Page 499 - Safety Memo

Safety Memo #26 (R) Mask Requirement for Jobsites, Wash/Sanitizing Stations, and Regular
Disinfecting

Date: June 5, 2020

To: ACI ALL
[MANDATORY: Mask Requirement for Jobsites, Wash/Sanitizing Stations, and Regular Disinfecting]

In recent days, there have been questions and a lack of clear direction from governing bodies whether or not
masks and other disease preventative measures are required on the jobsite for COVID-19 compliance.
OSHA, CDC, and state and local agencies like to use ambiguous phrasing such as: “strongly recommends,”
“highly encouraged,” etc.; but, do not explicitly say that they are required. Regardless, ACI has been following
their recommendations and is issuing masks to employees, posting relevant signage, designating sanitizing
stations, and implementing other measures to combat the spread of COVID-19.

Please read the following for specific instructions on COVID-19 prevention on our jobsites:

1. It is now mandatory for all personnel on an ACI jobsite to be equipped with a mask or face
covering. All project teams should inform subcontractors of this official mandate and remind them
that they are contractually responsible to follow our safety rules per “SECTION 20. HEALTHY AND
SAFETY” in the ACI Subcontract Agreement. Any disciplinary actions for violations of this mandate will
be left to the project team’s discretion.

2. All jobsites are to provide wash stations with soap and/or hand sanitizing stations.
Provide employees with access to soap, clean running water, and materials for drying their hands, or if
soap and water are not readily available, provide alcohol-based hand sanitizers containing at least 60%
alcohol at stations around the establishment for use by both workers and customers.
• Place handwashing stations and/or hand sanitizers in multiple locations (including in or adjacent to
portable restrooms) to encourage hand hygiene.

3. Regular disinfecting is recommended for frequently touched surfaces along with regular
cleaning. If you do start disinfecting regularly, you should record every disinfecting activity in a
log.
Clean and disinfect frequently touched surfaces. If the surfaces are visibly dirty, clean them prior to
disinfecting. To disinfect, use products that meet EPA’s criteria for use against SARS-CoV-2external
icon, diluted household bleach solutions that are prepared according to the manufacturer’s label for
disinfection, or alcohol solutions with at least 70% alcohol, and that are appropriate for the surface.
Follow manufacturer’s directions for use.
• Clean workspaces and breakrooms at least once per shift or as often as workers change
workstations.
• Provide worker training on manufacturer’s directions for disinfectant use and provide workers with
any additional PPE required for disinfection.

OSHA has been observed to be citing companies that are not following the CDC’s COVID-19 guidelines stating
that those companies are in violation of Title 8 CCR 3203(a)(4) which has to do with enforcing corrections for
any potential hazard. We are also bound to the General Duty Clause to maintain a safe work environment for
our employees and our subcontractors.

We as a company can only do our best to keep ourselves and everyone under us safe during this pandemic.

Stay safe and stay healthy!