Managing Critical Infrastructure During the COVID-19 Pandemic

Background

To address the pandemic, governments have issued a range of mandates and official guidance regarding social distancing, face coverings, and business closures and restrictions aimed at limiting transmission among individuals in close contact. Businesses responsible for critical infrastructure, however, must continue certain operations in the challenging environment of the pandemic.

In recognition of this, essential critical infrastructure workers have been exempted from various “stay-at-home” orders.² This reality presents unique challenges for critical infrastructure operators, especially since many critical infrastructure workers cannot work remotely and often must work in close proximity to one another, whether in a control room, as part of a maintenance crew, or in an essential production facility. This heightens the risk of infection for individual workers and creates the potential for groups of essential workers to become infected at the same time, potentially threatening continuous operations of critical infrastructure functions.³

Accordingly, critical infrastructure companies and other essential businesses need to take measures and develop strategies to monitor and manage the risk of exposure to the virus that causes COVID-19 within their workforces.⁴ They also should develop contingency plans that can be implemented swiftly if an outbreak occurs within the essential employee population. These response measures require substantial advance planning because a range of medical, legal, and other considerations must be coordinated among company management, legal and medical advisors, and critical workforce personnel.

COVID-19 Disease Characteristics

Due to the novel and emergent nature of COVID-19, employers must establish a basic understanding about the disease in order to develop appropriate measures tailored to their company’s needs. While the medical community’s understanding of the virus is still evolving, some important points of consensus relevant to critical infrastructure workforce management have emerged.

First, COVID-19 is highly transmissible and spreads more efficiently than many other respiratory diseases.⁵ This is due, in part, to the relatively long incubation period and duration of asymptomatic transmission seen with COVID-19. In addition, the multiple modes of transmission of COVID-19 create challenges for controlling the spread in many workplace environments.⁶ Transmission occurs primarily through direct, indirect, or close contact with an infected individual through droplets created by coughing, sneezing, or talking. Droplets expelled by an infected individual can also contaminate surfaces and objects, leading to fomite transmission to other individuals. Researchers are also studying the possibility that COVID-19 can be transmitted by smaller, aerosolized particles that have the potential to remain in the air longer and to travel farther than with droplet transmission.⁷

Second, while the lethality of COVID-19 has been difficult to determine with precision, due to its novelty and the lack of sufficient testing to determine the total number of infections, it is significantly more deadly than the seasonal flu. Current estimates suggest that COVID-19 has an overall fatality rate of between 0.5 percent and 1 percent, which is 5–10 times higher than the seasonal flu with its average fatality rate of approximately 0.1 percent.⁸ Fatality rates have been observed to increase with age, including in working-age populations of those 45–54 years old and those 55–64 years old.⁹ Furthermore, while the vast majority of those who contract COVID-19 survive the disease, evidence suggests that it can have significant and lasting health impacts on those who contract it.¹⁰

Third, while some clinical trials have shown promise, development of a safe and effective vaccine remains elusive. Even with expedited development and approval protocols, the likely timelines for testing, development, and deployment of a vaccine will require critical infrastructure companies to continue managing through the pandemic for the foreseeable future.

Developing Workforce Management Protocols

Current understanding of COVID-19 points to a range of measures that companies can take to protect essential employees and support continued business operations. These risk-based approaches vary depending on the nature of the organization, as there is no one-size-fits-all solution. The expense and difficulty of implementing safeguards also vary, depending on the measures chosen.

Factors to consider in developing a COVID-19 workforce management program to ensure continuity of essential operations include: the minimum number of employees needed to operate mission-critical functions, the number of trained and licensed personnel qualified to conduct those functions, the ability to isolate or distance essential employees from nonessential personnel, and opportunities for early detection of infections within the workforce and effective response measures.

Assessment of these and other company-specific factors can help guide the choice of measures that will best support business continuity for a critical workforce. Basic, straightforward measures focused on vigilant workplace and at-home hygiene, consistent use of masks, and disciplined social distancing, for example, may be sufficient for organizations with large workforce reserves and controlled-access facilities, while more extensive measures may be necessary for those with less margin for error. Legal considerations and the extent of medical supervision required also vary based on the measures taken and should be carefully considered when developing workforce management protocols.

