COVID-19 Response and Reintegration Plan - March 2021 - Charter Steel

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COVID-19 Response and Reintegration Plan - March 2021 - Charter Steel
COVID-19 Response
        and
 Reintegration Plan
     March 2021
COVID-19 Response and Reintegration Plan - March 2021 - Charter Steel
Contents

OVERVIEW: Return to the Workplace .................................................................................................. 6
Guiding Principles ................................................................................................................................. 7
Employee Phased Return ...................................................................................................................... 8
  Criteria for Return to the Workplace .......................................................................................................................................................................9
  Government Guidance/Orders ..............................................................................................................................................................................10
  Phased Return........................................................................................................................................................................................................11
  Criteria for Phase 2 and 3.......................................................................................................................................................................................12
  Additional Considerations ......................................................................................................................................................................................14
  Business Expense Policy Communication...............................................................................................................................................................15
  Employee Travel ....................................................................................................................................................................................................16
  Travel Guidelines for Current Travel Phase (Phase 2) ............................................................................................................................................17
  Company Plane Use ...............................................................................................................................................................................................20

Health and Safety Protocols................................................................................................................ 21
  Social Distancing Protocols ....................................................................................................................................................................................22
  Mail and package delivery process ........................................................................................................................................................................23
  Shipping & Receiving Driver Interaction ................................................................................................................................................................24
  Staggered work times/entrances ...........................................................................................................................................................................25
  Staggered breaks ...................................................................................................................................................................................................27
  Prescreening Protocols ..........................................................................................................................................................................................29

        Rev. 4 – March 2021                                                                                                                                                                                            2
COVID-19 Response and Reintegration Plan - March 2021 - Charter Steel
Employee Self-Assessment Process .......................................................................................................................................................................29
  Visitor Self-Assessment Process .............................................................................................................................................................................30
     Protocol Elements .............................................................................................................................................................................................30
     Once onsite:.......................................................................................................................................................................................................31
     Visitors:..............................................................................................................................................................................................................31
  On-Site Supplier Needs Assessment Process .........................................................................................................................................................32
  Re-integration for Visitors and On-Site Suppliers ..................................................................................................................................................33
     APPROVED CLEANING SUPPLIES .....................................................................................................................................................................35
     APPROPRIATE USE OF CLEANING SUPPLIES ......................................................................................................................................................36
     MANAGING CLEANING SUPPLIES ...................................................................................................................................................................36
  Cleaning Requirements, Area Process Guide and Logs ...........................................................................................................................................37
  Janitorial Service Management ..............................................................................................................................................................................43
  Contractor Disinfecting Services ............................................................................................................................................................................45
  Confirmed Case Response Procedure ....................................................................................................................................................................46
  Positive COVID-19 Response Training ....................................................................................................................................................................47
  Department of Health Relationship .......................................................................................................................................................................48
  Personal Protective Equipment Protocol ...............................................................................................................................................................50
  Temporary Operating Procedure for Mask at WI Sites ..........................................................................................................................................53

Workplace Preparedness .................................................................................................................... 55
  Areas of Focus ........................................................................................................................................................................................................56
  Office Preparedness ...............................................................................................................................................................................................57
  Workstation/Cube Design ......................................................................................................................................................................................58
  Employee/function separation ..............................................................................................................................................................................59

        Rev. 4 – March 2021                                                                                                                                                                                                 3
COVID-19 Response and Reintegration Plan - March 2021 - Charter Steel
Meeting/Event Occupant Limits ............................................................................................................................................................................60
  Conference Room Use Protocols ...........................................................................................................................................................................61
  Common Area/Breakrooms/Employee Kiosks Use ................................................................................................................................................62
  Lunchroom/Kitchenette Setup and Use .................................................................................................................................................................63
  Off-site Food Ordering and Workplace Provided Meals Protocol ..........................................................................................................................64
  Pulpits/Shared Offices ...........................................................................................................................................................................................65
  HVAC and Air Handling ..........................................................................................................................................................................................66
  High Touch Items Elimination ................................................................................................................................................................................67

Supply Chain/Procurement ................................................................................................................. 68
  Critical Supply Management ..................................................................................................................................................................................69
  Central Store Management Process.......................................................................................................................................................................70
  Functional Collaboration ........................................................................................................................................................................................71

Communication & Awareness ............................................................................................................ 73
  Communication & Awareness ................................................................................................................................................................................74
  Re-Entry Training ...................................................................................................................................................................................................76
  Positive Response – Plant Communication Guidelines ..........................................................................................................................................77
  Leader Protocol – III Employee Response ..............................................................................................................................................................78
  Work Schedule Changes ........................................................................................................................................................................................79
  Pulse Survey Process Management .......................................................................................................................................................................80

Internal Controls ................................................................................................................................. 81
  Instructions for Safety Contacts .............................................................................................................................................................................82
  Auditing of Process/Compliance ............................................................................................................................................................................83

        Rev. 4 – March 2021                                                                                                                                                                                            4
COVID-19 Response and Reintegration Plan - March 2021 - Charter Steel
Demonstrating/Documenting Legal Compliance ...................................................................................................................................................84
Summary of Changes – Version 4 ..........................................................................................................................................................................85

      Rev. 4 – March 2021                                                                                                                                                                                5
OVERVIEW: Return to the Workplace
    • The following framework is to be used by Charter
      Manufacturing businesses to facilitate the return to the
      workplace in a way that demonstrates our values and the
      behaviors necessary to protect you and our company.
    • Aspects of the framework may evolve as the environment
      around us changes and as we learn more.
    • Actions will be informed by direction from city, state and
      national government and agencies. Operating in multiple
      states could drive differing requirements.
    • Government guidelines are a key input, but Charter
      requirements may be adjusted based on best judgement and
      consistency with Charter culture.

