COVID-19 Prevention Program (CPP) for Neris Beauty
This CPP is designed to control employees’ exposures to the SARS-CoV-2 virus (COVID-19) that may occur in our workplace.
Authority and Responsibility
Neris Beauty has overall authority and responsibility for implementing the provisions of this CPP in our workplace. In addition, all managers and supervisors are responsible for implementing and maintaining the CPP in their assigned work areas and for ensuring employees receive answers to questions about the program in a language they understand.
All employees are responsible for using safe work practices, following all directives, policies and procedures, and assisting in maintaining a safe work environment.
Identification and Evaluation of COVID-19 Hazards
We implement the following in our workplace:
- Conduct workplace-specific evaluations using the Appendix A: Identification of COVID-19 Hazards form.
- Document the vaccination status of our employees by using Appendix E: Documentation of Employee COVID-19 Vaccination Status, which is maintained as a confidential medical record.
- Evaluate employees’ potential workplace exposures to all persons at, or who may enter, our
- Develop COVID-19 policies and procedures to respond effectively and immediately to individuals at the workplace who are a COVID-19 case to prevent or reduce the risk of transmission in the workplace.
- Review applicable orders and general and industry-specific guidance from the State of California, Cal/ OSHA, and the local health department related to COVID-19 hazards and
- Evaluate existing COVID-19 prevention controls in our workplace and the need for different or additional
- Conduct periodic inspections using the Appendix B: COVID-19 Inspections form as needed to identify and evaluate unhealthy conditions, work practices, and work procedures related to COVID-19 and to ensure compliance with our COVID-19 policies.
Employees and their authorized employees’ representatives are encouraged to participate in the identification and evaluation of COVID-19 hazards.
Correction of COVID-19 Hazards
Unsafe or unhealthy work conditions, practices or procedures are documented on the Appendix B: COVID-19 Inspections form, and corrected in a timely manner based on the severity of the hazards, as follows:
- The severity of the hazard will be assessed, and correction time frames assigned,
- Individuals are identified as being responsible for timely
- Follow-up measures are taken to ensure timely
Control of COVID-19 Hazards
We provide clean, undamaged face coverings and ensure they are properly worn by employees that are not fully vaccinated when they are indoors or in vehicles, and where required by orders from the
California Department of Public Health (CDPH).
Employees required to wear face coverings in our workplace may remove them under the following conditions:
- When an employee is alone in a room or a
- While eating or drinking at the workplace, provided employees are at least six feet apart and outside air supply to the area, if indoors, has been maximized to the extent
- Employees are required to wear respirators in accordance with our respirator program that meets section 5144
- Employees who cannot wear face coverings due to a medical or mental health condition or disability, or who are hearing-impaired or communicating with a hearing-impaired person. Such employees will wear an effective, non-restrictive alternative, such as a face shield with a drape on the bottom, if their condition permits
- Specific tasks that cannot feasibly be performed with a face This exception is limited to the time in which such tasks are being performed.
Any employee not wearing a required face covering or allowed non-restrictive alternative, will be at least six feet apart from all other persons unless the unmasked employee is either fully vaccinated or tested at least weekly for COVID-19.
We will not prevent any employee from wearing a face covering when it is not required unless it would create a safety hazard, such as interfering with the safe operation of equipment.
Face coverings will also be provided to any employee that requests one, regardless of their vaccination status.
For indoor locations, using Appendix B, we identify and evaluate how to maximize, to the extent feasible, ventilation with outdoor air using the highest filtration efficiency compatible with our existing ventilation system, and whether the use of portable or mounted High Efficiency Particulate Air (HEPA) filtration units, or other air cleaning systems, would reduce the risk of transmission by:
- Circumstances where the amount of outside air needs to be minimized due to other hazards, such as heat, wildfire smoke, or when the EPA Air Quality Index is greater than 100 for any
- How the ventilation system will be properly maintained and adjusted, whether you own and operate the building, or not.
- How to maximize, to the extent feasible, the amount of outside air and increase filtration efficiency to the highest level compatible with the existing ventilation
- How to implement use of portable or mounted HEPA filtration if we determine such use would reduce the risk of COVID-19
- Applicable orders and guidance from the State of California and your local health department related to COVID-19 hazards and prevention, including CDPH’s Interim Guidance for Ventilation, Filtration, and Air Quality in Indoor Environments.
Cleaning and disinfecting
We implement the following cleaning and disinfection measures for frequently touched surfaces and objects, such as doorknobs, elevator buttons, equipment, tools, handrails, handles, controls, phones, headsets, bathroom surfaces, and steering wheels:
- Ensure adequate supplies and adequate time for it to be done
- Inform the employees and authorized employee representatives of the frequency and scope of cleaning.