Basic Protective Measures

Basic protective measures are widely familiar by now. These require minimal effort and expense but can provide meaningful safeguards against exposure to and transmission of the COVID-19 virus. Basic protective measures include symptom monitoring, workplace social distancing and hygiene, education, reduced employee density and cohort staffing, and off-site/off-shift measures.

Symptom Monitoring

Daily temperature checks and symptom monitoring can help identify potentially infected individuals and prevent spread of disease to other employees, though the prevalence of asymptomatic transmission strongly indicates that symptom monitoring should be combined with other measures. The details of such a program should be developed with input from medical advisers and labor and employment counsel.

Workplace Social Distancing and Hygiene

These measures include social distancing practices within the workplace, mandatory masking requirements and use of other personal protective equipment (PPE) where appropriate, good personal hygiene practices, and enhanced cleaning and disinfecting in the workplace.¹¹

Education

While information about COVID-19 is readily available, education still plays an important role in effective workforce management. Effective education programs, with a focus not only on the “what” but also the “why,” can improve employee compliance both on and off the job. Written materials are important, but they are most effective when supplemented by other modes of communication, including briefings from management or expert advisers. Video training modules can provide further detail to reinforce and explain written policies and guidance. Live, interactive formats can facilitate deeper understanding through question-and-answer sessions and provide valuable insights into what measures work best in practice.

Reduced Employee Density and Cohort Staffing

Approaches to reducing employee density and the risk of spread of COVID-19 among employees include returning employees in stages, staggering days or shifts on-site, dividing returning employees into groups and minimizing interaction among different groups (cohort staffing), and physically separating critical workforce from the general employee population. These measures can help limit the spread of infection in the event of COVID-19 cases within the workplace. Effective cohort staffing often requires changes to current practices and can be supported through a tailored testing program, as discussed further below.

Off-Site/Off-Shift Measures

Measures implemented in the workplace are an important first step, but most employees spend between half to two-thirds of each workday outside the workplace. It is important for critical infrastructure companies to take steps to promote employee behavior off the job that reduces the risk of infection that could lead to an outbreak on the job.

Advanced Protective Measures

Critical infrastructure companies may also need to consider more advanced protective measures, especially for essential personnel. These are generally more complex to design and implement, and they present logistical, medical, and legal considerations that need to be addressed.

These measures can be divided into two categories: those implemented on-site at the workplace and those implemented off-site, including within the employee’s household. Some of these measures may call for medical consultation or supervision. Advanced measures may also implicate important legal considerations, some of which are addressed below.

Advanced measures include medical screening, workspace alterations, COVID-19 testing, preventative isolation, isolation from exposed or potentially sick family members, and on-site sequestration.

Medical Screening

A screening questionnaire to assess individual employee risk factors for exposure outside the workplace can be used as a tool to guide formation of employee cohort groups. While potentially useful, this presents legal issues that should be evaluated by labor and employment counsel.

Workspace Alterations

Changes to the physical workspace can also provide potential benefits. HVAC system upgrades such as high-efficiency particulate air (HEPA) filtration and UV-C ultraviolet light treatment systems may help reduce the likelihood of transmission within the workplace.¹² Companies also should consider using clear plastic shields or other physical barriers between employees; restricting access to spaces where mission-critical employees work; and reducing maximum-occupancy limits for shared workspaces, elevators, break rooms, and other common areas.

COVID-19 Testing

Tailored use of COVID-19 testing is an important tool for critical infrastructure workforce management. Two primary options are available to employers to screen for infected individuals: laboratory-based testing and point-of-care testing. These tests use different technologies, and they offer different advantages and disadvantages. Both are used to identify an active infection and are distinguishable from antibody tests, which can indicate a prior infection.

Laboratory-based testing uses a nasal/throat swab or saliva sample that is collected at an employer’s location, at a healthcare provider’s facility, or by telemedicine appointment and then transported to a laboratory for analysis, with results generally available within 48 to 72 hours. The laboratory-based COVID-19 test identifies genetic material of the virus using a reverse transcription polymerase chain reaction (PCR) process. Saliva-based samples can be collected remotely by a telemedicine appointment, allowing for sample collection at home. When administered properly, PCR tests are highly accurate.¹³