     Rev. 4 – March 2021                                           6
Guiding Principles
    • We will provide a consistent employee experience across our
      businesses that supports and promotes our Charter culture.
    • We will uphold our values: Safety, Trust, Teamwork, CI
    • We will safely perform critical work to keep Charter financially
      strong.

     Rev. 4 – March 2021                                                 7
Employee Phased Return

Rev. 4 – March 2021      8
Criteria for Return to the Workplace

  Rev. 4 – March 2021                  9
Government Guidance/Orders
Guidance and orders issued by federal, state, and local government and health
agencies need to be monitored to ensure compliance and to effectively manage
operations.

Changes may be related to items such as employment law, workplace health
requirements, stay-at-home orders, essential business definitions and reporting
obligations.

The COVID-19 response team leader is responsible for ensuring an effective
monitoring process is in place and changes are incorporated into appropriate
protocols. Regular monitoring and interaction with local health departments is
critical in assessing business continuity risk. More information can be found in
“Department of Health Relationship”.

Legal advice will be obtained as needed to ensure compliance risks are properly
managed.
   Rev. 4 – March 2021                                                         10
Phased Return
Employees return to workplace will be phased based on criticality to our
operations, increased productivity, and associated risk.

Notes:
  • The phase determination was made at the individual level based on role requirements
  • Entire functional areas may not return within the same phase
  • Adjustments to lists will be made through functional leads as needed
   Rev. 4 – March 2021                                                             11
Criteria for Phase 2 and 3
To prevent the transmission of the virus, Charter will consider the below criteria
before advancing to additional employees working onsite. The currently
defined Phases 2 will not be rolled out as a group but will be implemented as
the business need indicates onsite presence of individuals will increase their
effectiveness as the pandemic risk diminishes. Employees will be part of an
interactive process with their manager to determine return timing and discuss
individual needs. We will continue to refine based on new information:
         •   State government phasing guidance
         •   Work area adjusted for social distancing and HVAC improvements
         •   Cleaning protocols are successfully in action & supplies available
         •   The trend of cases, vaccine, and immunity status in our communities
         •   Employee concerns

   Rev. 4 – March 2021                                                             12
In the days, weeks, and months ahead, we will continue to monitor progress
case rates and vaccine adoption, keeping you informed of any changes. Know
that the health and safety of the entire Charter family is our number one
priority. Continue to self-monitor your health, practice good hygiene and
follow safety protocols, both inside and outside of work, to remain healthy
and well, and do not come to work if you are feeling ill.
We will provide 30-days’ notice to employees of any required return to work
date, allowing sufficient return to work planning and preparations, including
childcare preparations, re-entry training for managers, protocol training for
employees and other preparations in the workplace.

Rev. 4 – March 2021                                                         13
Additional Considerations
The pandemic has impacted our team members differently – including, but not
limited to, child and elder care challenges (due to school and daycare closures)
and personal or family member high risk health situations.

Charter Manufacturing will continually evaluate policies and procedures that
effectively balance individual considerations with business requirements.

Employees with concerns should contact their HR Partner or the HR Service
Center to understand available options based on individual circumstances.

   Rev. 4 – March 2021                                                         14
Business Expense Policy Communication
Charter does not pay for home office equipment, supplies or internet.
IT Equipment for Home Use
As you come back into the office, it may not be full time. If you would like equipment at home so you don’t have
to bring it back and forth you can purchase it yourself. Website from CDW provides standard Charter models.
Just go to https://www.cdw.com/accountcenter/LogOn and use your chartersteel.com email
(XXX@chartersteel.com) as your username. If you don’t have an account click forgot password and link will be
sent to your chartermfg.com email
You will find examples of Charter models you can order under Bundle Favorites – Company Favorites:
•     Monitors
•     Keyboards
•     Mouse
•     Docking Station
•     Web Camera
•     Speaker Phone
•     Headsets

    Rev. 4 – March 2021                                                                                        15
Employee Travel

  Rev. 4 – March 2021   16
Travel Guidelines for Current Travel Phase (Phase 2)
General Guidance
  •   No international travel is allowed.
  •   Charter’s Business Travel & Expense Policy is always to be followed.
  •   Don’t travel if you are sick or if you have been around someone with COVID-19 in the past 14
      days. Don’t travel with someone who is sick.
  •   Some state or local governments have requirements, such as requiring people to wear masks
      and requiring those who recently traveled to stay home for up to 14 days. Check state and local
      public health websites for information before you travel.
  •   During your trip, take steps to protect yourself and others from COVID-19:
         o Wear a mask to keep your nose and mouth covered when in public settings.
         o Avoid close contact by staying at least 6 feet apart (about 2 arms’ length) from anyone
            who is not from your household.
         o Wash your hands often or use hand sanitizer (with at least 60% alcohol).
         o Avoid contact with anyone who is sick.
         o Avoid touching your eyes, nose, and mouth
  •   After you travel, monitor your health and look for symptoms of COVID-19

