COVID-19 Workplace Safety Plan

I.     Purpose

The purpose of this document is to set forth the U.S. Equal Employment Opportunity Commission’s (the EEOC or the Commission) COVID-19 Workplace Safety Plan (Safety Plan) for employees, onsite contractors, individuals receiving services, and visitors.  This is not the EEOC’s Reentry Plan.^[1]  This document follows the President’s Executive Order (EO) 14043, Requiring Coronavirus Disease 2019 Vaccination for Federal Employees, Executive Order 13991, Protecting the Federal Workforce and Requiring Mask-Wearing, and the Office of Management and Budget (OMB) issued guidance, M-21-15 COVID-19 Safe Federal Workplace: Agency Model Safety Principles and its updates; adheres to the National Strategy for the COVID-19 Response and Pandemic Preparedness; and includes the latest guidance from the U.S. Centers for Disease Control and Prevention (CDC). The Safety Plan also incorporates Occupational Safety and Health Administration’s (OSHA) Guidance on Preparing Workplaces for COVID-19. 

As it has done since the start of the pandemic, the EEOC will work to balance delivery of our mission with adapting to the evolving challenges that COVID-19 presents to our workforce and the public.  The health and safety of the EEOC workforce, its contractors, and the public we serve is paramount.  The agency will follow the health and safety protocols and procedures outlined in this plan.  This is a living document dependent on government guidance about public health conditions and may be updated as circumstances require.   

Where a locality has imposed additional pandemic-related requirements more protective than those set forth in this Safety Plan, those requirements should be followed in federal buildings, in federally leased property, and on federal land in that locality.

In response to OMB guidance, M-21-15, the EEOC has:

• designated an EEOC COVID-19 Coordination Team;
• issued agency-wide notifications on masking and physical distancing consistent with current CDC guidance in all EEOC offices; and
• reviewed the safety principles provided by OMB and adapted them to meet the needs of the Commission.

II.    EEOC COVID-19 Coordination Team

The EEOC has established a COVID-19 Coordination Team. Currently, the members are:^[2]   

• Chief Operating Officer
• Deputy Chief Operating Officer
• Chief of Staff, Office of the Chair
• Representative from the Office of General Counsel
• Legal Counsel
• Associate Director, Office of Communications & Legislative Affairs
• Acting Director, Office of Field Programs
• Chief Human Capital Officer
• Chief Information Officer
• Chief Financial Officer
• Supervisory Security Specialist

Because the EEOC does not have a public health expert on staff, the EEOC will consult with a delegate provided by the CDC through the Safer Federal Workforce Taskforce when necessary.  

The COVID-19 Coordination Team will meet bi-weekly, or as otherwise deemed necessary, to review compliance with the agency’s Safety Plan, consider potential revisions to the Safety Plan pursuant to guidance from the Safer Federal Workforce Task Force and current CDC guidelines, and evaluate any other operational needs related to COVID-19 workplace safety.  The Team will consult with the General Services Administration (GSA), the Office of Personnel Management (OPM), and the Office of Management and Budget (OMB), as appropriate.  For privately owned and federally leased space, the COVID-19 Coordination Team will coordinate with GSA, building management, Facility Security and Safety Committees, and/or facility pandemic coordinators. 

The COVID Coordination Team is responsible for keeping the Chair informed regarding conclusions and recommendations of the Team.

III.   Communications with EEOC Employees, On-Site Contractors, Visitors, and Service Recipients

1. General:  The EEOC communicates with, educates, and informs employees, contractors, visitors, and service recipients in a variety of ways.  The EEOC will be transparent in communicating information to the workforce, as relevant and appropriate, consistent with local and federal privacy and confidentiality laws and regulations. 
   