Should we have a COVID-19 case in our workplace, we will implement the following procedures:
To implement effective hand sanitizing procedures, we:
- Evaluate handwashing facilities.
- Determine the need for additional
- Encourage and allowing time for employee
- Provide employees with an effective hand sanitizer, and prohibit hand sanitizers that contain methanol (i.e., methyl alcohol).
- Encourage employees to wash their hands for at least 20 seconds each
Personal protective equipment (PPE) used to control employees’ exposure to COVID-19
We evaluate the need for PPE (such as gloves, goggles, and face shields) as required by section 3380, and provide and ensure use of such PPE as needed.
Upon request, we provide respirators for voluntary use to all employees who are not fully vaccinated and who are working indoors or in vehicles with more than one person.We provide and ensure use of respirators in compliance with section 5144 when deemed necessary by Cal/OSHA.
We also provide and ensure use of eye and respiratory protection when employees are exposed to procedures that may aerosolize potentially infectious material such as saliva or respiratory tract fluids.
Testing of symptomatic employees
We make COVID-19 testing available at no cost to employees with COVID-19 symptoms who are not fully vaccinated, during employees’ paid time.
Investigating and Responding to COVID-19 Cases
We have developed effective procedure to investigate COVID-19 cases that include seeking information from our employees regarding COVID-19 cases, close contacts, test results, and onset of symptoms. This is accomplished by using the Appendix C: Investigating COVID-19 Cases form.
We also ensure the following is implemented:
Employees that had a close contact are offered COVID-19 testing at no cost during their working hours, excluding:
- Employees who were fully vaccinated before the close contact and do not have
- COVID-19 cases who were allowed to return to work per our return-to-work criteria and have remained free of symptoms for 90 days after the initial onset of symptoms, or for cases who never developed symptoms, for 90 days after the first positive test.
- The information on benefits described in Training and Instruction, and Exclusion of COVID-19 Cases, below, will be provided to employees.
- Written notice within 1 day of your knowledge of a COVID-19 case that people at the worksite may have been exposed to COVID-19. This notice will be provided to all employees (and their authorized representative), independent contractors and other employers at the worksite during the high-risk exposure period. These notifications must meet the requirements of T8CCR section 3205(c)(3)(B) and Labor Code section 6409.6(a)(4); (a)(2); and (c), and in a form readily understandable by employees and can be anticipated to be received by the ]
System for Communicating
Our goal is to ensure that we have effective two-way communication with our employees, in a form they can readily understand, and that it includes the following information:
- Who employees should report COVID-19 symptoms, possible close contacts and hazards to.
- That employees can report symptoms, possible close contacts and hazards without fear of losing their job.
- Access to COVID-19 testing when testing is required.
- The COVID-19 hazards employees (including other employers and individuals in contact with our
workplace) may be exposed to, what is being done to control those hazards, and our COVID-19 policies and procedures.
Training and Instruction
We provide effective employee training and instruction that includes:
- Our COVID-19 policies and procedures to protect employees from COVID-19 hazards, and how to participate in the identification and evaluation of COVID-19
- Information regarding COVID-19-related benefits (including mandated sick and vaccination leave) to which the employee may be entitled under applicable federal, state, or local
- The fact that:
- COVID-19 is an infectious disease that can be spread through the
- COVID-19 may be transmitted when a person touches a contaminated object and then touches their eyes, nose, or
- An infectious person may have no
- The fact that particles containing the virus can travel more than six feet, especially indoors, so physical distancing, face coverings, increased ventilation indoors, and respiratory protection decrease the spread of COVID-19 and are most effective when used in
- The right of employees that are not fully vaccinated to request a respirator for voluntary use, without fear of retaliation, and our policies for providing the Employees voluntarily using respirators will be trained according to section 5144(c)(2) requirements:
- How to properly wear
- How to perform a seal check according to the manufacturer’s instructions each time a respirator is worn, and the fact that facial hair can interfere with a
- The importance of frequent hand washing with soap and water for at least 20 seconds and using hand sanitizer when employees do not have immediate access to a sink or hand washing facility, and that hand sanitizer does not work if the hands are
- Proper use of face coverings and the fact that face coverings are not respiratory protective equipment. Since COVID-19 is an airborne disease, N95s and more protective respirators protect the users from airborne disease, while face coverings primarily protect people around the
- The conditions where face coverings musts be worn at the
- That face coverings are additionally recommended outdoors for people who are not fully vaccinated if six feet of distance cannot be
- Employees can request face coverings and can wear them at work regardless of vaccination status and without fear of
- COVID-19 symptoms, and the importance of obtaining a COVID-19 test and not coming to work if the employee has COVID-19
- Information on our COVID-19 policies and how to access COVID-19 testing and vaccination, and the fact that vaccination is effective at preventing COVID-19, protecting against both transmission and serious illness
Exclusion of COVID-19 Cases and Employees who had a Close Contact
Where we have a COVID-19 case or close contact in our workplace, we limit transmission by:
- Ensuring that COVID-19 cases are excluded from the workplace until our return-to-work requirements are met.