  Rev. 4 – March 2021                                                                                   17
Business Essential Domestic Travel
  • If you intend to travel, please direct your travel request to your manager, who will route for any additional
    approval needed by business leadership.
        o Travel by car must be approved by manager.
        o Travel by commercial air or company airplane must be approved by Business President or Executive.
            Charter approved face covering/mask must be worn at all times when traveling via commercial air
            and/or company airplane.
        o After obtaining the necessary approval, send travel plans to your travel coordinator to be booked,
            Self-booking travel is not allowed at this time.
        o Travel Coordinators:
            • Saukville – Tammy Schoenfeld (Ops) & Karen Early (Admin)
            • Cleveland & Fostoria – Maureen Hejduk
  • Rental vehicles, company vehicles or personal vehicles are permitted for travel. One traveler in the vehicle is
    recommended but not more than two travelers are permitted. When two travelers are in a vehicle, Charter
    approved face coverings are required.
        o Car rentals must be through Enterprise/National per Travel Policy.
        o EzPass, IPass or other automated toll payment system should be utilized verses paying tolls by toll booth
            exchange.
        o Masks and Hand Sanitizer will be part of the travel protocols (when stopping for gas / bio breaks)
  • Only company approved hotels are allowed for overnight stays which includes all hotels on our preferred hotel list
    that have hotel rate agreements.
        o Use of workout areas is allowed as long as the space is unoccupied by others
  • Travel meals are limited to room service, take out, drive through or curbside food only – no sit-down meals or
    drinks in restaurants or bars. Meetings in hotel conference areas are allowed following similar practices to on-site
    meetings.
  • Dining onsite must be limited to10 or fewer persons or the stated occupancy limit of the conference room
    maintaining six-feet social distancing or wearing face coverings when such distance cannot be maintained.

   Rev. 4 – March 2021                                                                                                 18
Commercial/Sales Travel
   •   For commercial sales employees, confirmation with manager is required that Charter and
       Customer pandemic protocols have been reviewed, understood, and will be adhered to.
   •   Dining with customers offsite should be limited to gatherings of 10 or fewer persons and social
       distancing of six feet must be maintained.
   •   Follow local ordinances for face covering/mask use.

Supplier Visits
   •   All Charter team members attending are required to follow all applicable travel requirements laid
       out in this policy.
   •   Prior to the visit guests must review, understand, and adhere to the site pandemic protocols.
       Host must approve the visit and share the attendee list.
   •   Dining with suppliers offsite should be limited to gatherings of 10 or fewer persons and social
       distancing of six feet must be maintained. Indoor dining should be avoided when possible.
   •   Follow local ordinances for face covering/mask use.
   •   Vendor visits must be approved by the functional area manager or the procurement leadership
       team.

   Rev. 4 – March 2021                                                                                     19
Company Plane Use
Use of the plane has been approved for flying to/from Cleveland to facilitate
travel to support essential business activities and priority projects. There is a
small list of approved travelers who regularly support essential business
activities, all others would need approval by functional VP.
The following protocols will be followed:
  • Limit is five passengers
  • Masks at all times
  • No food or beverage service
Documents:
  • NJM – What to expect
  • NJM – Aircraft Cleaning Procedures
  • EHI Duty of Care
  • Aircraft Request Form 09092020 COVID

   Rev. 4 – March 2021                                                              20
Health and Safety Protocols

Rev. 4 – March 2021           21
Social Distancing Protocols
The purpose of this protocol is to establish and prescribe social norms for workplace social distancing to deter
spread of disease, (COVID-19). This document is prepared referencing resources from the Centers for Disease
Control and Prevention, (CDC). The scope includes the physical spacing of personnel, abiding by a physical or
“social distance,” practice, and situational awareness and observation of activity, conditions, and visual markers.
A more detailed description of office setting social distancing is covered later in this document.
 Occupancy limitations defined/posted
All group office areas, pulpits and conference rooms should have defined occupancy limits. Consider ability to
social distance and a percentage of original designed occupancy to set limits. Communicate all occupancy limits
with signage, periodic reinforcement, and reduced seating availability.
Physical Barrier Installation
Placement of physical barriers is needed for workstations that do not allow for social distancing. Typical barriers
include:
   • Cubical Walls
   • Barrier posts and belts to separate or direct flow for workers, visitors, drivers, etc.
   • Plexiglass shielding

Work areas that do not allow for physical barriers would necessitate the need for PPE while social distancing
requirements are in effect. See PPE protocol.

    Rev. 4 – March 2021                                                                                           22
Mail and package delivery process

• All deliveries should be contactless when possible.

• Social distance guidelines should be adhered to when retrieving mail.
• Individual employees should retrieve their own mail from their own
  mailboxes versus having someone distribute to everyone’s desk.
• Employees without a mailbox will continue to receive mail from supervisors.

   Rev. 4 – March 2021                                                          23
Shipping & Receiving Driver Interaction
Charter Steel Protocol for Truck Drivers during Pandemic Conditions:
   1) Signage needs to be posted at sign-in kiosks with screening questions.
   2) Efforts should be made to segregate drivers from Charter Employees.
         a. Separate bathrooms – use portable toilets if necessary
         b. Separate vending machines
         c. Restrict access / confine drivers to a designated area
         d. Have drivers wait in their trucks and only come to the dock when their load is ready
   3) Eliminate / Reduce paperwork exchange with drivers
         a. Eliminate all unnecessary paperwork
                i. Consider getting load number and cell phone verbally (at a safe distance)
         b. Wear gloves when handling essential paperwork
         c. Use a drop box to exchange essential paperwork
         d. Use a mask if close prolonged interaction with drivers is required
         e. Leverage cell phone/ CB communication vs. pagers
         f. Provide inbound deliveries with a paper form letter acknowledging receipt vs. signing their BOL
   4) Increase sanitization of common surfaces
         a. Dock Locks
         b. TADs kiosk
         c. Wheel Chocks
         d. Handrails
   5) Truck drivers should be adhering to the CDC guidelines for drivers:
      As a long-haul truck driver, how can I protect myself and slow the spread?