   The COVID-19 Coordination Team, in coordination with the Office of the Chair, has the responsibility to make disclosures to local public health officials as required or necessary to provide for the public health and safety of federal employees and contractors in accordance with local public health mandates.
2. Communications with Employees and On-Site Contractors:  The EEOC’s internal email is the primary tool for communicating internal messages to staff.  There is a COVID-19 dedicated SharePoint site accessible to all employees and contractors and all-employee COVID-19 Update emails.  The EEOC also utilizes an emergency alert system, Everbridge, to communicate with employees.
3. Communications with Visitors and Service Recipients:  The EEOC’s primary means of communicating safety plans and protocols with individual visitors and service recipients is through email and its public facing website, eeoc.gov. The EEOC will also post signage and key messages at entrances, doors, reception desks, common areas, and conference rooms.     

IV.   Telework and Remote Work

As of the publication of this Plan, EEOC employees remain on maximum telework flexibilities due to the pandemic.  The agency will continue to evaluate safety conditions to determine when it will be appropriate for EEOC offices to reopen.  Employees will be given at least 30 days advance notice before this is changed.

During the maximum telework posture, all EEOC employees are expected to telework, unless they are directed to do otherwise by their supervisor for essential business needs and given advance notice and guidance.  Such essential activities must be approved under the Reentry Plan or approved in coordination with the COVID-19 Coordination Team.  They may include but are not limited to necessary support of investigations and litigation; processing of/securing paper records and documents; mail processing, security/badging protocols, and facilities maintenance that cannot be accomplished remotely.

V.    Occupancy Limits at EEOC Worksites

1. General:  The EEOC will make every effort to maximize the use of telework and remote work during widespread community transmission.  As a general matter, occupancy in EEOC’s workplaces should be no more than 25% of normal capacity during periods of high community transmission and 50% of normal capacity during periods of substantial transmission.  The EEOC may also establish occupancy limits for specific workplaces as a means of facilitating physical distancing. Any exceptions to established occupancy limits (for trial preparations or other court appearances, for example) must be cleared by the Office of the Chair in consultation with the COVID-19 Coordination Team.
2. Levels of Transmission: The agency will monitor levels of community transmission as identified by the CDC's COVID Data Tracker County View on a weekly basis to ensure assigned personnel are following appropriate CDC guidelines based on the level of community transmission in their location. EEOC offices/divisions may use discretion in determining the counties relevant to the determination of the level of community transmission in a given area, for a particular EEOC or federal facility. For example, EEOC may consider the county in which our facility is located as well as the transmission levels of surrounding local counties from which our employees commute to the facility.
3. All standards and guidance set forth in this document for EEOC facilities and EEOC employees, onsite contractors, visitors, and service recipients apply regardless of the occupancy levels at EEOC worksites.  

VI.   COVID-19 Vaccination and Vaccination Status:  EEOC Employees, Visitors, and Service Recipients[3]

Note that as of January 21, 2022, this section of the Safety Plan is no longer in effect, and the EEOC is taking no action to implement or enforce it.

1. EEOC Employees: 
   
   To ensure the safety of the agency’s workforce, as of November 22, 2021, all EEOC employees were required to be fully vaccinated, except in limited circumstances where an employee is legally entitled to an exception. Employees are considered “fully vaccinated” two weeks after completing the second dose of a two-dose COVID-19 vaccine (e.g., Pfizer or Moderna) or two weeks after receiving a single dose of a one-dose vaccine (e.g., Johnson & Johnson/Janssen).  Employees who are on maximum telework or work remotely are not excused from this requirement.
   
   Proof of Vaccination
   
   Employees were required to provide proof of vaccination via the EEOC’s secure, Teams-based VaxApp.  Employees may provide a digital copy of the record of immunization from a health care provider or pharmacy, a copy of the COVID-19 Vaccination Record Card, a copy of medical records documenting the vaccination, a copy of immunization records from a public health or state immunization information system, or a copy of any other official documentation containing required data points. In requesting this information, the agency will comply with any applicable Federal laws, including requirements under the Privacy Act and Rehabilitation Act of 1973.  Employees must certify under penalty of perjury that the documentation they are submitting is true and correct.
   
