   The Elhart Automotive Campus (hereinafter "Company") takes the health and safety of our employees very seriously. With the spread of the coronavirus or "COVID-19," a respiratory disease caused by the SARS-CoV-2 virus, the Company must remain vigilant in mitigating the outbreak. In order to be safe and maintain operations, we have developed this COVID-19 Exposure Prevention, Preparedness, and Response Plan to be implemented by the Company. The Company will continue to monitor the related guidance that U.S. Center for Disease Control and Prevention ("CDC") and Occupational Safety and Health Administration ("OSHA") continue to make available.
This Plan is based on information available from the CDC and OSHA at the time of its development and is subject to change based on further information provided by the CDC, OSHA, and other medical and public officials. The Company may also amend this Plan based on operational needs.
I. RESPONSIBILITIES OF MANAGERS AND SUPERVISORS
All managers and supervisors must be familiar with this Plan and be ready to answer questions from employees. Managers and supervisors must set a good example by following this Plan at all times. This involves practicing good personal hygiene and safety practices to prevent the spread of the virus. Managers and supervisors must encourage this same behavior from all employees.
Our Department Managers will implement, monitor, and report on the COVID-19 control strategies. These managers remain on-site at all times when employees are present on site.
II. RESPONSIBILITIES OF EMPLOYEES
The Company is asking every one of our employees to help with our prevention efforts while at work. In order to minimize the spread of COVID-19 at our jobsites, everyone must play their part. As set forth below, the Company has instituted various housekeeping, social distancing, and other best practices. All employees must follow these. In addition, employees are expected to report to their managers or supervisors if they are experiencing signs or symptoms of COVID-19, as described below. If you have a specific question about this Plan or COVID-19, please ask your manager or supervisor. If they cannot answer the question, please contact Robert Gibson, General Manager.
OSHA and the CDC have provided the following control and preventative guidance for all workers, regardless of exposure risk:
· Frequently wash your hands with soap and water for at least 20 seconds. When soap and running water are unavailable, use an alcohol-based hand rub with at least 60% alcohol.
· Avoid touching your eyes, nose, or mouth with unwashed hands.
· Follow appropriate respiratory etiquette, which includes covering for coughs and sneezes.
· Avoid close contact with people who are sick.
· In addition, employees must familiarize themselves with the symptoms of COVID-19, which include the following:
-Coughing;
-Fever;
-Shortness of breath, difficulty breathing; and
-Early symptoms such as chills, body aches, sore throat, headache, diarrhea, nausea/vomiting, and runny nose.
If you develop a fever and symptoms of respiratory illness, such as cough or shortness of breath, DO NOT COME TO WORK and call your supervisor and healthcare provider right away. Likewise, if you come into close contact with someone showing these symptoms, call your supervisor and healthcare provider right away.
III. PROTECTIVE MEASURES
The Company has instituted the following protective measures at the dealership.
A. General Safety Policies and Rules:
1. The dealership promotes remote work to the fullest extent possible.
2.    The dealership has limited staffing to the minimum number necessary to operate.
3. Elhart has assigned dedicated entry point(s) for all employees to reduce congestion at the main entrances of build-
       ing and offices.
4.    Any employee/visitor showing symptoms of COVID-19 will be asked to leave the dealership and return home. The Company's protocol for those showing symptoms of Covid-19, those diagnosed with Covid-19 and those in close contact with a person diagnosed with Covid-19 can be found on page 5, Section 5 "JOBSITE EXPOSURE SITUATIONS" of this response Plan.
5.    The Dealership will provide COVID-19 training to all employees that covers, at a minimum:
· Workplace infection-control practices
· The proper use of personal protective equipment.
· Steps the employee must take to notify the business or operation of any symptoms of COVID-19 or a suspected or confirmed diagnosis of COVID-19.
· How to report unsafe working conditions.
· How to log daily entry self-screening questionnaires.
· Appropriate cleaning procedures, including training for cashiers on cleaning between customers.
· How to manage symptomatic customers upon entry or in the store.