    Rev. 4 – March 2021                                                                                       24
Staggered work times/entrances
Shift Change Protocol – Social Distancing Priority

To reduce locker room interaction and promote social distancing:

Beginning of Shift
    • All employees must bring their clean work uniforms home and come to work
      dressed in uniform to eliminate/reduce time in the locker room.
    • Safety gear such as boots and PPE can also be taken home or stored in other
      locations to eliminate/reduce time in the locker room

End of Shift
    • To change out of soiled uniforms, stagger the use of locker rooms by use of a
       scheduling system. Each Plant will define, examples below:
          o Staggering use by department.
          o Where reasonable, shutting down operations, allowing one shift to leave,
             creating a gap, and then another shift start back up.
          o A combination of both.

   Rev. 4 – March 2021                                                                 25
(High Level) Plant examples of shift change locker   room use reductions:

Saukville Melt will stagger shift relief at different times, beginning roughly within 40-
minutes of 5am/pm shift change.

Saukville Roll will stagger shifts by having Skilled trades/Roll shop switch at 5:30am/pm,
and then Production/QC at 6am/pm.

Saukville Processing will stagger shift relief at different times beginning roughly within
40-minutes of 5am/pm shift change.

Cleveland Roll will stagger shifts by having Skilled trades switch at 5:00am/pm, and then
Production/Roll Shop/Lab at 6am/pm.

Cleveland Melt will utilize separate locker rooms for Maintenance and
Production employees.

Fostoria will have Shipping and Maintenance employees no longer use the main
processing locker room at the start and end of shifts to reduce interaction. These areas
will utilize lockers and unused offices in their areas as needed.

   Rev. 4 – March 2021                                                                       26
Staggered breaks
To reduce employee interaction and promote social distancing:

 During Shifts Lunch and Breaks

    • Where reasonable, establish a set rotation of employees for lunch/breaks to
      limit the potential number of employees to a small fixed amount, bay area, or
      department. Where not practical based upon manufacturing requirements,
      plants will establish guidelines to support the protocol intent. High level
      examples are noted below.
    • Ensure all pulpits and breakrooms have implemented social distancing protocols
      to restrict the amount of people at one time and ensure ample distancing exists.
    • Plastic utensils provided by Charter need to be individually wrapped.

  Rev. 4 – March 2021                                                                 27
(High Level) Plant examples of Break Staggering:

Saukville Melt does not have set break times, but most are taken in the operator pulpits where max number of employees/chairs is
specified. If the breakroom is full (restricted chairs/tables) the employees will take their break elsewhere.

Saukville Roll pulpit operators will take their breaks in the pulpits where the max number of people is specified. Stelmor operators
are on a staggered rotation due to tasks. Lunches are taken when possible, but the lunchroom does have social distancing seating
implemented.

Saukville Processing will stagger shift relief at different times beginning roughly within 40 minutes of 5am/pm shift change.

Saukville Shipping has 30-minute offset break times for the shifts. No more than 6 people at a time. That is also reinforced by
having the lunchroom having social distancing seating implemented.

Cleveland Roll take breaks in the operator pulpits where the max number of employees/chairs is specified. The maintenance
breakroom is utilized only by maintenance and has an established limit of people that can be present.

Cleveland Melt take breaks in the operator pulpits where the max number of employees/chairs is specified. The maintenance
breakroom is utilized only by maintenance and has an established limit of people that can be present.

Fostoria Shipping is not using the main lunchroom for breaks, but asking employees to leverage the shipping office, outside picnic
table or their vehicle. If more than (2) employees are taking a break at the same time, they are asked to offset breaks or take them
in separate areas.

Fostoria Processing rotate the breaks through departments and limit the max occupancy to (6) in the breakroom. Employees utilize
the breakroom, outside picnic tables and their vehicles for further distancing.

     Rev. 4 – March 2021                                                                                                           28
Prescreening Protocols
A key protective measure in the effort to reduce transmission of the COVID19 virus is to keep infected individuals from
entering our sites. Our Pre-screening protocols allow us to identify and restrict those showing symptoms of the virus from
entering the sites.

Employee Self-Assessment Process
Charter Steel utilizes employee self-assessment to insure ill employees do not enter the workplace. It is essential that all
employees complete the pre-screening process daily, including taking their temperature, before coming to work. This process
is in place to protect individual wellbeing, coworkers, and families.
Self-Assessment Process:
         Prior to coming to work:
             • Take your temperature. Is your temperature 100.4 degrees Fahrenheit or greater?
             • Have you experienced during the last 3 days symptoms such as?:
                    o Fever or chills                                                  o Nausea or vomiting
                    o Shortness of breath or difficulty                                o Diarrhea
                        breathing                                                      o New loss of taste or smell
                    o Fatigue                                                          o Sore throat
                    o Muscle or body                                                   o *Headache
                        aches                                                          o *Congestion or runny nose
                                                                                       o *Cough
                 *Note: Do not count symptoms that are compatible with your usual symptoms and timing of allergies.

