Climbing Gym Workplace Health & Safety for COVID-19 - Part I

Posted By Laura Allured, Thursday, May 28, 2020
Updated: Friday, May 29, 2020

It’s an understatement to say that climbing facilities have a lot to deal with right now. In addition to contending with the financial implications of getting members and customers back, gyms have to think about the various local, state, and federal rules for reopening. The decision to reopen for business comes down to a combination of issues that need to be weighed, each with their own risks. Among these issues is the safety and health of gym staff. The OSHA General Duty Clause requires that, “Each employer shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employee.” [OSH Act 1970]

Front desk staff, instructors, coaches, routesetters and the like are the faces of our industry and the first-line points of contact with the climbing public. Maintaining their health and safety during this pandemic is essential to keeping gyms safe and open for business.

This article is divided into two parts. The first part provides information about the Occupational Safety and Health Administration (OSHA) requirements for the health and safety of employees and practical approaches to managing workplace health and safety. Part II, which will be published next week, is a discussion section that is more interpretive and used to address specific questions related to legal issues and liabilities.

We must acknowledge that we are in unprecedented times for the climbing gym industry and small business as a whole. The playbook for such a pandemic is being written (and re-written) as we speak. There is some reliable information about the disease and transmission, but it is important to recognize that our understanding of “best practices” during this ongoing pandemic may change. However, there is a lot we can infer from infectious disease, in general, and that knowledge, along with existing evidence-based and peer-reviewed research and public health expertise, can act as a framework to advancing our position. The guidance provided here has been adapted from our current understanding of infectious disease controls, current workplace standards, and the best available science and public health policy, to date.

PART I – The Systematic Approach

Reopening Safely

The decision to reopen comes down to a number of factors. There are many types of gyms in different locations, with different populations and different local and state requirements. The focus here is on the aspects of the health and safety of employees. After reading through these questions you may realize that there is work to do. By taking additional time to think through these questions, discover answers, plan, and take a systematic approach you will be better prepared, more protective of your workers, and more likely to have a successful re-opening.

Consider the following questions:

1. What is the prevalence of the virus in the community? (Monitor WHO, CDC, as well as local and state health departments.)
2. Are there local, state, and federal orders that allow for reopening?
3. Do we have appropriate health and safety policies and programs in place? If not, where are the gaps?
4. What hazards are posed to staff?
5. Have we adequately communicated with the staff and what are the concerns of the employees?
6. What workplace controls are needed to protect staff?
7. Do we have an infectious disease Emergency Response Plan for dealing with an outbreak?
8. What enhanced cleaning and disinfecting procedures will be needed?
9. Do we have adequate and appropriate PPE for employees?
10. What additional staff training is required and how will we accomplish it?
11. What human resource policies need to be adjusted to accommodate for sick or at-risk employees? (ADA and HIPPA requirements must be followed.)
12. How will we track/measure the success of our policies?

Means of Exposure

We know that the SARS-CoV-2 virus that leads to the disease COVID-19, is a novel virus (i.e. new, or not previously identified), for which there is currently no vaccine. As such, the best approach for one to prevent illness is to avoid being exposed to the virus [CDC].

The virus spreads easily between people. The most common and likely route of exposure is person-to-person contact. Current research suggests that the most likely path of transmission for the virus is via liquid droplets from a carrier of the virus. These droplets may remain aloft in the air during exhalation, talking, sneezing, coughing, laughing, etc. Droplets may also be transferred from other parts of the body, most commonly, the hands, to the face (mouth, nose, and eyes).

A secondary means of the virus spreading may be through contact with surfaces or objects. Once droplets are present on a surface the viability of the virus is based on a number of factors, including but not limited to, the amount/quantity of droplets, type of material (i.e. plastic, metal, glass, wood, vinyl, etc.), and other variables. Research has shown that the SARS-CoV-2 virus can remain viable for a number of hours and up to a few days depending on various factors [NEJM Study].

According to credible health sources, COVID-19 is not spread through perspiration (sweat) however, items touched by many people in a gym (e.g., handholds, hangboards, ropes, carabiners, rental equipment, fitness equipment, etc.) could possibly pose a risk for transmission of settled respiratory droplets [Johns Hopkins School of Medicine FAQ].

Extrapolating from what we know about modes of transmission, in a climbing gym the most likely route of exposure would be through face-to-face interactions and direct contact with the patrons and co-workers. Other routes of exposures would be via communally handled or touched items coupled with a lack of good personal hygiene. Things like climbing walls, holds, volumes, ropes, rental shoes and harnesses, as well as other commonly touched areas around a gym including the front desk, keyboards/keypads, phones, waiver stations, door handles, and railings, provide the possibility of virus transfer.

Workplace Hazard Assessment

Identifying tasks where exposure may occur and addressing those areas ahead of time is a vital part of the process. A Workplace Hazard Assessment helps to systematically identify and address the risk to employees.