   Requests for Accommodation
   
   There are limited exceptions to the requirement that federal employees be fully vaccinated by November 22, 2021.  In certain circumstances, an employee may be legally entitled to a reasonable accommodation that does not pose an undue hardship because of a disability or a sincerely held religious belief, practice, or observance.  Employees who wish to seek a legally required exception to the vaccine requirement or an extension to the deadline for vaccination for medical reasons should submit a Request for a Medical Exception to the COVID19 Vaccination Requirement Form to disability.program@eeoc.gov.  Employees who wish to request an exception to the vaccination requirement based on a sincerely-held religious belief, practice or observance should submit a Religious Accommodation Request Form to religious.accommodation@eeoc.gov.
   
   Employees who request an exception in accordance with the above process will not be asked to comply with the vaccine requirement while their accommodation requests are pending.  If your request for an accommodation is denied, you will be required to receive your first (or, if a one-dose series, only) vaccine dose within two weeks of the final determination to deny the accommodation.
                          
   Noncompliance
   
   If an employee fails to comply with the requirement to be fully vaccinated or provide proof of vaccination and does not have a pending or approved exception, the EEOC will pursue progressive disciplinary measures (counseling, suspension, and, if necessary, removal from federal service).
   
   New Employees
   
   Individuals who start their government service after November 22, 2021, need to be fully vaccinated prior to their start date, except in limited circumstances where an exception is legally required.  If the EEOC has an urgent, mission-critical hiring need to onboard new staff prior to those new staff becoming fully vaccinated, such new hires must be fully vaccinated within 60 days of their start date (except in limited circumstances where an exception is legally required), and they must follow safety protocols for not fully vaccinated individuals until they are fully vaccinated.
2. Employee Leave for Vaccination
   
   When a federal employee is required to be vaccinated, the time the employee spends obtaining any authorized COVID-19 vaccination (including travel time) is duty time; thus, there is no need for the employee to take administrative leave for such time during the employee’s basic tour of duty.  If, due to unforeseen circumstances, the employee is unable to obtain the vaccine during basic tour of duty hours the normal overtime hours of work rules apply.
   
   Booster Shots and Additional Doses
   
   The EEOC will grant employees up to four hours of administrative leave to receive any authorized COVID-19 vaccine booster shot (or additional dose of COVID-19 vaccine), if they are eligible to receive such a booster shot or additional dose.  If an employee needs to spend less time getting the vaccine booster shot or additional dose, only the needed amount of administrative leave should be granted. Employees should obtain advance approval from their supervisor before using administrative leave for purposes of obtaining a COVID-19 vaccine booster shot or additional dose. Employees may not be credited with administrative leave or overtime work for time spent getting a booster vaccine shot or additional dose outside their tour of duty.
   
   EEOC employees are authorized to take up to two days of administrative leave for adverse reactions to the vaccine or booster shot.  If an employee requests more than two days to recover, the employee may take other available leave (e.g., sick leave) to cover any additional absence.  Finally, employees will receive up to four hours of administrative leave per dose to accompany a family member receiving the vaccine, for a potential maximum total of twelve hours for a family member receiving three doses of the vaccine. “Family member” is an individual who meets the definition of that term in OPM’s leave regulations (see 5 CFR 630.201).  Please notify your supervisor before using any of this leave.
3. Onsite Contractors
   
   For existing EEOC contract or contract-like instruments (“contracts”) that contain a clause implementing requirements of Executive Order 14042 (Sept. 9, 2021), Executive Order on Ensuring Adequate COVID Safety Protocols for Federal Contractors, the EEOC will take no action to enforce the clause implementing requirements of Executive Order 14042, absent further written notice, where the place of performance identified in the contract is in a U.S. state or outlying area subject to a court order prohibiting the application of requirements pursuant to the Executive Order.
   
   However, federal agency COVID-19 workplace safety protocols for federal buildings and Federally controlled facilities still apply in all locations.  Contractor employees working onsite in those buildings and facilities must still follow federal agency workplace safety protocols when working onsite.
   