             •   Have you been in contact with anyone who has been diagnosed with a critical contagious illness, such as
                 COVID19 within the past 14-days?
             •   Do you have a housemate that is experiencing symptoms or awaiting COVID19 results?

If you answered “yes” to any of these questions, notify your supervisor and the HR Service Center and stay home.
Rev. 4 – March 2021                                                                                                          29
Visitor Self-Assessment Process
This protocol applies to all visitors coming onsite. “Workplace visitors” may refer to employees’ friends and family (referred to as
personal visitors), customers and suppliers.
We ask that visitors are only on-site if the work is business critical. Those visits include things like inventory replenishment and
contractor services that keep our production running. During this time, frequent visits should be reduced wherever possible.
This protocol does not refer to remote employees from other Charter locations.

Protocol Elements
Prior to coming on-site, it is required for visitors to self-assess the following areas:
   •     Use a thermometer to take your temperature. Is your fever 100.4 degrees Fahrenheit or greater?
   •     Have you experienced during the last 3 days symptoms such as?
            o Fever or chills
            o Shortness of breath or difficulty breathing
            o Fatigue
            o Muscle or body aches
            o Nausea or vomiting
            o Diarrhea
            o New loss of taste or smell
            o Sore throat
            o *Headache
            o *Congestion or runny nose
            o *Cough
             Note: Do not count symptoms that are compatible with your usual symptoms and timing of allergies.

   •     Have you been in contact with anyone who has been diagnosed with a critical contagious illness within the past 14-days?
If the visitor answers “yes” to any of the above questions, he/she will not be permitted onsite.

       Rev. 4 – March 2021                                                                                                             30
Once onsite:
  • Visitors should register at the gate with the security guard/ reception and or front office.
        o Name of visitor and date/time of visit will be documented.
  • Verify the visitor has been asked self-assessment questions
  • If the visitor says “yes” to any of the questions, then they are not permitted onsite.
  • The security guard and/or administrative assistant will confirm that the visitor has the required PPE.
  • If the visitor does not have a mask or a facial covering, one will be provided.
  • Visitors are required to adhere to social distancing guidelines when on Charter Steel property.
  • Visitor is required to only visit designated location where work will be performed and or delivery will be
     complete.
  • Visitors will sign out at the gate with the security guard/ reception, front office or with host (after hours)
     once visit is over.

Visitors:
    • Truck drivers -who pick up loads at any of our facilities are required to wear face coverings while on site(s).
    • Suppliers - that gain access to any of our facilities are required to wear face coverings while on site(s).
    • Charter Steel may occasionally accept the following types of visitors:
          o Students
          o Job Candidates
          o External vendors
          o Auditors
          o Customers
      The above self- assessment protocol and face covering guidelines apply to them as well.

    Rev. 4 – March 2021                                                                                              31
On-Site Supplier Needs Assessment Process
To control the exposure, spread of a virus:
Assess Suppliers On-site: A current state assessment must be done to identify which vendors are coming on-site, and how
frequently. This will include raw and indirect material providers, contractors, service providers and all sales professionals.
Only Business Critical Visits: Communicate to all suppliers that there are no on-site visits unless the visits are deemed business
critical by Charter Steel. All contractors must self-assess before coming on-site

   •     Non-essential visits include sales calls, tours or meetings that can be done virtually.
   •     See visitor policy. Include any changes to the visitor policy in this communication, found in the visitor self-assessment
         protocol. Changes include the check-in log, self-assessment and mask requirements if working within 6 feet (unless local
         mask requirements are more stringent).

Vendor (Supplier) Managed Inventory Programs: Procurement will determine criticality and review service levels for critical
suppliers.

   •     Visit Cadence: Review visit cadence with procurement and operational leads. Example: If a program is traditionally stocked
         three times/week, look to reduce the frequency to one time per week.
   •     Eliminate visits: If the supplier is not business critical or orders can be placed electronically, virtual meetings.

Contractors: Operations will identify critical contractors who must remain on-site. Those deemed to be not critical, will be notified
accordingly. Contractors will be brought back into the business as it is deemed safe to do so.

   •     Work should be done in house by Charter Steel employees where possible.
   •     Determine if work can be postponed.

All suppliers coming on site, must follow the same social distancing and mask policies being followed by Charter Steel employees.
This assessment has been completed for the COVID-19 pandemic.
       Rev. 4 – March 2021                                                                                                            32
Re-integration for Visitors and On-Site Suppliers
Contractors will be part of an interactive process with the purchasing team to
determine return timing and discuss business needs.
Bringing visitors back on-site must be done in a strategic and safe fashion. We will gradually allow
visitors on-site, visits that can be done virtually should be done so.

Communication to visitors coming back to site must include the following information:
  • Full review of the visitor’s self-assessment process
  • Personal Protective Equipment Protocol
  • Social distancing protocol
  • Any other applicable protocols; cleaning, lunchrooms, conference rooms, and food and drink
    policies.
  • Suppliers coming back on-site must sign off on the contractor protocols.

Procurement will provide a standard communication letter to be used for suppliers coming back
on-site. A version of these protocols for visitors and contractors is on Charter Steel’s website under
Contact Us --> Supplying to Charter.

   Rev. 4 – March 2021                                                                              33
Cleaning Protocols
PURPOSE
  Establish cleaning and disinfection procedures to control and prevent the spread of the coronavirus disease
  (COVID-19). Use protocols as a foundation to change habits, coach and develop new social norms.