· Please see Elhart's Covid-19 Employee Training Program for details
6. The Dealership will Conduct a daily entry self-screening protocol for all employees/contractors entering the workplace, a questionnaire covering symptoms & suspected or confirmed exposure to people with possible COVID.Â
· Managers must see that 100% of employees complete this questionnaire every day and retain the completed questionnaires for required logging.Â
· If any employee answers yes to the screening questions, managers must confidentially engage the employee and follow protocol for further screening or dismissal from work.
7.  General Safety Practices
· The Dealership and management team will oversee that everyone on the worksite premises stay at least six feet from one another to the maximum extent possible, including through the use of ground markings, signs, and physical barriers, as appropriate to the worksite.
· All in-person meetings will be limited. To the extent possible, meetings will be conducted by telephone.
· If meetings are conducted in-person, avoid gathering in groups of more than 10 people and participants must remain at least six (6) feet apart.
· Employees will be required to wear face coverings in shared spaces, including during in-person meetings and in restrooms and hallways.
· Employees will be encouraged to stagger breaks and lunches, if practicable, to reduce the size of any group at any one time to less than ten (10) people.
· Employees should limit the use of co-workers' devices, tools, and equipment. To the extent devices, tools, and equipment must be shared, the Company will provide alcohol-based wipes to clean devices, tools, and equipment before and after use. When cleaning the devices, tools and equipment, employees should consult manufacturing recommendations for proper cleaning techniques and restrictions.
· Employees are encouraged to minimize ride-sharing. While in vehicles, employees must ensure adequate ventilation. If practicable, each employee should use/drive the same truck or piece of equipment and not rotate vehicles. Additionally, employees and customers using demonstrator vehicles should be advised to limit other vehicle passengers, such as family members, from using/riding in the vehicle.
· Increase distancing between employees by spreading out workspaces, staggering workspace usage, restricting non-essential common space (e.g., cafeterias), providing visual cues to guide movement and activity (e.g., restricting elevator capacity with markings, locking conference rooms).
· Prohibit social gatherings and meetings that do not allow for social distancing or that create unnecessary movement through the office.
· Provide disinfecting supplies and require employees wipe down their work stations at least twice daily.
· Post signs about the importance of personal hygiene.
· Suspend all nonessential visitors.
· Restrict all non-essential travel, including in-person conference events.
· In lieu of using a common source of drinking water, such as a cooler, employees should use individual water bottles.
· Elhart encourages employees to use personal protective equipment and hand sanitizer on public transportation.
B. Personal Protective Equipment and Work Practice Controls:
1. Elhart will Provide non-medical grade face coverings to their employees and will require face coverings to be worn when employees cannot consistently maintain six feet of separation from other individuals in the workplace. The Company will not prohibit an employee from wearing PPE while working.
2.   PPE Training is provided to all employees
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               C. Customers and Other Visitors:
1. The number of customers on the dealership premises shall be limited as advised by current local, state and federal guidelines to limit the spread of COVID-19;
2. The Dealership has posted signs at store entrance(s) informing customers not to enter if they are or have recently
        been sick.
3.  All customers will be screened in advance of entering the dealership facilities. If the customer answers "yes" to any of the following questions, he/she should not be permitted to access the jobsite:
· Have you been confirmed positive for COVID-19?
· Are you currently experiencing, or recently experienced, any acute respiratory illness symptoms such as fever, cough, or shortness of breath?
· Have you been in close contact with any persons who has been confirmed positive for COVID-19?
· Have you been in close contact with any persons who have traveled and are also exhibiting acute respiratory illness symptoms?
4. Deliveries will be permitted but should be properly coordinated in line with the Company's minimal contact and cleaning protocols. Delivery personnel should remain in their vehicles if at all possible.
5. If required by local, state or federal order, all customers and other visitors will be required to wear a covering over
       his or her nose and mouth-such as a homemade mask, scarf, bandana, or handkerchief; the Company may require
       customers and visitors to comply with this requirement notwithstanding the lifting of any local, state or federal or
       der or guidelines.  If a customer does not have a face covering, we will provide them one, free of charge. Signs are
       posted on entrance doors and in all customer areas to explain that masks are required, and masks are available.
6. The Company will not permit customers to congregate in close proximity in small waiting rooms and will encourage
        social distancing.
