Power Solutions International (the “Company”) has implemented this Infectious Disease Response Policy (“Policy”), setting forth protocols and guidelines to inform the Company’s response to a pandemic or other infectious disease of significant public health concern. As of March 13, 2020, the Policy is in force in response to the virus SARS-COV-2 which causes the illness called COVID-19.
The Company is committed to providing a healthy and safe environment for our employees. The Company strives, in cooperation with advice and guidance from the Centers for Disease Control and Prevention (“CDC”) and other applicable public health authorities, to take all appropriate measures to safeguard employees and visitors from the risks and transmission of COVID-19, while also maintaining appropriate business continuity.
Through this Policy and other means, the Company seeks to make employees aware of resources and preventative measures to be implemented in the event of a pandemic or other infectious disease of significant public health concern (including COVID-19).
For context, the World Health Organization defines “pandemic” as the worldwide spread of a new disease. Whether or not declared a “pandemic” by an official body, infectious diseases can spread easily from person to person. For ease of reference, we use the term “pandemic” in this policy to refer to any infectious disease that the Pandemic Response Team determines warrants implementation of this Policy based on information and guidance from applicable public health authorities.
This policy applies to all Company personnel in the United States.
Roles and Responsibilities
The following roles and responsibilities apply:
Pandemic Response Team
The Pandemic response and efforts will be led and supported by the Pandemic Response Team (“PRT”), consisting of the following positions
John Miller, CEO
Chip Avery, CFO
Ken Winemaster, EVP
William Buzogany, Esquire
Patrick Capuson, VP Operations
Brian Grant, VP Purchasing
When an infectious disease outbreak begins affecting employees or operations, the PRT should be activated. The team will:
- Assess the extent of the pandemic and its potential impact on business operations;
- Activate relevant portions of the Policy accordingly, as adjusted based on applicable public health authority guidance for the contagion(s) in question.
- Assemble and manage a Pandemic Support Team in applicable locations to protect critical business operations and facilitate the return to normal operations once the pandemic has passed.
- Identify other individuals or teams to develop communications, implement policies, or perform tasks and help assemble information for medical, infectious disease, insurance, government, or legal inquiries.
- Assist with notifying/contacting appropriate medical, emergency services, and health departments;
- Ensure timely and accurate communication to Company personnel, customers, and business contacts, mindful of privacy and other individual rights and protections.
- Respond promptly to questions and concerns;
- Other response functions.
Pandemic Support Team
The Pandemic Support Team (“PST”) will be assembled by the PRT and will work closely with the PRT and the HR Department. Members will vary depending upon which personnel/locations have been impacted by the pandemic. The team will:
- Assess the situation and monitor the potential business impact.
- Track the status of personnel calling in sick.
- Determine backup personnel needed.
- Regularly brief PRT and key senior management on pandemic status.
- Contact/notify appropriate emergency organizations (e.g., hospitals, clinics).
- Coordinate activities with others (first responders, etc.).
- Communicate with key clients and business contacts as appropriate.
- Maintain regular contact with affected personnel to assess their condition and availability for work.
- Estimate the continued duration of the Pandemic Response Plan based on the expected return to work.
Crisis Communications Team (Jeremy Lessaris, VP Marketing, Dan Dun Director, Marketing, Pam Fisher, Director, HR)
The Crisis Communications Team is responsible for developing internal and external messages and distributing general audience external communications upon PRT approval.
Once the PRT has activated the Plan, employees should:
- Become familiar with and acknowledge the Plan.
- Abide by any temporary policies or measures the PRT implements in connection with the Plan.
- Immediately report any concerns with pandemic symptoms they may be personally experiencing, or they observe in others.
- When an outbreak begins or a potential pandemic is identified, activate the PRT.
- Conduct an initial risk assessment regarding all Company locations and operations. The risk assessment should, among other things, identify workers who may have exposure risk and identify potential sources of exposure at each worksite. The PRT and management should consult available guidance from applicable public health authorities and regulatory agencies, including for example:
- OSHA’s COVID-19 Guidance: https://www.osha.gov/SLTC/covid-19/index.html
- CDC’s Guidance for Workplaces: https://www.cdc.gov/coronavirus/2019-ncov/community/guidance-business-response.html
- Prepare a Pandemic Impact Assessment Form (Appendix A) to help guide the next planning steps.
Crisis Response Planning And Implementation
Once a pandemic or related emergency has been identified and the Plan is activated, the PRT and management should determine the impact on business operations and sites. The PRT and management should work together closely to develop and implement an initial crisis response plan and pandemic recovery procedures, and employees should be made aware of potential measures that may be implemented. Crisis Response will usually involve the following components:
A. Temporary policies
Prevention of disease transmission is a key element associated with managing the threat of pandemic situations. When this Plan is activated, the PRT should work with Company leadership to identify and implement any appropriate temporary workplace rules, interim policies, or other guidance to ensure workplace safety and promote continuity of business operations. Depending on the circumstances, this may include interim measures to identify and address employee illnesses, restrict travel to areas of transmission risk, provide remote working arrangements, address temporary worksite closures, implement public health authority recommendations or directives, and other related matters:
- Guided by and consistent with applicable public health authority guidance, management should encourage and/or require employees with illness symptoms to stay home while sick and seek any appropriate medical care. Management should allow employees to return to work based on applicable guidance from public health authorities (including as employees are appropriately cleared to return to work by healthcare providers).
- Consider options such as remote working, holding “virtual” meetings, and avoiding conducting business in congregate settings.