Point-of-care testing uses a nasal or throat swab taken by a healthcare provider at the employer’s location or at a healthcare provider’s facility using a portable diagnostic machine that provides results within 15–20 minutes. Point-of-care testing uses one of two approaches to identify COVID-19 infection: antigen testing to detect proteins on the surface of the virus, or a real-time variant of the traditional PCR process that identifies genetic material of the virus. Recent findings indicate a high level of accuracy with the latest point-of-care testing technologies.¹⁴

The best choice of a testing method depends on how testing will be integrated into a workforce management program. In some cases, more than one method may be indicated. Point-of-care tests are generally less expensive than laboratory-based PCR tests, and the rapid results offer a clear advantage, though they have a slightly lower accuracy rate.¹⁵ Laboratory tests are slightly more accurate, and the ability to provide a sample by telemedicine visit is a benefit in some circumstances, but the tests are somewhat more expensive and results generally take 48–72 hours.

The Food and Drug Administration has approved “batch testing” to allow multiple individuals to be tested together with a combined sample, thereby reducing costs, though this practice introduces an increased likelihood of false negative test results due to sample dilution. For this reason, batch testing is still in a developmental stage and is not widely used in practice.

COVID-19 testing can be incorporated into a comprehensive workforce management program in a number of ways. Some employers may elect to test all employees before they return to work in order to establish a baseline, though this provides only a single snapshot in time and does not substitute for ongoing measures. Testing can also be used in conjunction with contact tracing to facilitate case management following a known or suspected exposure, and it may facilitate more rapid return to work for individuals who have been confirmed negative.¹⁶ In addition, COVID-19 tests can be used to facilitate in-person meetings, to periodically screen mission-critical personnel required to work on-site, to check employees returning from travel or other high-risk scenarios, to conduct point-prevalence survey (random sample) testing, and in other applications that can be designed to meet individual organizational needs with the assistance of a medical advisor.¹⁷

Companies incorporating testing into their COVID-19 workforce management programs should consider contracting with a private provider offering testing to ensure consistent availability and timely results. These providers have experience working with a number of industrial applications and can tailor a testing program to a company’s specific needs and budget.

Preventative Self-Isolation

This measure ranges from relatively minor steps, such as recommending that essential employees limit activities outside their household to the extent possible, to more aggressive steps, such as recommending that essential employees self-isolate within their households depending on potential exposure risk factors present.

Isolation from Exposed or Potentially Sick Family Members

In addition to education and guidance regarding measures to minimize contact with family members who have potentially been exposed or who exhibit possible symptoms, employers should consider providing temporary alternative housing arrangements for critical employees when circumstances warrant.

On-Site Sequestration

Among advanced measures, one of the most intensive is an on-site sequestration program for mission-critical personnel. Several utilities undertook sequestration programs for control-room operator personnel at the outset of the COVID-19 outbreak.¹⁸ Such programs are inherently complex and resource intensive and need to be designed around the company’s particular circumstances, including workforce needs, head count, and the configuration of facilities.

Critical infrastructure companies, in coordination with their medical and legal advisors, will need to identify and address a wide range of potential risk factors and other issues prior to implementation of an on-site sequestration or quarantine program. They will need to consider, for example:

• selection criteria for assessing the technical, managerial, legal, and medical personnel who may participate in quarantine;
• entry and exit protocols, both for quarantine rotations and for unquarantined personnel who require access to quarantined facilities (e.g., for critical maintenance);
• lodging, meals, supplies, and receiving protocols needed in order to provide living accommodations for sequestered personnel;
• medical screenings, supervision, and support needed to conduct initial screenings prior to entry into sequestration, as well as for ongoing screenings, wellness checks, mental health assessments and support, and emergency medical care;
• ongoing preventative measures, including continued social distancing, use of masks, hygiene, cleaning, etc., as well as preparations for self-isolation within quarantine or removal from quarantine if indicated; and
• wage and hour considerations needed to assess compensation and related matters for special staffing protocols to ensure compliance with applicable laws.

Medical Input and Supervision

Many of the measures described above have medical components or significance. It is advisable for critical infrastructure companies to consult with an appropriate medical advisor to ensure that the measures are consistent with the latest medical guidance and administered or supervised by licensed medical professionals where required.

A medical advisor can provide valuable assistance in the

• initial assessment to identify available resources and determine how best to allocate those resources to serve program objectives;
• development of detailed program protocols in consultation with management and legal advisors;
• implementation of the program with adjustments as necessary in response to changes in relevant underlying facts (e.g., the availability of testing, staffing rotations, and potential exposures); and
• oversight, periodic review, and adjustment by management of program details in consultation with medical and legal advisors to ensure that the program remains consistent with current information and guidance.

