Clulo & Luyt, P.C.
Timothy J. Clulo
Gregory M. Luyt