Climbing gyms have a high throughput of individuals and the amount of interaction and “contact” is relatively high compared to other workplaces. Based on the OSHA Occupational Risk Pyramid for COVID-19, many climbing gym workers align with the “Medium” exposure risk category. Medium exposure risks include those jobs that require frequent and/or close contact with (i.e. within 6 feet of) people who may be infected with SARS-CoV-2 but who are not known or suspected. The Lower exposure risk category include those jobs that do not require contact with people known to be, or suspected of having SARS-CoV-2 and frequent close contact is not likely to occur. This may pertain to those employees that work away from the public in an office.A Hazard Assessment does not have to be a complex exercise, but it should be a written document that demonstrates that you went through the process. Performing a Hazard Assessment is the starting point for the next part of the process: Workplace Controls. [OSHA Hazard Assessment Tool].

Workplace Controls

Approach workplace safety from a systematic approach by implementing a hierarchy of controls. The best approach to workplace safety is likely going to require a combination of these controls. The purpose of the hierarchy of controls is to work from the “most effective” to the “least effective.” It may be that installing HEPA Negative Air machines throughout your gym is a highly effective control, but that may not be practical. Then again, there may be adjustments you can make to your existing HVAC system that improve it efficiency. Move through the hierarchy and then consider the administrative controls and finally, Personal Protective Equipment.

Engineering Controls

Engineering Controls are those controls that are design-based approaches and tools to keep workers from being exposed. The benefits to this approach are that they offer the highest level of protection and do not rely on worker behavior to be effective. An additional benefit is that these controls often are equally effective in providing protection to your customers. These controls include things like:

• HEPA filtration units
• High efficiency air filters
• Increase of ventilation rates
  
  • Get fresh air into the gym
  • Maximize ventilation by using fans
• Installation of physical barriers like acrylic sneeze guards
• No-touch door opening-closing devices

Some drawbacks to engineering controls include the initial costs for the purchase of equipment, and limitations in types of exposures that are controlled. However, it is important to consider in your cost-comparisons the long-term benefit of engineering controls – there may be other benefits, like improved air quality, that are long term. An engineering control does not necessarily eliminate the hazard (i.e. the virus) but may offer an added level of protection.

Administrative Controls

An administrative control requires an action by the worker or the employer. These are changes in workplace policies and work procedures to reduce or minimize exposure to a hazard. These include:

Flexible Work Schedules

• Actively encouraging sick employees to stay home.
• Encourage sick employees to stay home without penalty.
• Limit operational hours.
• Change work shifts and alternating work days.
• Perform routesetting off-hours when the public is not present.

Physical Distancing

• Implement a social distancing plan for employees and public alike.
• Limit the number of people in the gym.
• Use physical barriers to create distancing and segregate areas.
• Mark zones and minimum 6-foot intervals on the floor and pads.
• Consider separate entrances and exits.
• Instruct at a distance.
• Consider the use of video and remote learning tools for training.
• Limit access to fitness training areas.
• Keep instructor to student ratio low.
• Do not shake hands.

Employee Training

• All employees must receive training about the gym’s health and safety policies and safe work practices.
• Training must be administered if face-coverings/masks are being required.
• Train employees on the importance of hand washing and proper method for hand washing.
• As applicable, train employees on the proper housekeeping, cleaning, and disinfection methods.
• Hazard Communication training should be provided on the safety and proper use of cleaning and disinfecting products. (Note: OSHA and the CDC have printable flyers available on their websites that can be posted.)
• Training is required for how to put on and remove gloves.
• If an N95 respiratory is being required, it must be within the context of a comprehensive respiratory protection program. (See additional notes about the use of N95 masks in Part II.)

Other Controls

• Use an on-line sign up system.
• Enable electronic payments and limit face-to-face transactions.
• Provide hand washing stations at the front of the establishment or alternatively, hand sanitizer if not feasible.
• Provide no-touch trash cans.
• Supply no-touch hand sanitizing devices.
• Provide tissues.
• Establish “before and after” rules for hand washing.

Personal Protective Equipment (PPE)

The use of Personal Protective Equipment is an important tool that can be used to minimize the likelihood of exposure. PPE for SARS-CoV-2 include things like cloth face coverings, gloves, protective eyewear or facemasks, and respiratory protection. Employers are obligated to provide their workers with the PPE needed to keep them safe during work (29 CFR 1910.132).

It is important to distinguish between what we mean by face coverings vs. Respiratory Protection. Surgical masks and face coverings are intended to trap droplets expelled by the user, they may protect others from the wearer of the mask but are not substantial enough to protect the wearer from an inhalation hazard. More recent guidance from the CDC has noted that some minimal level of protection is afforded to the wearer against droplet exposure. On the other hand, a respirator – such as an N95 NIOSH-approved respirator (National Institute for Occupational Safety and Health – NIOSH) has a rated level of protection to the wearer. There are additional requirements for a worker that wears an N95 (or half-face or full-face) respirator. Workers must be part of a comprehensive written respiratory protection program that includes fit-testing, training, and a medical evaluation. (29 CFR 1910.134)

While PPE is a valuable component of your health and safety controls it is not a substitute for good hygiene and physical distancing.

