Sue, you make an excellent point here about Check Facilities 2 (highlighted below).  If that is the expectation, then what would a draft guidance need to include in order to improve the odds that a facility is not ‘scammed’ as you suggest?  I agree wholeheartedly that this is fraught with risk, which is why I like the idea of changing the phrase from “Consider verification testing to ensure disinfection of contact surfaces” to something more specific and prescriptive such as “Request verification testing of sample surfaces at the end of the required dwell time to ensure proper chemical application was used in accordance with EPA List N to disinfect contact surfaces for the pathogen(s) of concern.”  This would seem to mitigate the risk of misapplication, inappropriately dilute chemistry, etc.  Would be interesting to hear others’ thoughts on that approach. 

Dom DeCaria

	Domenic DeCaria | Technical Director The Vinyl Institute 1747 Pennsylvania Ave NW Ste 825 | Washington, DC 20006 O: (202) 765-2179 | M: (202) 341-5226

A few questions, if I may, since the posted ideas were a starting point looking for feedback:

I’m setting aside Check Facilities 1 & 3, which are more about considering the passage of time in unused facilities (and useful!)

I won’t comment much on Check Facilities 2 & 4. Although they do not seem particularly feasible to me, especially for small companies, or large companies without in-house expertise… I guess the expectation is that everyone will pay professional cleaners to do the second, rely on their guarantee, and hope not to get scammed by unqualified folks, and we’ll all get larger workplaces with smaller workforces to enable the fourth.

The information chains for the last three portions are generally good – adapted to local communication chains and bureaucracy, perhaps.

The entry conditions are perhaps the most problematic. How do you establish COVID 19 symptoms that don’t overlap with allergies? Mass transit exclusion is impractical. Just walking on a busy sidewalk could be as risky, and if you do have a car, park and then walk to workplace... do you re-check everyone if they go out for lunch or an off-site meeting? There is a lot of really creative work in trying to control where people stand, enter, exit…but they all seem to work best at low densities, and our world does not completely function at low densities.

And in general....

Why do we think that everyone will abide by such stringent requirements...forever? People on this list have safety experience (most more than me) and know compliance with extreme measures requires high hazard and risk thoroughly explained and obviously present, requires shorter shifts due to the stress, and, perhaps, the ability to fire people who don’t follow the rules. How is this pandemic sufficiently different from influenza, Zika, or AIDS to convince people to live with stringent protocols for months or years? Please note I’m not saying the virus isn’t different – I’m talking about societal response.

I guess hope springs eternal that “this time” will be the event that permanently changes human behavior – but I’m not convinced there is a stick large enough to get compliance with some of the ideas I’m hearing (not just from this listserv) from the size populations that folks are trying to control.

I delayed in sending this, but was reminded by the upcoming document from CSHEMA…I value reading all of the re-opening documents that folks have shared, and think that some of the ideas are useful to discuss – but haven’t seen one yet that seems likely to work broadly. Maybe thinking practically opens up people to too much liability?

Sue

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