SCOPE
  Routine cleaning and disinfection of workstations including office areas, pulpits, shared workstations, and
  other common surfaces.

DEFINITIONS
  Cleaning- wiping away dirt and impurities from surfaces. Cleaning does not necessarily kill bacteria
           and viruses but removes them to lower the risk of spreading infection.

   Sanitizing- process of reducing bacteria and viruses to a certain percentage on surfaces

   Disinfecting- process of killing all bacteria and viruses on surfaces. Surfaces should be cleaned or sanitized
   before they are disinfected.

   Sterilizing- the process of killing all microorganisms.

    Rev. 4 – March 2021                                                                                             34
APPROVED CLEANING SUPPLIES
     1. Regular soap and water for cleaning. It does not sanitize or disinfect.

      2. EPA Pesticide Registration, List N, are considered effective against SARS-CoV-2.
                  Common products include Clorox and Lysol disinfecting wipes and sprays, cleaners containing
                  bleach.

      3. CDC products for disinfection include:
              • Hydrogen peroxide solutions (typically 3%). Most effective on nonporous surfaces, sprayed or
                 wiped (letting it stand for at least one minute before wiping).
              • Isopropyl alcohol (rubbing alcohols) in concentrations of at least 70%. wiped or sprayed
                 (letting it stand for at least 30 seconds. Shelf life of one month after opening container; 3 years
                 if unopened)
              • Bleach sanitizing solution mixed in a ratio of 1-part bleach to 10 parts water (6-month shelf
                 life.)

      4. Charter Steel Approved Disinfecting Methods
               • UV-C light (see protocol below and SWP, Safe Work Practice K, and ensure proper training
                  before use)
               • Fogging or electrostatic spray by approved vendors.

    Rev. 4 – March 2021                                                                                           35
APPROPRIATE USE OF CLEANING SUPPLIES
     1. Where possible, use ready-to-use disinfectants. Any concentrated cleaners must be approved by the
           Safety Department.
       2. Read labels carefully to ensure safety and proper levels of cleaning. Disinfecting might require
           extended time.
       3. Spray bottles used as secondary containers for sanitizing solutions must be labeled with content.
       4. Cleaners should be appropriate for the surfaces.
       5. Cleaners must be used in accordance with the manufacturer’s recommendations. Spray cleaners are
           typically not suitable for electronics. As a result, electronics should be cleaned/disinfected using wipes
           or UV-C light.

MANAGING CLEANING SUPPLIES
  1. Immediately secure critical supplies on-site.
   2. Critical supplies are only to be accessed by Charter Steel approved personnel and managed through a
      central store.
   3. Approved personnel will distribute cleaning supplies to disinfection/sanitization stations according to area
      need.

    Rev. 4 – March 2021                                                                                            36
Cleaning Requirements, Area Process Guide and Logs
Cleaning of all common work areas will be completed before and after personnel changes (shift change, operator
change, etc.) and routinely throughout the day. Cleaning will be completed according to the Disinfection
Summary Chart and Area Process Guide. Cleaning logs will be completed and maintained for conference rooms
and other rooms with multiple occupants such as: locker rooms, lunchrooms, and pulpits with frequent changes
of occupants.
      Expectations:
             1. Use the Process Guide and Disinfection Summary Chart to define the areas/equipment needing to
                be cleaned and the appropriate frequency of each area.
             2. Conference rooms must be cleaned by the host or designee following each meeting
             3. Informal audits will be completed by the area owners as needed to ensure cleaning is effective.
      Cleaning Log Process:
             1. Locate logs in common, high traffic areas that are easily accessible.
             2. Record correctly and legibly each time cleaning or disinfecting is performed. (Time, am/pm,
                appropriate cleaning column checked, name, signature, and company)
             3. Area owners to ensure cleaning logs are available and information is retrievable if needed for
                tracing.
             4. Logs will be used as a basis for making informed decisions in case of a confirmed Covid-19 case.
             5. Entry for each shift that an area was used by a Charter Steel employee
             6. Entry for each day, area, and level of cleaning expected from outside cleaning service. (See
                cleaning contract or consult Plant Managers for details regarding outside cleaning services.)

    Rev. 4 – March 2021                                                                                            37
Sample Log:

Rev. 4 – March 2021   38
Sample Area Process Guide:

                             Click here for the log & Process Guide
   Rev. 4 – March 2021                                                39
DISINFECTION SUMMARY CHART   Click here for a printable copy of the chart

   Rev. 4 – March 2021                                                      40
UV-C Surface Sterilizer Protocol
**Warning: UV-C Light is harmful to your eyes and skin if not protected. Safety training is required before using***