- Evaluate the need to postpone or cancel meetings and events that involve crowds or travel, consistent with public health authority guidance and sound business judgment.
- Determine any necessary or prudent travel restrictions and/or disclosure requirements in line with public health authority guidance.
- Ensure that policies incentivize employee cooperation, facilitate trust in the Company, and avoid stigma or panic among employees.
- Follow public health authority guidance in isolating and/or excluding employees from the workplace, and determine the extent to which such circumstances will be addressed through remote working arrangements, paid benefits (such as sick leave, STD, etc.), or unpaid leave, ensuring compliance with applicable federal, state, and local laws.
- Track attendance / update reporting procedures. The goal of the Company is to implement flexibility in its attendance and leave policies to address the pandemic, while at the same time providing for continued business operations where appropriate and safeguarding against fraud and abuse.
- Determine appropriate return-to-work protocols. Consideration should be given to public health authority advice on suspending requirements for routine doctor’s notes to return to work, while also determining situations where medical clearance may be necessary to ensure employee and worksite safety.
- Determine appropriate requirements and procedures for employees to disclose known exposure risks or illness.
- Determine appropriate measures to screen visitors and vendors in accordance with applicable legal protections.
B. Promoting Awareness
When this Policy is activated, the PRT should engage in appropriate actions to promote awareness of the contagion and preventative measures through reliable medical information, such as applicable factsheets or guidance from the CDC, WHO, or other public health authorities.
- Educate employees on good hygiene practices, including handwashing and proper etiquette for coughing and sneezing.
- Routinely clean shared office equipment.
- Ensure a sufficient stock of supplies to enhance hygiene practices (e.g. alcohol wipes, disinfectant, alcohol-based hand sanitizer, soap for all sinks, paper towels).
- Determine any necessary Personal Protective Equipment (“PPE”), including masks, gloves, respirators, etc., based on job classifications and exposure risks, and provide all necessary training in accordance with applicable OSHA standards.
- Provide additional training / instruction / support to those managing office administrative functions.
- Identify and consult outside experts where applicable (local authorities, medical consultants, etc.)
C. Operational stability
Pandemic situations and other public health emergencies may disrupt operations, forcing closures and/or sustained employee absences. The PRT should prepare for operational disruption by planning and preparing for the following possible scenarios:
- Facility closures
- Stand down of nonessential functions in a facility
- Restricting nonessential business travel (based on applicable public health authority recommendations and/or business needs)
- Temporary layoffs or furloughs
- Requiring employees to use vacation time / other leave time
- Hours / pay reduction
- Adjusted commute times
- Remote work
- Position eliminations and severance packages (mindful of applicable laws and employee consultation requirements)
- Reducing other expenses
The Company’s operational response must be tailored to the context and circumstances in light of applicable public health authority guidance.
When this Policy is activated, the PRT should engage in appropriate communication measures informed by the following guidance:
- Communicate with employees on a regular basis to assure them that the Company is monitoring the situation and taking appropriate precautions.
- Ensure that communications acknowledge the evolving nature of the situation—while all-employee communications need not be too frequent, employees should be advised of developments and risks in a timely manner.
- In each communication, consider the following while adhering to applicable public health authority guidance
- Workplace safety
- Employee confidentiality and privacy
- Acknowledge employees’ concerns while avoiding contributing to unnecessary fear or panic.
- Do not give medical advice to employees—when asked, refer them to a medical doctor or public health authority materials.
- Identify local and centralized points of contact, including a “pandemic response team” email address if appropriate.
- The PRT and PST should determine critical and/or time-sensitive assignments and business functions.
- Evaluate available staffing and determine the ability to handle the above-mentioned assignments and anticipated workloads.
- Depending upon the degree of absenteeism and its anticipated spread, arrange for additional back-up personnel using the following Back-up Personnel Strategy
- Develop a process to allocate and assign work according to priorities, available personnel, and available resources.
- Determine resources needed (people, supplies, vendors/service providers, equipment/technology, and contact information). Use back-up personnel strategy above, as needed.
- Determine meetings or other commitments for affected personnel that need to be changed or moved immediately. Notify respective parties and plan accordingly.
- Communicate recovery strategies to office and firm personnel and appropriate.
- Once the situation has stabilized, PRT and PST teams should meet regularly until the crisis is resolved and business operations have returned to normal.
- Assign someone to document the recovery status and take meeting notes. (Appendix B: Status Reporting Form) and (Appendix C: Pandemic Event Recovery Reporting Form)
- Update Executive Management daily or as needed. Update all personnel regarding the status of the recovery process regularly.
Related Policy, Procedure and Additional Documents
- CDC Guidance for Businesses on COVID-19 https://www.cdc.gov/coronavirus/2019-ncov/specific-groups/guidance-business-response.html
- CDC Risk Assessment, including employee quarantine information – https://www.cdc.gov/coronavirus/2019-ncov/php/risk-assessment.html
- CDC Coronavirus FAQ – https://www.cdc.gov/coronavirus/2019-ncov/faq.html
- DOL guidance on COVID-19 https://www.dol.gov/agencies/whd/flsa/pandemic
- OSHA guidance on COVID-19 https://www.osha.gov/SLTC/covid-19/
- WHO “Getting your workplace ready for COVID-19” (March 2, 2020) https://www.who.int/docs/default-source/coronaviruse/getting-workplace-ready-for-covid-19.pdf?sfvrsn=359a81e7_6
Download the PDF Pandemic Response Plan