7.    The company has created communication materials for customers (e.g., signs or pamphlets) to inform them of  Â
       changes to store practices and to explain the precautions the store is taking to prevent infection. These are postedÂ
       on all doors and customer areas.
8. The company has established lines to regulate entry with markings for patrons to enable them to stand at least six
        feet apart from one another while waiting. Elhart also explore alternatives to any lines, allowing customers to wait
        in their cars for a text message or phone call, to enable social distancing and to accommodate seniors and those
        with disabilities.
9. Elhart has designed spaces and store activities in a manner that encourages employees and customers to maintain  Â
       Six feet of distance from one another.
10. Elhart has Installed physical barriers at checkout or other service points that require interaction, including plexiglass barriers, tape markers, or tables, as appropriate.
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IV. DEALERSHIP CLEANING AND DISINFECTING
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A. The Company has instituted regular and additional housekeeping practices, which include cleaning and disinfecting frequently used tools and equipment, and other elements of the work environment. Employees should regularly do the same in their assigned work areas.
B. An additional staff member is employed to do regular disinfecting of "often used" surfaces throughout the day at all Elhart locations.
C. Break/lunchroom and bathroom areas will be cleaned frequently. Employees performing cleaning will be issued proper personal protective equipment ("PPE"), such as nitrile, latex, or vinyl gloves and gowns, as recommended by the CDC.
D. Any trash collected from the jobsite must be changed frequently by someone wearing nitrile, latex, or vinyl gloves.
E. The Company will ensure that hand sanitizer dispensers are always filled.
F. Vehicles and equipment/tools must be cleaned before change in operator or rider.
G. The Company will clean those areas of the jobsite that a confirmed-positive individual may have contacted and it will do so before employees can access that workspace again.
H. The Company will ensure that any disinfection shall be conducted using one of the following:
· Common EPA-registered household disinfectant;
· Alcohol solution with at least 60% alcohol; or
· Diluted household bleach solutions (if appropriate for the surface).
I. The Company will maintain Safety Data Sheets of all disinfectants used on site.
J. The Company will sanitize/disinfect/wipe down customer vehicles at drop off and pick up.  The dealership utilizes spray sanitizer "Transform":
· Service uses Transform when customers come into the lane and after they complete the work.
· Collision and Detail uses Transform when the vehicle enters the facility and at delivery
· Rental uses Transform before showing each vehicle, upon return at vehicle "check in" and after the detail process.
· Sales uses Transform before and after showing the vehicle/test drive and at delivery of the vehicle.
K. The Company requires that employees place seat, floor mat and steering wheel protectors in all vehicles.
L. All employees involved in touching customers' vehicles must use rubber gloves and change them frequently and must change or wash gloves before working on a different vehicle.
M. The Company will place hand sanitizer in all customer and employee areas, including every desk, customer waiting area, parts counter, technician stalls, etc.
O. Elhart makes cleaning supplies available to employees upon entry and at the worksite, and provides time for employees to wash hands frequently or to use hand sanitizer.
N. The Company will place signs and put tape on the floor or use pre-made floor markers to remind everyone of social distancing.
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V. JOBSITE EXPOSURE SITUATIONS
A. Employee Exhibits COVID-19 Symptoms:
                If an employee exhibits COVID-19 symptoms and does not have test results or is unable to be tested, the employee must be sent home and remain at home until (1) at least 72 hours (3 full days) have passed since recovery (Recovery is defined as (a) resolution of fever without the use of fever-reducing medications and (b) improvement in respiratory symptoms (e.g., cough, shortness of breath); and (2) at least seven (7) days have passed since symptoms first appeared. To the extent practical, employees are required to obtain a doctor's note clearing them to return to work.
B. Employee Tests Positive for COVID-19:
An employee who tests positive for COVID-19 will be directed to self-quarantine away from work. Employees that test positive and are symptom free may return to work when at least seven (7) days have passed since the date of his or her first positive test, and have not had a subsequent illness. Employees who test positive and have symptoms and are di rected to care for themselves at home may return to work when (1) at least 72 hours (3 full days) have passed since recov ery (Recovery is defined as (a) resolution of fever without the use of fever-reducing medications and (b) improvement in respiratory symptoms (e.g., cough, shortness of breath); and (2) at least seven (7) days have passed since symptoms first appeared. Employees who test positive and have been hospitalized may return to work when directed to do so by their medical care providers. The Company may require an employee to provide documentation clearing his or her return to work.