   Additional information related to contractors may be found at COVID-19 Workplace Safety: Guidance for Federal Contractors and Subcontractors.
4. Visitors
   
   The number of visitors to EEOC workplaces should be minimized, and employees must make efforts to conduct visits virtually where possible.  Specifically, visitors will be restricted to essential, time-sensitive, scheduled visits only.  All visitors will be asked to complete the Certification of Vaccination Form before entering the workplace.  Visitors are expected to show the completed form upon entry into a Federal building or Federally controlled indoor worksite and then keep the form on their person while they are inside a federal building or federal worksite. Agencies should not collect or maintain visitors’ Certification of Vaccination Forms at this time. The EEOC will not ask visitors for supporting vaccination documentation.
   
   Visitors who are not fully vaccinated or decline to provide information about their vaccination status must provide proof of a negative COVID-19 test completed no later than the previous three (3) days and comply with masking and physical distancing requirements for individuals who are not fully vaccinated consistent with the requirements for visitors in the Face Masks and Physical Distancing section below. Visitors in areas of high or substantial transmission must wear a mask in public indoor settings regardless of vaccination status.
5. Recipients of EEOC Services 
   
   The requirements related to the provision of information about vaccination and provision of proof of a recent negative COVID-19 test do not apply to members of the public entering a federal building or federal work site to obtain a public service or benefit (e.g., charging parties, potential charging parties, mediation participants). 

VII. Face Masks and Physical Distancing

1. General Rules for Masking and Physical Distancing
   
   Individuals who are not fully vaccinated must wear a mask regardless of community transmission level in an EEOC facility.  In areas of high or substantial transmission, everyone, including fully vaccinated people, must wear a mask in an EEOC facility, except for limited exceptions discussed in this section.  Levels of community transmission can be identified by consulting the CDC's COVID Data Tracker County View. 
   
   In areas of low or moderate transmission, in most settings, fully vaccinated individuals generally do not need to wear a mask or physically distance in EEOC facilities, except where required by federal, state, local, Tribal, or territorial laws, rules, or regulations.  Of course, fully vaccinated individuals may choose to wear a mask regardless of the level of transmission for a variety of reasons.  Nothing in CDC guidance or this Safety Plan precludes an employee from wearing a mask, if the employee so chooses.  CDC’s guidance for mask wearing and physical distancing in specific settings, including healthcare, transportation, correctional and detention facilities, and schools, should be followed, as applicable.
   
   Individuals who are not fully vaccinated or who decline to provide their vaccination status—including employees, onsite contractors, visitors, and members of the public who are seeking a public service or benefit—must maintain physical distance and properly wear masks. To the extent practicable, individuals who are not fully vaccinated or who decline to provide information about their vaccination status should maintain a physical distance of at least six feet from others at all times, consistent with CDC guidelines, including in offices, conference rooms, and all other communal and work spaces.
2. Implementation of General Rules
   
   For individuals who are required to wear a mask:
   • Appropriate masks should be worn consistently and correctly (over mouth and nose).
   • Appropriate masks should be worn in any common areas or shared workspaces (including hallways, restrooms, facility entrances, elevators, breakrooms, dining facilities, open floorplan office space, cubicle embankments, and conference rooms).
   • In general, people do not need to wear masks when outdoors.  However, consistent with CDC guidance, those who are not fully vaccinated should wear a mask in crowded outdoor settings or during outdoor activities that involve sustained close contact with other people who are not fully vaccinated.
     
     Exceptions may be made consistent with CDC guidelines, for example, when an individual is alone in an office with floor to ceiling walls and a closed door, or for a limited time when eating or drinking and maintaining physical distance in accordance with CDC guidelines.  In addition, individuals may be asked to lower their masks briefly for identification purposes in compliance with safety and security requirements.
3. Appropriate masks
   
   Appropriate masks must cover the mouth and nose and comply with current CDC guidance.  CDC recommends the following:  disposable masks, masks that fit properly (snugly around the nose and chin with no large gaps around the sides of the face), masks made with breathable fabric (such as cotton), masks made with tightly-woven fabric (i.e., fabrics that do not let light pass through when held up to a light source), masks with two or three layers, and masks with inner filter pockets.  The EEOC will not allow novelty or non-protective masks, masks with ventilation valves, or face shields as a substitute for masks.
4. Employee Compliance
   
   Employees are expected to adhere to masking and distancing requirements.  Failure to do so (absent an approved reasonable accommodation) may result in progressive disciplinary action.  The Coordination Team will provide additional guidance for implementing this policy, following satisfaction of applicable collective bargaining obligations.
   