Key Legal Considerations

Because critical infrastructure companies play a vitally important role in the functioning of society, they cannot cease operations during a crisis, and their mission-critical functions must continue operating even when the general public is subject to stay-at-home orders or similar restrictions. Any critical workforce management program that addresses COVID-19 should be developed with an understanding of relevant legal considerations. Many of the measures that a company may adopt alter the workplace environment or other employment conditions in ways that are legally significant. Below is representative sampling of legal considerations when developing a COVID19 workforce management program for critical infrastructure.

Labor, Employment, and Compensation

Labor, employment, and compensation is perhaps the most obvious legal subject matter area implicated by changes to the work environment implemented as part of a pandemic workforce management program. In general, there are three primary authorities that need to be considered when developing such a program.

First, laws and regulations that govern workplace health and safety, including the Occupational Health and Safety Act (OSHA) and the equivalent law in OSHA-state-plan states, apply to the working conditions on-site—thus, employers have a legal obligation to keep employees free from health and safety hazards. Moreover, OSHA requirements extend to the living conditions of any employees quarantined on-site, which means that any on-site quarantine protocol must be developed in a manner consistent with employers’ obligations under OSHA and other applicable laws and regulations.

Second, protocols need to be developed in a manner consistent with guidance provided by the Centers for Disease Control (CDC). For example, the CDC has published guidance regarding the circumstances in which a critical infrastructure worker may continue to work in the event of potential exposure to COVID-19,¹⁹ which requires, among other things, that such employees maintain social distance as work duties permit, be regularly monitored for temperature and other symptoms, and wear a mask at all times for 14 days after their last exposure. A workforce management protocol should include a mechanism that directly or indirectly incorporates such guidance, and that incorporates any changes to such guidance that the CDC and other authorities may implement over time. CDC guidance is not required by law unless it is incorporated into a state’s executive orders or similar mandates, but CDC guidance will be the standard of care in any negligence case related to COVID-19 exposure.

Third, state and local health departments have police power to enforce government quarantines, stay-at-home orders, mask orders, and the like. Workforce management protocols must therefore comply with any obligations imposed by these authorities and also should comply with nonmandatory guidance for the same reasons stated above.

In addition to applicable health and safety requirements, employers must also comply with applicable federal, state, and local law relating to employee compensation. At the federal level, the Fair Labor Standards Act includes certain obligations relating to pay for work assignments that are 24 hours or more (in addition to ordinary overtime pay obligations). The Families First Coronavirus Response Act also contains pay and job security obligations. Further, changes to the wages, benefits, and other terms and conditions of bargained employees may be subject to collective bargaining agreements and negotiations with union representatives. Finally, a number of states and localities also have passed and implemented COVID-19–related sick pay laws. Thus, the compensation payable to mission-critical employees may need to be adjusted to comply with federal law—as well as any similar or other relevant state law requirements.

Data Privacy and Security

Protocols developed to maintain critical workforce continuity in the face of COVID-19 (or other infectious diseases) may, depending on the healthcare and working arrangements included in the protocol, result in the flow of sensitive personal information and protected health information in and among employees and third parties in ways that are not typical for the company. Some of the potential measures described above, for example, involve regular temperature checks and collection of other information regarding symptoms, the results of which need to be periodically communicated either to the employer or the employer’s medical advisory team. This flow of data has privacy and cybersecurity implications. Although the company may already have systems in place to collect, transfer, communicate, process, store, and destroy sensitive or protected personal information in compliance with federal and state law and consistent with cybersecurity best practices, those existing systems might not work effectively with the efficient administration of the workforce management protocol.

Consequently, data privacy and cybersecurity procedures should be developed with an understanding of various issues associated with the potential flow of sensitive and protected personal information. What information needs to be collected? Who needs to see it and how often? How should it be transferred and stored? Are there any privacy or security risks, and, if so, how can they be mitigated? To the extent that the company’s existing information systems will not suffice to appropriately handle that information in compliance with applicable law and corporate policies, the workforce management protocol should account for the need to implement appropriate information-handling procedures.

