General Allowance for Proximity Training in Yale Research Laboratories

Background

During the pandemic, researchers in Yale laboratories must comply with a number of precautions to reduce the risk of infection. One precaution is the requirement to stay at least 6 feet from others to minimize the risk of both droplet and aerosol transmission. Other precautions are listed under Standard Precautions below.

The six-foot distancing requirement presents a particular hardship for some researchers. In a few cases, the Office of Environmental Health and Safety (EHS) has given a special allowance to laboratory researchers for work in proximity (i.e., within less than six feet of each other) under certain written conditions and with the use of additional PPE. For example, EHS has allowed short-duration proximity work in our BSL-3 laboratories for people equipped with Powered Air-Purifying Respirators (PAPRs).

EHS has provided these special allowances in recognition that limited-duration proximity work with enhanced PPE has not been associated with disease transmission in the healthcare environment (which is characterized by good ventilation). Since last summer, EHS has granted allowances to researchers and other groups who need to do short duration (e.g., multiple periods per day of less than 30 minutes) proximity work in well-ventilated areas with enhanced PPE and according to approved procedures. Non‑research groups include Facilities, the Museums, and the Institute for the Preservation of Cultural Heritage. The necessary proximity work is commonly a two-person manual job.

The six-foot distancing requirement poses a significant barrier to laboratory training, which often requires demonstrating manual manipulation of samples and instruments, and coaching the trainee on their manual techniques. New and inexperienced laboratory staff in particular need to be closely supervised to ensure that expensive and sensitive equipment is used properly and is operated safely, and to prevent accidents and injuries. In many cases, the period of training is prolonged into weeks and months, as the trainee gains proficiency and expands their skills. Other examples include demonstrating laboratory techniques inside a biosafety cabinet or fume hood (i.e., animal inoculations or surgeries, chemical transfer processes in inert atmospheres, etc.).

With respect to this general allowance, note that the laboratory environment is characterized by excellent ventilation. In the past year, Yale has observed less than ten infections among laboratory researchers. We understand that transmission from one lab person to another has not been suspected. Our peer universities report similar findings.

Applicability of This General Allowance

This general allowance is to allow proximity training for laboratory researchers under specified conditions, after alternative training methods have been exhausted. Alternatives and the specified conditions are described below. If the following conditions are met, people may conduct proximity training in laboratories without receiving permission from EHS.

EHS approval is required for any proximity work that does not fall under this general allowance for training in laboratories. Requests will be evaluated and a special allowance may be approved on a case-by-case evaluation.

At this time, an individual’s vaccination status is not a criterion for granting an allowance for proximity work.

Alternatives to Proximity Work

Alternatives should be explored prior to engaging in proximity work. These include modifying procedures or work practices. Consider creative alternatives such as the use of mechanical device or the use of on-line tutorials. Zoom or Facetime can be used for remote instruction.

Required Conditions for Proximity Training in Labs

Alternatives to proximity work must be exhausted. See below.

All standard COVID precautions, listed below, must be utilized.

Prior to the initial training session, the risks of proximity work should be discussed among all participants. For example, participants should understand that:

  • Asymptomatic people with COVID-19 can transmit the disease.
  • One individual can transmit the disease to many others.
  • The risk of droplet and aerosol transmission increases greatly within six feet.
  • The risk of aerosol transmission also increases with exertion.

Participants who have questions about the risk of proximity work should consult their EHS Safety Advisor.

The following additional limitations and requirements apply:

  • The duration of each session should be as short as possible and may not exceed three hours.
  • The total duration of proximity work in a day should be as short as possible and may not exceed six hours.
  • Groups in proximity may not exceed four persons. However, the number of individuals involved in proximity work shall be minimized as much as feasible.[1]
  • Consult with EHS for any training that involves significant exertion.
  • In a laboratory room, only one group may perform proximity training at a time.
  • Ventilation in the area must meet or exceed the requirements for occupancy Level C in the re-opening guidance.[2]
  • ASTM-rated or KN95 masks must be worn as a face covering. ASTM-rated masks are available via the Yale COVID stock room in SciQuest. KN95 masks are available via YPPS.
  • A face shield must be added over the face covering. These are available via the Yale COVID stock room in SciQuest. Goggles should be used instead of face shields when handling corrosive liquids.
  • When the work allows, staff shall position themselves to increase distance between each other as much as possible.
  • After the task is complete:
    • Remove and disinfect the face shield. Face shields can be reused if undamaged after disinfection using >70% Ethanol, 0.5% Hydrogen Peroxide solution, or Oxivir disinfecting wipes.
    • clean hands using hand sanitizer and/or soap and water for 20 seconds.
    • Remove and discard the ASTM-rated or KN95 mask and replace with a surgical mask or cloth face covering, as appropriate.
  • A record of this proximity work and the individuals involved shall be maintained by the research group to facilitate possible future contact tracing.

Standard COVID Precautions

All proximity work shall be done while observing all of Yale’s other standard research safety and COVID health and safety precautions. These include:

  • All work shall be performed in accordance with the research registration and associated safety plans submitted by the Principal Investigator and approved by the Department, Dean, Provost’s Office, and applicable safety committee.
  • Individuals shall monitor symptoms daily (daily health check) and not come to work if sick.
  • Proximity workers are encouraged to participate in Yale’s weekly testing program.
  • Proximity workers must take Yale’s COVID Health and Safety training. Ensure that personnel understand the risk of working in close proximity.
  • Work areas that do not have a handwashing sink with soap and paper towels shall be equipped with hand sanitizer.

[1] Consider working in assigned pairs to reduce the risk of many exposures from an infectious individual. Pairs can be scheduled to consistently work as a pair and not intermingled with individuals from another pair of proximity workers.

[2] Consult the Facilities Superintendent for your building to determine if laboratory ventilation meets this requirement. Contact your EHS Safety Advisor if you have any questions.