   EEOC leadership and security personnel will enforce compliance with masking requirements.  Supervisors who need assistance in addressing employees who are not following this Safety Plan, including adhering to masking and physical distancing requirements, should contact the Employee Labor Relations Team.  The Employee Labor Relations Team will coordinate with the COVID-19 Coordination Team and senior leadership, as appropriate.
5. Signage and Supplies
   
   Signage will be posted to notify employees, contractors, and visitors of mask and distancing requirements consistent with federal guidance.
   
   At EEOC headquarters, masks will be available to those who do not have one, including members of the public and nonemployees.  District offices should procure masks to make them available to those who do not have one, including members of the public and nonemployees.
6. Reasonable Accommodations
   
   Some individuals may require accommodations or modifications under applicable law relating to masking requirements.  See generally What You Should Know About COVID-19 and the ADA, the Rehabilitation Act, and Other EEO Laws |Reasonable Accommodation Section D.|U.S. Equal Employment Opportunity Commission (eeoc.gov)
   
   EEOC employees seeking a reasonable accommodation for disability or medical reasons should contact the Accommodations Manager at disability.program@eeoc.gov.  Employees seeking an accommodation based on a sincerely held religious belief, practice, or observance should contact the Accommodations Manager at religious.accommodation@eeoc.gov.

VIII.  Testing for COVID-19:  Employees and Onsite Contractors

In accordance with federal guidance, The EEOC may establish a program to test EEOC employees and contractors working onsite who are not fully vaccinated due to a legally required exception.  Additional guidance is forthcoming from the Safer Federal Workforce Taskforce on testing protocols for individuals who are excepted from the vaccination requirement and the Safety Plan will be updated accordingly when that information is available.

The EEOC will also implement a process for employee diagnostic testing after a workplace exposure. 

IX.  Symptom Monitoring for COVID-19:  Employees, On-Site Contractors, Visitors, and Service Recipients

The EEOC requires employees, onsite contractors, visitors, and service recipients to complete virtual or in-person health checks before entering our offices.

The health check is adapted from the tool developed by the CDC and asks about symptoms, close contact with someone with COVID-19, and COVID-19 testing and diagnosis status).  The EEOC will use this information to assess the individual’s risk level and to determine whether the individual should be allowed entry to the workplace.

If EEOC employees, on-site contractors, visitors, or service recipients have symptoms consistent with COVID-19, they should not enter any EEOC facility.  Employees and onsite contractors should contact their supervisor to arrange telework or take leave as applicable.

Any employee or onsite contractor, regardless of vaccination status, who develops any symptoms consistent with COVID-19 during the workday must immediately isolate, wear a mask (if the individual is not already doing so and one is available), notify their supervisor, and promptly leave the workplace. The EEOC has processes in place to provide advice and support to supervisors on any related reporting or HR requirements.

X.    Quarantine, Isolation, and Steps for Individuals Following Exposure to Someone with Suspected or Confirmed COVID-19

1. Definitions:
   
   (1)       Quarantine keeps someone who might have been exposed to the virus away from others. 
   (2)       Isolation keeps someone who is infected with the virus away from others, even if they don’t have symptoms. 
2. General Rule:  Any individual with a suspected or confirmed case of COVID-19 will be advised to isolate pursuant to CDC guidelines and in compliance with State, local, and Tribal laws and regulations.

Individuals who are Not Fully Vaccinated

Individuals who are not fully vaccinated and who have had a close contact with someone who has tested positive for COVID-19 should follow CDC and state, local, and Tribal guidance for quarantine.