In order to ensure that all program participants—management, mission-critical employees, medical supervisors, and others—fully understand and accept the information and privacy implications of the workforce management protocol, it is advisable to develop brief information-management procedures for program participants and to review them with each participant. Additionally, weekly reviews during the course of the program are advisable to enable appropriate adjustments to the information-handling protocols.

Insurance

Critical infrastructure companies typically maintain a variety of insurance coverages, many of which are potentially implicated by the COVID-19 pandemic and a company’s response to it. Those coverages include, among others, commercial property polices, business interruption insurance, worker’s compensation and employer’s liability policies, employment liability, director’s and officer’s liability policies, event cancellation policies, and trade disruption policies.

Insurance coverages that are most likely to be affected by COVID-19 are those with a “time element” to them: business interruption, contingent business interruption, extra expense coverage, preservation of property, and contamination/communicable disease coverage.

As part of the process of developing a workforce management protocol in response to COVID-19, companies should be aware of potential impacts to these and any other potentially relevant policies that they maintain and should take appropriate steps to maximize their rights under those policies. For example, a given insurance policy might require the policyholder to issue one or more notices in order to preserve the right to claim under the policy (e.g., a notice of circumstances). Companies should thoroughly review all existing policies to understand any applicable deadlines and notice requirements to avoid potential insurers’ defenses, and they should carefully review and consider those policies in any upcoming policy renewals. Further, new coverages or coverage features may be needed in connection with the implementation of a COVID-19 workforce management program. Such policies should be carefully reviewed to ensure adequate coverage and a full understanding of exclusions.

Conclusion

Despite significant efforts to control the spread of COVID-19 and to develop effective prevention and treatment measures, the highly contagious disease remains an ongoing global pandemic. As the outbreak continues to spread through different areas of the country, with the possibility of another surge this fall, critical infrastructure companies must manage through the crisis. The nature of the disease presents unique workforce management challenges because many critical infrastructure workers cannot work remotely and often must work in close proximity to one another. A significant threat to be managed is the potential for a group of essential workers to become infected at the same time, possibly threatening continuous operations of critical infrastructure functions.

Critical infrastructure companies and other essential businesses must therefore develop robust business continuity plans for pandemics generally and take meaningful steps to monitor and manage the risk of COVID-19 within their workforces and mitigate any internal spread of the disease, especially within critical employee populations. These measures require substantial effort because a range of management, logistical, medical, legal, and other considerations must be addressed to ensure continued operational readiness.

Endnotes

1. See Liz Sly, Simon Denyer & Ruth Eglash, Coronavirus Makes a Comeback Around the World, Wash. Post (July 29, 2020), https://www.washingtonpost.com/world/a-coronavirus-comeback-around-the-world/2020/07/28/8ddd9e64-d043-11ea-826b-cc394d824e35_story.html.

2. The Cybersecurity and Infrastructure Security Agency (CISA) has provided guidance relating to the identification and management of essential critical infrastructure workers during the COVID-19 pandemic, including a list of workers that are considered “essential.” See Cybersec. & Infrastructure Sec. Agency, Identifying Critical Infrastructure During COVID-19 (rev. May 28, 2020), https://www.cisa.gov/identifying-critical-infrastructure-during-covid-19; Advisory Memorandum from Chistopher C. Krebs, Dir., Cybersec. & Infrastructure Sec. Agency, on Identification of Essential Critical Infrastructure Workers During COVID-19 Response (May 19, 2020), https://www.cisa.gov/sites/default/files/publications/Version_3.1_CISA_Guidance_on_Essential_Critical_Infrastructure_Workers.pdf.

3. Electric utilities and grid operators, for example, “rely on a small number of highly trained operators for their control rooms”; and experienced operators “are essential for reliable grid operations,” which, in turn, are critical for keeping electricity flowing not only to the general public but also to hospitals and other critical businesses. See Thomas S. Popik et al., Preserving Operational Continuity for Electric Utility Control Rooms During the COVID-19 Pandemic (Mar. 25, 2020).

4. The official name for the virus that causes COVID-19 is “severe acute respiratory syndrome coronavirus 2,” or “SARS-CoV-2.” See Naming the Coronavirus Disease (COVID-19) and the Virus That Causes It, World Health Org. (2020), https://www.who.int/emergencies/diseases/novel-coronavirus-2019/technical-guidance/naming-the-coronavirus-disease-(covid-2019)-and-the-virus-that-causes-it.

