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Critical Infrastructure Guidance

Resources from the Office of Governor Mike Dunleavy, Alaska Department of Health and Social Services, and Alaska Division of Homeland Security and Emergency Management.

Vaccination of Critical Infrastructure Workers

On 10 February, the State of Alaska published revised vaccine eligibility guidance, which can be found here: http://dhss.alaska.gov/dph/Epi/id/Pages/COVID-19/VaccineAvailability.aspx. As Phase 1b, Tier 2 opens, more Critical Infrastructure workers we be eligible to receive vaccine. Concurrently, the State opened vaccination to non-resident workers, with additional guidance provider thorough a letter (linked below) from the Governor’s Chief of Staff and the Commissioner of Dept. of Health and Social Services. All CI employers should incorporate these changes and guidance into their plans for vaccination of their workforce. Additionally, while not yet required, it is recommended that CI employers provide their workers with appropriate documentation to prove their eligibility to receive vaccine from a registered provider. A possible template for CI Employee Letters is also linked below.

Testing Requirements for Critical Infrastructure Workers Arriving from International Airports

On 12 January, the Center for Disease Control (CDC) released an Order titled “Requirement for Proof of Negative COVID-19 Test or Recovery from COVID-19 for All Air Passengers Arriving in the United States,” which will go into effect on Tuesday, 26 January 2021.

The order requires all airline passengers arriving to the United States directly from a foreign airport to have documented negative COVID-19 test results prior to boarding the aircraft. The requirement has been placed on the airline to screen passengers prior to boarding to ensure that they meet this requirement.

There will be no immediate change to the State of Alaska COVID-19 Outbreak Health Order No. 6 (International and Interstate Travel) as a result of this new CDC Order, as the Federal requirement is additional and does not conflict with or over-ride the State Health Order.

Private sector businesses and public agencies which are part of our Critical Infrastructure workforce should be aware of several considerations regarding the CDC Order:

  • Other than those exemptions noted for aircrews and airline employees who are following the FAA SAFO, there are no other exemptions from this testing requirement granted for CI workers, and no process identified to request exemption. The State of Alaska does not have the ability to exempt travelers from the Federal entrance requirements. CI employees are still allowed to forego the State testing requirements in HO-6 if their employer has established alternate protective measures in their Community Workforce Protective Plan. All CI workers arriving from international airports must now also meet the Federal testing requirement, regardless of what is in their employer’s CWPP.
  • This Federal testing requirement also applies to charter flights originating from foreign airports. If a company is bringing in CI workers on a chartered flight, it is incumbent upon the employer to ensure that all passengers meet the Federal testing requirement.
  • The Federal testing requirement does not allow individuals to travel with pending test results, or to travel without a test and receive a test upon arrival.
  • The Federal testing requirements may be met with an FDA-authorized antigen test. The State requirements in HOs 5 & 6 do not allow for antigen testing to meet State entrance requirements. If an employer is having inbound CI workers tested solely to meet the Federal requirements (with a molecular test planned later in their Entry Quarantine process), an antigen test may suffice. But if the test is intended to satisfy the Entry Quarantine test required by HO-5 or an employer’s CWPP, then it must be an FDA-authorized molecular test.
  • Arriving international travelers who have tested positive for COVID-19 within 90 days prior to travel are not require to test, but must provide documentation of positive test results (with personal identifiers that match their travel documents) and a signed letter on official letterhead that contains the name, address and phone number of a licensed healthcare provider of public health official stating that the passenger has been cleared for travel. Recovered prior positives who first contracted the disease more than 90 days prior to travel are required to test.
  • More information regarding this Order and answers to FAQs are available at the CDC website at: https://www.cdc.gov/coronavirus/2019-ncov/travelers/testing-international-air-travelers.html

Close Contact Quarantine for Critical Infrastructure Workers

When an individual is identified as a close contact of a confirmed case of SARS-CoV-2 (the virus that causes COVID-19), they should quarantine for 14 days to reduce the risk of spreading the virus should they become infected. Based on the available evidence, this is the safest course of action.

However, critical infrastructure workers may be able to work during their quarantine period if their organization would be unable to maintain operations safely without them. Allowing exposed individuals to continue work carries inherent risk, and should only be done as a last resort to maintain the continuity of essential services. Close Contact Quarantine is different and more critical than Entry Travel Quarantine, when it is not known whether or not someone has been exposed. Allowing a CI worker to continue working during Close Contact Quarantine should be determined on a case-by-case basis, not a blanket policy from the employer’s CWPP.

When determining whether or not an individual is allowed to work during quarantine the following should be considered:

  1. Is the close contact specifically critical to the operations? Individuals who can stay home should stay home.
  2. If a close contact does have to work, could their responsibilities be temporarily changed in a way that reduces their contact with others? Is there a way to eliminate their contact with others who are higher risk (for example, older adults)?

Close contacts who have to continue working should adhere to the following practices:

  • Pre-Screen: Employers should measure the employee’s temperature and assess symptoms prior to them starting work. Ideally, temperature checks should happen before the individual enters the facility.
  • Regular Monitoring: As long as the employee doesn’t have a fever or symptoms, they should self-monitor under the supervision of their employer’s occupational health program.
  • Wear a Mask: The employee should wear a face mask at all times while in the workplace for 14 days after last exposure. Employers can issue facemasks or can approve employees’ supplied cloth face coverings in the event of shortages.
  • Social Distance: The employee should maintain 6 feet and practice social distancing as work duties permit in the workplace.
  • Disinfect and Clean work spaces: Clean and disinfect all areas such as offices, bathrooms, common areas, shared electronic equipment routinely.