Individuals who are Fully Vaccinated  

Individuals who are fully vaccinated and have had close contact with someone with suspected or confirmed COVID-19 should get tested 3-5 days after exposure, even if they do not have symptoms.  They should also wear a mask indoors in public for 14 days following exposure or until their test result is negative.  If their test result is positive, they should isolate for 5 days.

Employees and contractors who are in isolation or quarantine should not return to the workplace until approved by their supervisor.  Employees who wish and are able may telework during any periods of quarantine or isolation.  Alternatively, they may apply for the appropriate leave.

XI.   Contact Tracing:  Employees & Onsite Contractors

The COVID-19 Coordination Team will collaborate with and support the contact tracing programs of local health departments to help identify, track, and manage contacts of COVID-19 cases.  

Employees and contractors who have been on site at an EEOC office should report known or suspected cases of COVID-19 (due either to specific symptoms or a positive test) to their supervisor, who must notify the COVID-19 Coordination Team. 

The COVID-19 Coordination Team will ensure that the agency makes disclosures to local public health officials, as required or necessary, to provide for the health and safety of EEOC employees, onsite contractor employees, and the general public, in accordance with local public health mandates. 

If COVID-19 cases occur within a specific building or work setting, it will be the responsibility of the COVID-19 Coordination Team (or a district office/designee) to determine—in consultation with local public health officials—appropriate next steps.  The COVID-19 Coordination Team will coordinate with facilities staff to implement infection control and workplace safety efforts once informed of a known or suspected case of COVID-19 (due either to specific symptoms or a positive test).  The EEOC will be transparent in communicating related information to the workforce, as relevant and appropriate and consistent with federal, state, and local privacy and confidentiality laws and regulations.

XII.         Travel:  EEOC Employees

EEOC employees who are fully vaccinated currently are not subject to any government-wide restrictions on official travel, although agency travel policies still apply. Federal employees who are fully vaccinated not need to get tested before or after domestic travel or self-quarantine after travel, unless required by their destination.  However, all air passengers coming to the United States from abroad, including federal employees who are fully vaccinated, are required to have a negative COVID-19 test result no more than three days before the flight to the United States departs or must show documentation of recover from COVID-19 within the previous 90 days before they board a flight to the United States.  Also, after traveling abroad, fully vaccinated employees should get tested for COVID-19 within 3-5 days after traveling; self-monitor for COVID-19 symptoms; if symptoms develop, isolated and get tested; and follow all recommendations or requirements of their local U.S. destination after travel.

EEOC employees who are not fully vaccinated are subject to government-wide restrictions on official travel.  For the limited number of EEOC employees who are not fully vaccinated, unless it is contrary to a reasonable accommodation to which an employee is legally entitled, official domestic travel should be limited to only necessary, mission-critical trips.  International travel should also be avoided, if at all possible, unless it is mission critical (e.g., military deployments, COVID-19 response deployments or activities, or high-level activities that cannot occur remotely).  The COVID-19 Coordination Team, in consultation with the Office of the Chair, will issue specific guidance to account for the particulars of the EEOC’s mission.

EEOC employees should adhere strictly to CDC guidelines before, during, and after travel.

XIII.         Meetings, Events, and Conferences

In the event the EEOC intends to host an in-person meeting, conference, or event that will be attended by more than 50 participants—regardless of whether participants include members of the public—the meeting organizer must first seek the approval of the Chair, in consultation with the COVID-19 Coordination Team.

Visitors and in-person attendees at any meetings, conferences, and events hosted by an agency, regardless of size, must be asked to provide information about vaccination status.  In requesting this information, EEOC will comply with any applicable federal laws, including requirements under the Privacy Act and the Paperwork Reduction Act. 

Visitors and in-person attendees who are not fully vaccinated or decline to provide information about their vaccination status must provide proof of a negative COVID-19 test completed no later than the previous three (3) days and comply with masking and physical distancing requirements for individuals who are not fully vaccinated consistent with the requirements for visitors in the Face Masks and Physical Distancing section above. 