5. See, e.g., Annelies Wilder-Smith et al., Can We Contain the COVID-19 Outbreak with the Same Measures as for SARS?, 20 Lancet (May 1, 2020), https://www.thelancet.com/journals/laninf/article/PIIS1473-3099(20)30129-8/fulltext.

6. See World Health Org., Transmission of SARS-CoV-2: Implications for Infection Prevention Precautions (July 9, 2020), https://www.who.int/news-room/commentaries/detail/transmission-of-sars-cov-2-implications-for-infection-prevention-precautions.

7. See Joshua L. Santarpia et al., Aerosol and Surface Contamination of SARS-CoV-2 Observed in Quarantine and Isolation Care, Nature Research (July 29, 2020), https://www.nature.com/articles/s41598-020-69286-3.

8. See Brianna Abbott & Jason Douglas, How Deadly Is COVID-19? Researchers Are Getting Closer to an Answer, Wall St. J. (July 21, 2020), https://www.wsj.com/articles/how-deadly-is-covid-19-researchers-are-getting-closer-to-an-answer-11595323801.

9. See Nat’l Ctr. For Health Statistics, Ctrs. for Disease Control & Prevention, Weekly Updates by Select Demographic and Geographic Characteristics (Aug. 5, 2020), https://www.cdc.gov/nchs/nvss/vsrr/covid_weekly/index.htm.

10. See, e.g., Mark W. Tenforde et al., Symptom Duration and Risk Factors for Delayed Return to Usual Health Among Outpatients with COVID-19 in a Multistate Health Care Systems Network—United States, March–June 2020, CDC Morbidity & Mortality Wkly. Rep. (July 31, 2020), https://www.cdc.gov/mmwr/volumes/69/wr/mm6930e1.htm (setting out the results of a recent study in which 35 percent of symptomatic patients reported not having returned to their usual state of health roughly two to three weeks after initial testing); see also Kara Manke, From Lung Scarring to Heart Damage , COVID-19 May Leave Lingering Marks, Berkeley News (July 8, 2020), https://news.berkeley.edu/2020/07/08/from-lung-scarring-to-heart-damage-covid-19-may-leave-lingering-marks.

11. See Cleaning and Disinfecting Your Facility, Ctrs. for Disease Control & Prevention (July 28, 2020), https://www.cdc.gov/coronavirus/2019-ncov/community/disinfecting-building-facility.html.

12. See Will Stone, Coronavirus Sparks New Interest in Using Ultraviolet Light to Disinfect Indoor Air, NPR (July 13, 2020), https://www.npr.org/sections/health-shots/2020/07/13/890387205/coronavirus-sparks-new-interest-in-using-ultraviolet-light-to-disinfect-indoor-a.

13. See How Do COVID-19 Antibody Tests Differ from Diagnostic Tests, Mayo Clinic (2020), https://www.mayoclinic.org/diseases-conditions/coronavirus/expert-answers/covid-antibody-tests/faq-20484429.

14. Id.

15. Id.

16. See Implementing Safety Practices for Critical Infrastructure Workers Who May Have Had Exposure to a Person with Suspected or Confirmed COVID-19, Ctrs. for Disease Control & Prevention (Apr. 20, 2020) [hereinafter Implementing Safety Practices], https://www.cdc.gov/coronavirus/2019-ncov/community/critical-workers/implementing-safety-practices.html.

17. Guillermo V. Sanchez et al., Initial and Repeated Point Prevalence Surveys to Inform SARS-CoV-2 Infection Prevention in 26 Skilled Nursing Facilities—Detroit, Michigan, March–May 2020, CDC Morbidity & Mortality Wkly Rep. (July 10, 2020), https://www.cdc.gov/mmwr/volumes/69/wr/mm6927e1.htm. Random sample testing of a small portion of the employee population on a regular basis can discover asymptomatic carriers, allowing them to be removed from the population and informing contract tracing initiatives.

18. Jimmy Vielkind, New York Utility Workers Live at Job Site During Coronavirus Crisis, Wall St. J. (Apr. 5, 2020), https://www.wsj.com/articles/new-york-utility-workers-live-at-job-site-during-coronavirus-crisis-11586098801.

19. See Implementing Safety Practices, supra note 16.