Requirements for PPE include:

• Training on the proper donning (putting on) and doffing (taking off) of masks and gloves
• Proper disposal of used PPE to avoid contamination

Employers should be aware that cleaning products and disinfectants may contain hazardous chemicals that could be harmful to workers. When workers are exposed to hazardous chemicals (such as sanitizing agents) additional personal protective equipment (PPE) is required. Additional guidance for these specific areas can be found in OSHA’s Hazardous Communication standard (29 CR 1910.1200), in the PPE standard (29 CFR 1910 Subpart I) and in the section specifically related to Housekeeping for hospital environments, which may apply here.

The U.S. Environmental Protection Agency (EPA) has developed a list of products that meet EPA’s criteria for use against SARS-CoV-2. Review product labels and Safety Data Sheets and follow manufacturer specifications.

Emergency Response Plan

Every climbing facility needs to consider the scenario where a presumed positive COVID-19 person has entered their facility. For this reason a workplace specific emergency response plan is necessary. CDC guidance recommends the following:

• Be prepared to change your business practices, if needed, to maintain critical operations.
• Establish an emergency communications plan. Identify key contacts (with back-ups), chain of communications (including suppliers and customers), and processes for tracking and communicating about business and employee status.
• Share your response plans with employees and clearly communicate expectations. It is important to let employees know plans and expectations if COVID-19 occurs in communities where you have a workplace.
• In most cases, you do not need to shut down your facility. But do close off any areas used for prolonged periods of time by the sick person:
  
  • Wait 24 hours before cleaning and disinfecting to minimize potential for other employees being exposed to respiratory droplets.
  • If waiting 24 hours is not feasible, wait as long as possible. During this waiting period, open outside doors and windows to increase air circulation in these areas.

For Gym Owners

In addition to considering and incorporating the above items into your plan, consider the following as well:

• If you do not already have one, designate a health and safety officer or a team. If that is not possible, seek outside expertise. A professional or company who specializes in workplace health and safety programs who has experience with climbing facilities is preferred.
• Using the guidance herein, along with the additional references, develop an Infectious Disease Preparedness and Response Plan.
• Develop a phase-in reopening plan. Your phased in plan should have measurable targets and contingencies in the event of changes.
• Develop procedures for the prompt identification and isolation of sick employees.
• Develop a wellness questionnaire. Employers have the right to require employees to participate in health screenings and monitoring programs for the purposes of protecting the workplace. A number of apps are coming to market that may help to monitor employee illness. Give additional consideration employees who are in an elevated-risk category as defined by the CDC (consult ADA). (Notes:
• Confidentiality of health data must be maintained and any health screenings should be made as private as possible.)
• COVID-19 can be a recordable illness if a worker is infected as a result of performing their work-related duties. Certain conditions apply including that it must be a “confirmed case” (i.e. presumptive positive test that was laboratory confirmed), the case must be “work-related,” (29 CFR 1904.5) and the case must meet certain criteria for days away from work and have required medical treatment (29 CFR 1904.7).
  Reduce and limit in-person staff meetings and gatherings.
  Work with your local health department in tracking cases and staying abreast of the ongoing trends.

For Employees

Employees have an important role to play in maintaining their own health and safety and in protecting their co-workers, the public, and the gym.

• Evaluate your health and do not come to work sick.
• Communicate with your manager about your condition.
• Report unsafe conditions to management.
• Abide by all physical distancing guidelines.
• Wear face coverings at work and out in public when social distancing cannot be maintained.
• Wash your hands often.
• Participate and seek training for the proper use and limitations of PPE.

Our Work Here Is Not Done

It's clear that our understanding of best practices during this pandemic may change and the situation is evolving on a daily basis. In Part II of this article, I will focus on some of the unanswered questions and areas of legal concern. Keep an eye out for this information covering the more nuanced areas of workplace safety and health next week.

Additional Guidance and References

• CWA Roadmap to Reopening
• Guidance on Preparing Workplaces for COVID-19 – OSHA 3990-03 2020
• Interim Guidance for Businesses and Employers Responding to Coronavirus Disease 2019 (COVID-19) – May 2020
• CDC – General Business FAQ
• National Safety Council - SAFER: Safe Actions for Employee Returns
• American Industrial Hygiene Association – Reopening Guidance for Gyms and Workout Facilities

About Aaron Gibson

Aaron is a climber of over 27 years and an EOSH Professional specializing in fall protection, health, and safety. He holds a Masters of Science in Environmental Epidemiology & Toxicology from the University of Oklahoma Health Science Center School of Public Health and is an Associate Safety Professional (ASP) pursuing his Certified Safety Professional (CSP) through the Board of Certified Safety Professionals (BCSP). He has over sixteen years of experience in workplace and environmental health and safety serving local, state, and federal agencies as well as private industry. Aaron has applied his experience to the climbing industry as a safety industry consultant, as well as a gym owner and manager, a USA Climbing coach, certified routesetter, CWA Climbing Wall Instructor Provider, and AMGA Single Pitch Instructor. You can contact Aaron at aaron@rockislandclimbing.com.