Visitors and in-person attendees in areas of high or substantial transmission must wear a mask in public indoor settings regardless of vaccination status.

XIV.       Environmental Cleaning and Disinfection

The EEOC will ensure regular cleaning of common use, high-touch, and high-density spaces, such as lobbies, restrooms, elevators, and stairwells.  Office space in regular use will be cleaned regularly in accordance with CDC guidelines.  Wipes and other Environmental Protection Agency-approved disinfectants will be made available for use by individuals to wipe down workstations and related personal property.  Physical barriers such as plexiglass shields may be installed where appropriate.

In the event of a suspected or confirmed case of COVID-19 in the workplace, enhanced environmental cleaning of the spaces that the individual occupied or accessed will be performed in accordance with CDC and, where applicable, GSA guidance, which provides as follows: 

• If fewer than 24 hours have passed since the person who is sick or diagnosed with COVID-19 has been in the space, clean and disinfect the space.
• If more than 24 hours have passed since the person who is sick or diagnosed with COVID-19 has been in the space, cleaning is enough.  The EEOC may choose to also disinfect depending on certain conditions or everyday practices required by each facility.
• If more than 3 days have passed since the person who is sick or diagnosed with COVID-19 has been in the space, no additional cleaning (beyond regular cleaning practices) is needed.

If enhanced cleaning is required, the EEOC will wait as long as possible (at least several hours) before cleaning and disinfecting.  Extended wait periods allow increased opportunity for viral deactivation to occur naturally, while also allowing time for aerosols to settle, prior to surface disinfection.  Personnel and visitors will be asked to vacate the affected space until cleaning and disinfection is completed.

The EEOC’s COVID-19 Coordination Team, in conjunction with district offices, as appropriate, will determine the appropriate scope of workplace closures needed—in some cases, it may be a suite or individual offices or part of a floor, in other cases, it may include an entire building.

XV.         Hygiene

Hand sanitizer stations will be available at building entrances and throughout workspaces.  Hand sanitizers should contain at least 60% alcohol and be manufactured in accordance with the requirements of the U.S. Food and Drug Administration (FDA). Ingredients should be listed on a “Drug Facts” label.  EEOC will ensure the hand sanitizer is not on the FDA’s do not use list.

XVI.       Ventilation and Air Filtration

Modifications to ventilation systems will be considered in accordance with CDC’s COVID-19 ventilation recommendations, especially as building population density increases.  To the maximum extent feasible, indoor ventilation will be optimized to increase the proportion of outdoor air and improve filtration.  Deployment of portable high-efficiency particulate air (HEPA) cleaners will be considered for higher-risk spaces (e.g., intake rooms).

Where compliance with CDC ventilation and air filtration recommendations is not feasible in a particular office, the COVID-19 Coordination Team will evaluate mitigating measures.

XVII.      Collective Bargaining Obligations

Consistent with President Biden’s policy to support collective bargaining and EEOC’s commitment to working with its union, the EEOC will satisfy applicable collective bargaining obligations under 5 U.S.C. Chapter 71 when implementing this Safety Plan and any updates, including on a post-implementation basis where necessary.  In addition, the EEOC communicates regularly with employee representatives on workplace safety matters.

XVIII.     Confidentiality and Privacy

All medical information collected from individuals, including vaccination information, test results, and any other information obtained as a result of testing or symptom monitoring, will be treated in accordance with applicable laws and policies on confidentiality and privacy, and will be accessible only to those with a need to know.  Retention of employee information conforms with the confidentiality requirements of Section 501 of the Rehabilitation Act.

XIV.       Modifications to Safety Plan

As noted above, the principles presented here are aligned with the latest guidance from the CDC, OSHA, and the Safer Federal Workforce Taskforce based on evolving understanding of the pandemic.  These principles, and the Safety Plan itself, will be reassessed over time as conditions warrant and as CDC guidelines are updated.