Additional guidance is provided here: https://www.cdc.gov/coronavirus/2019-ncov/community/critical-workers/implementing-safety-practices.html

Two other points:

  • Close contacts who must continue working are still under quarantine outside their working hours.
  • At this time, a negative test results will not shorten the duration of Close Contact Quarantine.

If you have any questions, please call the Alaska Section of Epidemiology at 907-269-8000.

Notice to Critical Infrastructure Workers Travelers Arriving to Alaska

  1. Travel that is deemed essential or for critical infrastructure, as previously defined in Health Orders 6 and 8, will continue as it has under existing guidance.
  2. Critical infrastructure workers traveling to Alaska will no longer be able to use state-funded testing at airports.
  3. Critical infrastructure companies and organizations will be asked to provide employees with a letter on company letterhead that states they are a critical infrastructure worker. These letters must include travel plans and confirm that the traveler is following the employer’s Community Workforce Protect Plan on file with the state that includes testing and/or quarantine provisions.

Protective Plans

All Critical Infrastructure businesses with workers arriving to the State are still required under COVID-19 Outbreak Health Orders to develop and submit a Community/Workforce Protective Plan (CWPP) to the Unified Command for review. Additionally, all private sector businesses, whether Essential Services/Critical Infrastructure or non-essential/non-critical, with workers traveling between Alaskan communities off of highway and Alaska Marine Highway systems are still required under COVID-19 Outbreak Health Orders to develop and submit a CWPP to the Unified Command for review. Protective Plans can be submitted to akcovidplans@ak-prepared.com. Visit the State website at  https://covid19.alaska.gov/unified-command/protective-plans for guidance on developing Protective Plans.

Educators and School Staff

DHSS is working closely with DEED, superintendents, school districts, and teachers to protect students and staff from COVID-19, while assuring that kids continue to receive an excellent education. As is true for other essential critical infrastructure domains, the school setting is unique in many ways that necessitate a tailored strategy for dealing with COVID-19 cases and outbreaks. Detailed DHSS school-specific COVID-19 guidance is available here.

Seafood Processing Workers

Workers arriving to the State to work in shore-based seafood processing plants, processor vessels and larger catcher-processor vessels must continue to follow the requirements of Appendix 01 to Health Order 5. Seafood processing workers are not permitted to shorten or modify quarantine using a test-based strategy.

Seafood processing companies are encouraged to read and incorporate the new CDC guidance on Protecting Seafood Processing Workers from COVID-19, available here.

Commercial Fishing Vessel Crewmembers

Vessel crews arriving to the State must continue to follow the requirements of Appendix 02 to Health Order 5. Vessel crewmembers may begin work during their quarantine period under the protective measures enacted by the Health Order but, are not permitted to shorten or modify quarantine using a test-based strategy. Testing is not required for vessel crewmembers, but it is highly recommended that all crewmembers be tested prior to joining a vessel, in order to avoid potential spread among the rest of the crew.

Independent Commercial Fishing Harvesters

Independent harvesters, such as setnetters, arriving to the State must continue to follow the requirements of Appendix 03 to Health Order 5. Harvesters may begin work during their quarantine period under the protective measures enacted by the Health Order, but are not permitted to shorten or modify quarantine using a test-based strategy.

Fishing Charter Operations and Lodges

Charter fishing operations which have staff arriving to the State or moving between Alaskan communities are required to submit Community/Workforce Protective Plans to the Unified Command for review. The Charter or Lodge CWPP must meet or exceed the travel, testing and on-site protective measures required of harvester sites in Appendix 03 to COVID-19 Outbreak Health Order 05. The employees of a charter fishing operation or lodge are considered Critical Infrastructure workers and must follow the employer’s submitted CWPP. The clients arriving to the lodge or charter operation from out-of-State are not considered Critical Infrastructure workers and must follow the guidance for non-essential travelers in COVID-19 Outbreak Health Order 06 – Interstate Travel.

All other Critical Infrastructure Businesses

Critical Infrastructure businesses must continue to follow the CWPP which they have submitted to the Unified Command for review. If companies intend to shorten or modify employees’ quarantine using a test-based strategy, they must revise their CWPP to reflect that they are choosing to accept the risk of doing so. Company leaders should bear in mind that the most effective protective measure currently available is a full 14-day quarantine. No currently available test or screening procedure is guaranteed, so shortening or modifying quarantine or allowing employees to work during quarantine carries inherent risks. Due to this, it is highly recommended that companies do not use a test-based strategy to shorten or modify quarantine for arriving workers who will be living or working in close proximity to others or sharing facilities such as dining and bathrooms.

Government Agencies

The requirement for companies to submit their Community/Workforce Protective Plan to the Alaska Unified Command is only for private sector businesses. The expectation is that all Federal, State, local and tribal government entities are establishing internal policies for travel and quarantine, but they are not required to submit those policies to the Unified Command. Some government agencies have developed protective plans which they are directing their contractors to follow. For example, all summer road construction crews are directed by the Alaska Department of Transportation to follow the AKDOT protective plan. If contracted companies have not been directed to follow a plan developed by the government agency that they are contracted with, they must develop and submit their own plan if they have workers arriving to the State or moving between Alaskan communities.

Critical Infrastructure Testing

In addition to Travel and Quarantine procedures, there have been many questions regarding the process for CI Workers to receive PCR tests upon arrival to the State. Critical Infrastructure businesses that need to have their arriving workers tested, either in accordance with their own CWPP or to comply with Health Orders 5, 6 and 8, must establish their own testing process through a local clinic or contracted medical service.

Questions regarding Critical Infrastructure travel may be sent to the Unified Command at: covidquestions@alaska.gov, with “ATTN: Critical Infrastructure” in the email subject line.