To Safely Sterilize:
Ensure the user and any person in the vicinity of the user are wearing the manufacturer recommended PPE and in accordance with Safe Work
                                                                      Practice K.
2.      Plug unit into a standard 120VAC/60Hz grounded outlet. An extension cord can be used to extend the reach of the attached 6-foot
cord.
3.      Turn the unit on using the switch on the end of the unit. Be sure that the bulb side of the unit is down or facing away from any people.
4.      Holding the device by the handle, slowly run it over the surface to be disinfected.
        • Ideally the bottom of the device will be 1 to 2 inches off the surface
        • In order to ensure proper and complete sterilization the user should maintain the light on areas for 5 seconds if the unit is
             2 inches (or less) off the surface. This can be achieved by two relatively slow passes (back and forth) or one very slow pass. The time
             needed for disinfection is reduced if the < 2” inch distance is maintained, but more importantly, the time increases significantly as
             the unit it pulled farther away than the 2 inches.
        • It is important to know that only areas that receive light will be disinfected; In some cases, the surface may need to be approached
             from different angles to reach shadows
Additional Items to consider when using this instrument:
        • Do not use this unit to disinfect clothing on a person or any part of your body.
        • UV rays can reflect off surfaces, especially shiny ones; always wear PPE when unit is on.
        • Surfaces that contain dirt and dust could impact the disinfecting as the dirt could potentially shield viruses from the light; it is
             advised to physically clean these areas prior to relying on UV disinfecting.
        • The bulb in this unit has a shatterproof coating. If the bulb needs to be replaced; it should be disposed of in one of the
             proper “Universal Waste – Lamps” containers.
For additional questions on this unit or the proper use, refer to General Safe Work Practice K or contact the Environmental or
Safety Department.

     Rev. 4 – March 2021                                                                                                                         41
IF SOMEONE EXHIBITS SIGNS ASSOCIATED WITH COVID-19
         •    Symptoms of respiratory infection, including cough or difficulty breathing, fever, chills, sore throat, muscle pain or
                                                         new loss of taste or smell.

1.     Immediately clean/disinfect work area.
2.     Wear safety glasses, disposable gloves, and FR jacket (comfort only N95 respirator may also be used).
3.     Remove and dispose of gloves, taking care to avoid bare skin contact with the outside surface of the gloves.
4.     Place disposables in closed trash container (dispose of trash bag if container is open top) and jacket in soiled container.
5.     Wash hands with soap and water.

     Rev. 4 – March 2021                                                                                                               42
Janitorial Service Management
To control the exposure and spread of a virus, Procurement and the Janitorial Service will:
Increase Disinfecting: Collaborate with the janitorial service to increase or add disinfecting. Review other
cleaning practices and reduce services as appropriate.
   •     Re-allocate resources from office spaces for employees working from home.
   •     Reduce the frequency of cleaning activities, such as vacuuming, to utilize that time disinfecting.
   •     High touch surfaces will be a priority
   •     Ensure proper safety training is in place for any new porters coming on-site and appropriate PPE is being
         worn.

Manage Critical Supplies: Ensure janitorial service providers have adequate stock of critical supplies.
   • As supplies become harder to procure, the janitorial services must be prepared with supplies on hand and
     have reliable supply chain channels.
   • Immediately secure critical supplies that are on-site. A limited subset of employees will have access to
     distribute supplies, while ensuring the vendor stocking the supplies and the janitorial service have access.
   • Review disinfecting products being used by the janitorial service to ensure they are CDC approved
     disinfectants.
   • Review manufacturer recommended PPE for each product, such as gloves and face coverings if needed.
     Guidelines will be laid out in safe work practices.
   • An approved supplies list is found in the cleaning protocol, this includes UV Lights, and fogging.

       Rev. 4 – March 2021                                                                                           43
Prepare for Positive Case Response: Prepare the janitorial service or 3rd party contractor for a positive case
response. Determine the appropriate contacts, emergency phone number and required response time. Review
cleaning capabilities, capacity, and service costs.
   • Response time: Ideally, the response team could report on-site within 2 hours of an emergency call, full
     details are laid out in the positive case protocol.
   • Charter Steel must have a back-up vendor for positive case response. This source may also cover other
     capacity and capability gaps of the janitorial service.

Complete Cleaning Logs: Document disinfecting by area using cleaning logs, as defined in the cleaning protocol.
   • The log will capture disinfecting activities done by employees, janitorial services, and any 3rd party
       contractors.
   • Charter Steel will communicate any gaps found on the logs to the janitorial service.
Update Operating Procedures: As service levels change, janitorial operating procedures (cleaning specifications)
that the porters use must be continually updated. A full cleaning coverage table can be found in the cleaning
protocols.
Methods of disinfecting: Alternatives to disinfecting by hand.
   • Determine if the janitorial service has capability to use a sprayer, electrostatic fogger, or UV lights to
     disinfect.

Manage Office Staffing Changes: For people working from home, identify a process to cover cleaning in those
office spaces through each return to work phase.
   •     Determine which tasks will be managed internally, by the janitorial service or by a 3rd party.
       Rev. 4 – March 2021                                                                                        44
Contractor Disinfecting Services

The Environmental Department is responsible for securing the services of a sufficient
number of emergency cleaning contractor options to support timely response to
sanitizing the workspace following a confirmed case.
Contractors should be thoroughly vetted and familiarized with Charter Steel facilities
and procedures prior to an emergency service call.

The ranked list of approved contractors can be found in the Confirmed Case Response
Procedure.

   Rev. 4 – March 2021                                                                   45
Confirmed Case Response Procedure

In order to safely respond to a positive case of COVID-19 to prevent the spread of the
virus to others a procedure has been developed. This procedure includes notifying
employees that have come into close contact, disinfecting areas of contact and
communication to appropriate parties. These procedures have been tested with
tabletop and live drill scenarios. Response Teams have been organized and trained by
plant for effective investigation and actions to prevent the spread of COVID 19.

