FAQ on Worker and Student Safety During COVID-19

The Centers for Disease Control and Prevention (CDC) reports that, "Health officials are currently taking steps to prevent the introduction and spread of COVID-19 into US communities. Schools can play an important role in this effort by preparing to take steps to prevent the spread of COVID-19 among their students and staff, should local health officials identify such a need. School plans should be designed to minimize disruption to teaching and learning and protect students and staff from social stigma and discrimination. Plans can build on everyday practices (e.g., encouraging hand hygiene, monitoring absenteeism, communicating routinely) that include strategies for before, during, and after a possible outbreak." As discussed below, we urge association leaders to meet with district administrators to develop and/or expand existing plans to limit exposure and reduce spread to students and staff.

Districts will be working with local health departments to share resources and develop plans as exposure to the virus becomes more widespread. Likewise, it is important that association and district leaders discuss the many issues impacting students, staff, and schools as the spread of COVID-19 is likely to continue and even accelerate. As explained below, it is important that local associations review their collective bargaining agreements or board policies and engage in discussions, consultation, and/or bargaining with district administration over this situation.

This Advisory will be updated as additional information becomes available. In the meantime, questions should be directed to your local Organizational Consultant.

Frequently Asked Questions

Q. Are hand sanitizers allowed in schools?

Association leaders should insist the district maintain a safe and sanitary school environment, such as by providing adequate sanitary supplies (like alcohol-based hand sanitizer) and additional cleaning of school facilities to prevent the spread of the virus. There is nothing in the law that prohibits the use of alcohol-based hand sanitizers in school settings.

Q. What else can districts and associations do to prepare for the possible spread of the virus?

ARS 15-341 (A)(31) requires every school site to have an emergency response plan that meets the minimum state requirements.  The ADE and the Arizona Division of Emergency Management (ADEM) are responsible for developing the minimum standards for school emergency response plans in Arizona. See minimum standards  

To respond to the current coronavirus, we are urging districts to review a variety of checklists available at the following sites.

National School Boards Association 

Arizona Department of Health and Safety

Center for Disease Control – Keeping the Workplace Safe graphic 

Occupational Safety and Health Administration

• OSHA Standards https://www.osha.gov/SLTC/covid-19/standards.html 
  • Important Note: OSHA does not apply directly to public school districts in Arizona.  However, Arizona state laws on occupational safety and health generally track federal law, and OSHA guidance is useful in several ways.

This section highlights OSHA standards and directives (instructions for compliance officers) and other related information that may apply to worker exposure to novel coronavirus, COVID-19.

There is no specific OSHA standard covering COVID-19. However, some OSHA requirements may apply to preventing occupational exposure to COVID-19. Among the most relevant are:

• OSHA's Personal Protective Equipment (PPE) standards (in general industry, 29 CFR 1910 Subpart I), which require using gloves, eye and face protection, and respiratory protection. 
  • When respirators are necessary to protect workers, employers must implement a comprehensive respiratory protection program in accordance with the Respiratory Protection standard (29 CFR 1910.134). 
    • OSHA has issued temporary guidance related to enforcement of respirator annual fit-testing requirements for healthcare.
• The General Duty Clause, Section 5(a)(1) of the Occupational Safety and Health (OSH) Act of 1970, 29 USC 654(a)(1), which requires employers to furnish to each worker “employment and a place of employment, which are free from recognized hazards that are causing or are likely to cause death or serious physical harm.”

OSHA’s Bloodborne Pathogens standard (29 CFR 1910.1030) applies to occupational exposure to human blood and other potentially infectious materials that typically do not include respiratory secretions that may transmit COVID-19. However, the provisions of the standard offer a framework that may help control some sources of the virus, including exposures to body fluids (e.g., respiratory secretions) not covered by the standard.

Arizona Division of Occupational (ADOSH) – no guidance on coronavirus specifically, but employers are still subject to the same general duty outlined above (but under state law)

If your district does not yet have a plan, or the plan does not address critical issues for the association, you should demand to be included in the development of an adequate plan.

Q. What are other issues local associations should consider in determining if a district plan is adequate?

• Does the plan address how the district will deal with an unusual number of absences of both students and staff? If the district does not have adequate employee resources, is there a plan to obtain additional help?
• Does the plan establish procedures to be followed in the event the district office is closed, such as procedures for paying employees if the staff who process payroll are absent or the payroll office is shut down?
• Does the plan address the status of school staff as "disaster service workers" or “essential employees” and specify whether staff are to be assigned any other activities if their school is closed? 
• Does the plan establish a communication system with employees to inform them of the status of the situation?
• Has the district made sure that all staff are aware of the plan and understand how it is to be implemented?