Health and Safety Considerations for Reopening Public Schools

Health and Safety Committees and Risk Assessment

One of the root causes of workplace injuries, illnesses and incidents is failing to identify hazards that are present or could be anticipated. A critical element of any effective safety and health program is a proac- tive, ongoing process to identify and assess such hazards.

A crucial part of this process is called a workplace hazard assessment or risk assessment. Currently, we are advocating for schools to begin this process now in order to assess the workplace and identify poten- tial hazards related to COVID-19. Once the school is assessed, the administration must use appropriate combinations of controls to limit the spread of COVID-19. Controls may include workplace administrative practices, engineering controls like plastic barriers or personal protective equipment (PPE). It is important to be sure to protect the most vulnerable. To understand who these people are, keep in mind the following: Risk Level = Probability of exposure to COVID-19 + the severity of the consequences if exposed.

As we have established, all effective health and safety programs are created with input from labor partners. One way we can ensure union participation is through health and safety committees.

Thankfully, under the state’s Rebuild Schools to Uphold Education (RESCUE) Law of 1998, health and safety committees are required in all school districts. These committees must include representation from district officials and representatives from staff and teacher unions. All plans for reopening should be discussed collectively by this committee.

Create a plan to protect the school community

At a minimum, your school’s health and safety plan to address COVID-19 should include the following controls:

1. Establish policies and practices for social distancing

Workspaces may need to be altered to help staff maintain social distancing. A best practice is a defined workspace when possible. This space consists of the area six feet around a worker’s post, including every item within this six-foot space. This space is not to be shared. If staff need to share items, they must be included in the disinfection routine. For students, the use of shared items should also be limited when possible or cleaned between uses per CDC guidance.

2. Provide employees and students with what they need to clean their hands, cover their coughs and sneezes and protect themselves and others from the spread of bacteria

Make sure your plan includes ensuring that there are cleaning supplies and proper PPE for staff and students. Your school should:

• Provide tissues and no-touch trash cans
• Provide soap and water in the workplace
• Place posters that encourage hand hygiene to help stop the spread of the virus at the school entrance and in other workplace areas where they are likely to be seen
• Ensure that all staff wear face coverings per CDC and state guidelines and encourage students to wear them as well

3. Enhance cleaning practices

In New York State, all primary and secondary schools, state agencies and state authorities are required to use green cleaning products. For more information on the approved green cleaning products, visit The New York Green Cleaning Program. Disinfectants are not part of this law; your school’s Hazard Communication Program will list all products (cleaners or disinfectants) that are to be used, the type of personal protective equipment needed to use the product safely and how staff will be trained on their usage. It’s important that the local knows what cleaning products the district is using and how the district trains staff on the use of these products. If staff, other than trained custodial staff, need to assist with classroom cleaning, they should use a district-provided basic cleaner. A third-party certified green cleaner is required.

4. Ensure indoor environmental quality

COVID-19 can become airborne at different times, including when people sneeze, cough and even speak. Fresh air and an effective ventilation system are crucial to the well-being of the indoor occupants. For more information on effective ways to ensure proper ventilation and indoor environmental quality, visit the website of ASHRAE (American Society of Heating, Refrigerating and Air-Conditioning Engineers).

5. Plan for isolating symptomatic staff, students or members of the public

Staff and students who appear to have symptoms upon arrival to school or who become sick during the day should immediately be separated from others. Schools should identify an isola- tion room or area to separate anyone who has COVID-19 symptoms or tests positive but does not have symptoms. School nurses and other healthcare providers should use Standard and Transmission-Based Precautions when caring for sick people. NYSUT believes there should be a nurse in every school. If there is not, staff that are identified as responsible for caring for sick individuals must be provided with appropriate PPE and trained on standard and transmission-based precautions.

6. Plan for a confirmed case of COVID-19 in the school community

The New York State Department of Health currently requires an initial 24-hour closure in order to begin the investigation to determine the contacts the individual may have had within the school. Schools must be prepared for the possibility of schools not reopening for some time after a confirmed case. More on the current guidelines can be found here (Last update March 9, 2020): School Guidance from DOH and SED.

7. Reduce and prevent psychological risks; promote mental health well-being

All health and safety control measures must be implemented to promote mental health and well-being and to prevent and reduce psychosocial risks, including violence and harassment. Steps include:

• Frequent communication and up-to-date information should be shared directly with staff.
• The employer should create a venue for staff to express concerns and ask questions about health risks.
• The school’s labor-management health and safety committee can conduct multidisciplinary sessions to work together on strategies to solve problems and identify concerns, including the well-being of staff.
• A system is needed to provide psychological support and monitor stress and burnout.

Training and Communication

It is the employer’s responsibility to ensure that all policies or procedures in a health and safety program are followed. To do this, your school must include your local in the risk assessment process and clearly communicate with the school community about how they plan to protect every- one. Training staff on the plan is crucial. In the case of staff who will be cleaning and disinfecting, the school is required to provide them with specific training required by the NYS Department of Labor. You can learn more here: Hazard Communication.

Additional training on how to report health and safety concerns is essential. Your school should already have this system in place. Reporting a health and safety concern should not be punished and all concerns must be reviewed by the health and safety committee and responded to by the school’s administration. To learn more about your school’s responsibility to collect, review and respond to health and safety concerns, visit Part 155.4(d)(7) of the State Education Rules and Regulations.

For more detailed information on the elements of a plan, reopening FAQ’s and other resources, go to the Health and Safety section of the online Coronavirus Toolkit at  www.nysut.org/coronavirus or contact your NYSUT regional office.