- Excluding employees that had a close contact from the workplace until our return-to-work criteria have been met, with the following exceptions:
- Employees who were fully vaccinated before the close contact and who do not develop COVID-19
- COVID-19 cases who returned to work per our return-to-work criteria and have remained free of COVID-19 symptoms, for 90 days after the initial onset of COVID-19 symptoms, or for COVID-19 cases who never developed COVID-19 symptoms, for 90 days after the first positive
- For employees excluded from work, continuing, and maintaining employees’ earnings, wages, seniority, and all other employees’ rights and benefits.
- Providing employees at the time of exclusion with information on available
Reporting, Record keeping, and Access
It is our policy to:
- Report information about COVID-19 cases and outbreaks at our workplace to the local health department whenever required by law, and provide any related information requested by the local health
- Maintain records of the steps taken to implement our written COVID-19 Prevention Program in accordance with section 3203(b).
- Make our written COVID-19 Prevention Program available at the workplace to employees, authorized employee representatives, and to representatives of Cal/OSHA immediately upon
- Use the Appendix C: Investigating COVID-19 Cases form to keep a record of and track all COVID-19
COVID-19 cases with symptoms will not return to work until all the following have occurred:
- At least 24 hours have passed since a fever of 4 °F. or higher has resolved without the use of fever-reducing medications, and
- COVID-19 symptoms have improved, and
- At least 10 days have passed since COVID-19 symptoms first
- COVID-19 cases who tested positive but never developed symptoms will not return to work until a minimum of 10 days have passed since the date of specimen collection of their first positive COVID-19
- A negative COVID-19 test will not be required for an employee to return to work once the requirements for “cases with symptoms” or “cases who tested positive but never developed symptoms” (above) have been
- Persons who had a close contact may return to work as follows:
- Close contact but never developed symptoms: when 10 days have passed since the last known close contact.
- Close contact with symptoms: when the “cases with symptoms” criteria (above) have been met, unless the following are true:
- The person tested negative for COVID-19 using a polymerase chain reaction (PCR) COVID-19
test with specimen taken after the onset of symptoms; and
- At least 10 days have passed since the last known close contact, and
- The person has been symptom-free for at least 24 hours, without using fever-reducing
- If an order to isolate, quarantine, or exclude an employee is issued by a local or state health official, the employee will not return to work until the period of isolation or quarantine is completed or the order is
Appendix A: Identification of COVID-19 Hazards
All persons, regardless of symptoms or negative COVID-19 test results, will be considered potentially infectious. Particular attention will be paid to areas where people may congregate or come in contact with one another, regardless of whether employees are performing an assigned work task or not. For example: meetings, trainings, entrances, bathrooms, hallways, aisles, walkways, elevators, break or eating areas, cool-down areas, and waiting areas.
Evaluation of potential workplace exposure will be to all persons at the workplace or who may enter the workplace, including coworkers, employees of other entities, members of the public, customers or clients, and independent contractors. We will consider how employees and other persons enter, leave, and travel through the workplace, in addition to addressing stationary work.
Multiple COVID-19 Infections and COVID-19 Outbreaks
- We provide COVID-19 testing at no cost to all employees, during paid time, in our exposed group except for:
- Employees who were not present during the relevant 14-day
- Employees who were fully vaccinated before the multiple infections or outbreak and who do not have
- COVID-19 cases who did not develop symptoms after returning to work pursuant to our return-to- work criteria, no testing is required for 90 days after the initial onset of symptoms or, for COVID-19 cases who never developed symptoms, 90 days after the first positive
- COVID-19 testing consists of the following:
- All employees in our exposed group are immediately tested and then again one week later. Negative COVID-19 test results of employees with COVID-19 exposure will not impact the duration of any quarantine, isolation, or exclusion period required by, or orders issued by, the local health
- After the first two COVID-19 tests, we continue to provide COVID-19 testing once a week of employees in the exposed group who remain at the workplace, or more frequently if recommended by the local health department, until there are no new COVID-19 cases detected in our workplace for a 14-day
- We provide additional testing when deemed necessary by Cal/OSHA.