Click here for Procedure

   Rev. 4 – March 2021                                                                   46
Positive COVID-19 Response Training
Click here for the Training PowerPoint

   Rev. 4 – March 2021                   47
Department of Health Relationship
Initiate Contact and Build Relationship
Early in a pandemic it is valuable to begin dialog with local health departments. Contact county or local
health departments and ask to be included in any email or web-based update process to ensure you
keep informed of changes to outbreak status, protocols, or requirements.
Contact Information

Cuyahoga County Board of Health (CLE)
https://www.ccbh.net/                                            Washington Ozaukee Public Health Department
(216)201-2000                                                    http://www.washozwi.gov/
                                                                 Port Washington Office (262)284-8170
Wood County Health Department (FOS)                              West Bend Office (262)335-4462
http://www.woodcountyhealth.org/
Bowling Green Office (419)352-8402

Contact Tracing & Post Sanitation Protocol
Some state or local health agencies require employers to report and/or coordinate positive case management with them.
Identify all local health agency protocol and requirements and how they can affect operations.

Include any changes to required coordination with local health agencies in the Positive Case Management protocols.

Stay up to date with the tracing process used by the local health agency and ensure site documentation is aligned to allow
for efficient information gathering.

Align disinfection/sanitation practices and documentation to allow for expedited startup of operations if health agency
approval is required.
    Rev. 4 – March 2021                                                                                                   48
Disinfecting / Sanitizing Stations
Sanitization Stations are locations where employees and visitors can locate disinfecting supplies.

Please contact a facilitator, supervisor, or administrative support staff if supplies are low.
                                   Suggested Locations           Suggested Supplies
                          -Building Entry Points             -Hand Sanitizer
                          -Conference Rooms                  -Disinfecting Wipes
                          -Lunch Rooms and Vending           -Disposable Gloves
                          -Pulpits                           -Disposable Masks
                          -Visitor Sign in Locations         -Disinfecting Spray
                          -Water Coolers and Coffee Makers   -Paper Toweling
                          -Department Common Areas
                          -Copiers/Mailrooms
                          -Scanners

High touch points are a high transmission risk. Having supplies available at these locations will help
reduce our exposure to the virus.

Each location must be analyzed for needed supplies. A location may need disinfecting wipes over a
spray.

Hand washing is preferred over hand sanitizer where the option is available.

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Rev. 4 – March 2021
Personal Protective Equipment Protocol

PPE, when used properly, is a key method to reduce the transmission of COVID-19. The
purpose of the Personal Protective Equipment protocol is to establish the guidelines and
circumstances where personal protective equipment must be worn to control and
prevent the spread of a virus.
Masks Protocol for Reducing Transmission of COVID-19
   • N95 filtering facepiece respirators are not to be used for COVID-19 protection, as
     limited supplies need to be reserved for workplace particulate protection,
     hospitals, and emergency services.
   • General purpose masks are the preferred option for COVID-19 protection. Masks
     used to reduce transmission of COVID-19 are not necessarily appropriate for
     protecting you against workplace contaminants, such as particulates, acid gases or
     organic vapors. Follow all Level 3 and safe work practices appropriate to the area,
     including specific respiratory protection.

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Rev. 4 – March 2021
Safety Glasses          Mask                Gloves                    Face Shield

 Emergency response team                                    Required                Required            Required                  **Optional

 General Cleaning                                           Required                *Optional           Required                  **Optional

 Cleaning Personal Workstation                              Follow Mfg. Reqts       *Optional           Follow Mfg. Reqts         **Optional

 Employees away from their workstation or working           As specified based on   Required                                      **Optional
 under 6 ft apart with no barrier in plant/office setting   risk assessment
                                                                                                                                  (in place of mask)

 Shipping & Receiving (interacting with drivers)            Required                *Optional           Required

 Decontamination of affected areas                          Required                Required            Required

 General Plant Area/at office workstation                                           *Optional

 Off-site Visits (Customer Sites)                           Follow Site Requirements

 Company Travel (Planes, Trains, Autos)                     Follow Regional Travel Advice

 *See WI specific mask requirements on later page.

** WI sites: Face Shields are not an option for use in place of a mask while the Governor’s Order is in place. Excepts only allowed if approved due
     to medical condition or risk assessment determines face masks creates greater hazard.
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      Rev. 4 – March 2021
*See WI specific mask requirements on following page.

** WI sites: Face Shields are not an option for use in place of a mask while the Governor’s Order is in place. Exceptions only allowed if approved
   due to medical condition or risk assessment determines face masks creates greater hazard.

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      Rev. 4 – March 2021
Temporary Operating Procedure for Mask at WI Sites
Wisconsin sites are required to follow additional mask requirements while Governor
Evers’ executive order requiring the use of masks is in place. The following additional
temporary requirements have been put in place in WI to comply with the order.
In addition to current protocols, masks are required to be worn when:
   •   walking into/out of work (wear a mask to and from your car)
   •   in a pulpit, locker room or any enclosed space and you are not alone
   •   in your office or cubicle and not alone
   •   in a break room, lunchroom, clean room, or log room and not actively eating or drinking
   •   not at your workstation - Workstation is defined as the area where work is being performed as part of
       assigned or routine work tasks

Exceptions where a mask is not required by the order include when:
   •   actively eating or drinking
   •   working alone in a pulpit (but the moment another teammate enters, both must wear masks)
   •   operating mobile equipment alone
   •   in a crane cab alone
   •   at your desk, cubical or office alone (but must wear mask when someone comes to talk to you)

Note: Face shields can be used instead of masks for medical conditions or if the mask creates a greater safety or
health hazard as determined by utilizing a risk assessment.

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Rev. 4 – March 2021
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