                               Notification: When an employee is identified with a confirmed case of COVID-19, within 24 hours, Elhart will notify:
· The local public health department
· Any co-workers, contractors, or suppliers who may have come into contact with the person with a confirmed case of COVID-19.
Cleaning and Disinfection:Â From the CDC, Timing and location of cleaning and disinfection of surfaces After Persons Suspected/Confirmed to Have COVID-19 Have Been in the Facility:
·  Close off areas visited by the ill persons. Open outside doors and windows and use ventilating fans to increase air circulation in the area. Wait 24 hours or as long as practical before beginning cleaning and disinfection.
· Cleaning staff should clean and disinfect all areas such as offices, bathrooms, common areas, shared electronic equipment (like tablets, touch screens, keyboards, remote controls, tools and equipment) used by the ill persons, focusing especially on frequently touched surfaces.
· Please see The CDC's How to Clean and Disinfect attached to this Response Plan. Elhart will follow this CDC process completely.
C. Employee Has Close Contact with an Individual Who Has Tested Positive for COVID-19:
Employees who have come into close contact with an individual (including customer or supplier) who has tested positive for COVID-19 (co-worker or otherwise) will be directed to self-quarantine for 14 days from the last date of close contact with that individual. Close contact is defined as six (6) feet for a prolonged period of time.
If the Company learns that an employee has tested positive, the Company will conduct an investigation to determine co-workers who may have had close contact with the confirmed positive employee in the prior 14 days and direct those individuals who have had close contact with the confirmed-positive employee to self-quarantine for 14 days from the last date of close contact with that employee. If applicable, the Company will also notify any sub-contractors, vendors/suppliers or visitors who may have had close contact with the confirmed-positive employee. If an employee learns that he or she has come into close contact with a confirmed-positive individual outside of the workplace, he/she must alert a manager or supervisor of the close contact and self-quarantine for 14 days from the last date of close contact with that individual.
VI. RECORDKEEPING
A. OSHA: If a confirmed case of COVID-19 is reported, the Company will determine if it meets the criteria for recordability and reportability under OSHA's recordkeeping rule.
B. Executive Order Requirements: Elhart will maintain a record of the requirements set forth in Sections
· 1(c) Covid-19 Training to Employees
· 1(d) Daily Entry Self-Screening protocol
· 1(k) In the event that an employee is identified with a confirmed case of COVID-19, within 24 hours, Elhart will maintain a record of and notify both the local public health department, and any co-workers, contractors, or suppliers who may have come into contact with the person with a confirmed case of COVID-19.
VII. CONFIDENTIALITY/PRIVACY
Except for circumstances in which the Company is legally required to report workplace occurrences of communicable disease, the confidentiality of all medical conditions will be maintained in accordance with applicable law and to the extent practical under the circumstances. When it is required, the number of persons who will be informed that an unnamed employee has tested positive will be kept to the minimum needed to comply with reporting requirements and to limit the potential for transmission to others. The Company reserves the right to inform other employees that an unnamed co-worker has been diagnosed with COVID-19 if the other employees might have been exposed to the disease so the employees may take measures to protect their own health. The Company also reserves the right to inform vendors/suppliers or customers that an unnamed employee has been diagnosed with COVID-19 if they might have been exposed to the disease so those individuals may take measures to protect their own health.
VIII.      RETALIATION/DISCRIMINATION
Follow Executive Order 2020-36, and any executive orders that follow it, that prohibit discharging, disciplining, or otherwise retaliating against employees who stay home or who leave work when they are at particular risk of infecting others with COVID-19.
IX. GENERAL QUESTIONS
Given the fast-developing nature of the COVID-19 outbreak, the Company may modify this Plan on a case by case basis. If you have any questions concerning this Plan, please contact General Manager or Human Resources Director..