We continue to comply with the applicable elements of our CPP, as well as the following:
- Employees in the exposed group wear face coverings when indoors, or when outdoors and less than six feet apart (unless one of the face-covering exceptions indicated in our CPP apply).
- We give notice to employees in the exposed group of their right to request a respirator for voluntary use if they are not fully vaccinated.
- We evaluate whether to implement physical distancing of at least six feet between persons, or where six feet of physical distancing is not feasible, the need for use of cleanable solid partitions of sufficient size to reduce COVID-19
COVID-19 investigation, review, and hazard correction
We immediately perform a review of potentially relevant COVID-19 policies, procedures, and controls and implement changes as needed to prevent further spread of COVID-19.
The investigation and review is documented and includes:
- Investigation of new or unabated COVID-19 hazards including:
- Our leave policies and practices and whether employees are discouraged from remaining home when
- Our COVID-19 testing
- Insufficient outdoor
- Insufficient air
- Lack of physical
- Updating the review:
- Every thirty days that the outbreak
- In response to new information or to new or previously unrecognized COVID-19
- When otherwise
- Implementing changes to reduce the transmission of COVID-19 based on the investigation and We consider:
- Moving indoor tasks outdoors or having them performed
- Increasing outdoor air supply when work is done
- Improving air
- Increasing physical distancing as much as
- Requiring respiratory protection in compliance with section
Buildings or structures with mechanical ventilation
We will filter recirculated air with Minimum Efficiency Reporting Value (MERV) 13 or higher efficiency filters, if compatible with the ventilation system. If MERV-13 or higher filters are not compatible, we will use filters with the highest compatible filtering efficiency. We will also evaluate whether portable or mounted High Efficiency Particulate Air (HEPA) filtration units or other air cleaning systems would reduce the risk of transmission and, if so, implement their use to the degree feasible.
COVID-19 Prevention in Employer-Provided Transportation
Assignment of transportation
To the extent feasible, we reduce exposure to COVID-19 hazards by assigning employees sharing vehicles to distinct groups and ensuring that each group remains separate from other such groups during
transportation, during work activities, and in employer-provided housing. We prioritize shared transportation assignments in the following order:
- Employees residing in the same housing unit are transported in the same
- Employees working in the same crew or workplace are transported in the same
- Employees who do not share the same household, work crew or workplace are transported in the same vehicle only when no other transportation alternatives are
Face coverings and respirators
We ensure that the:
- Face covering requirements of our CPP Face Coverings are followed for employees waiting for transportation, if
- All employees who are not fully vaccinated are provided with a face covering, which must be worn unless an exception under our CPP Face Coverings
- Upon request, we provide respirators for voluntary use in compliance with subsection 5144(c)(2) to all employees in the vehicle who are not fully vaccinated.
We develop, implement, and maintain effective procedures for screening and excluding drivers and riders with COVID-19 symptoms prior to boarding shared transportation.
Cleaning and disinfecting
We ensure that:
- All high-contact surfaces (door handles, seatbelt buckles, armrests, etc.) used by passengers are cleaned to prevent the spread of COVID-19 and are cleaned and disinfected if used by a COVID-19 case during the high-risk exposure period, when the surface will be used by another employee within 24 hours of the COVID-19.
- All high-contact surfaces used by drivers, such as the steering wheel, armrests, seatbelt buckles, door handles and shifter, are cleaned to prevent the spread of COVID-19 between different drivers
and are disinfected after use by a COVID-19 case during the high-risk exposure period, if the surface will be used by another employee within 24 hours of the COVID-19 case.
- We provide sanitizing materials, training on how to use them properly, and ensure they are kept in adequate
We ensure that vehicle windows are kept open, and the ventilation system is set to maximize outdoor air and not set to recirculate air. Windows do not have to be kept open if one or more of the following conditions exist:
- The vehicle has functioning air conditioning in use and excessive outdoor heat would create a hazard to
- The vehicle has functioning heating in use and excessive outdoor cold would create a hazard to
- Protection is needed from weather conditions; such as rain or
- The vehicle has a cabin air filter in use and the U.S. EPA Air Quality Index for any pollutant is greater than
We provide hand sanitizer in each vehicle and ensure that all drivers and riders sanitize their hands before entering and exiting the vehicle. Hand sanitizers with methyl alcohol are prohibited.