1648.15  RECORDKEEPING FOR HEALTHCARE SETTINGS
          	IN SCHOOL BUILDINGS – COVID-19
The Board of Education is committed to providing a safe and healthy workplace for all employees.  The school district shall maintain its records in accordance with Occupational Safety and Health Act of 1970 (OSHA) COVID-19 Emergency Temporary Standard (ETS) published on June 21, 2021 as adopted by the Public Employees Occupational Safety and Health (PEOSH), the agency with jurisdiction over public employers in New Jersey.  The provisions of the ETS have expired and are no longer in effect for school districts except for the provisions addressing recordkeeping, outlined in 29 CFR §1910.502(q).  The ETS and this Policy are only applicable for employees working in the school nurse’s office and any adjoining clinical areas in the school building.   
For the purpose of this Policy, “employee” means any district employee or contracted service provider working in a healthcare setting where people with suspected or confirmed COVID-19 are reasonably expected to be present. Therefore, the provisions of the ETS and this Policy only apply to employees or contracted service providers working in a nurse’s office or any adjoining clinical areas. 
For the purpose of this Policy, “healthcare setting” means all settings in the school district where any employee or contracted service provider provides healthcare services or healthcare support services.  Where a healthcare setting is embedded within a non-healthcare setting (i.e. school nurse’s office and any adjoining clinical areas in a school building), the ETS and this Policy only apply to the embedded healthcare setting and not to the remainder of a school building. 
The school district will retain all versions of Policy 1648.14 – Safety Plan for Healthcare Settings in School Buildings, to comply with the ETS while the ETS remains in effect, even after Policy 1648.14 has been abolished.  
The school district will establish and maintain a COVID-19 log to record each instance in which an employee is COVID-19 positive, regardless of whether the instance is connected to exposure to COVID-19 at work.  The COVID-19 log will contain, for each instance, the employee’s name, one form of contact information, occupation, location where the employee worked, the date of the employee’s last day in the healthcare setting, the date of the positive test for, or diagnosis of, COVID-19, and the date the employee first had one or more COVID-19 symptoms, if any were experienced. 
The school district will record the information in the COVID-19 log within twenty-four hours of learning the employee is COVID-19 positive.  The school district will maintain the COVID-19 log as a confidential medical record and will not disclose it except as required by the ETS or other Federal law.  The school district will maintain and preserve the COVID-19 log while the ETS remains in effect. 
By the end of the next business day after a request, the school district will provide for examination and copying:  all versions of Policy 1648.14; the individual COVID-19 log entry for a particular employee to that employee and to anyone having written authorized consent of that employee; and a version of the COVID-19 log that removes the names of employees, contact information, and occupation, and only includes, for each employee in the  COVID-19 log, the location where the employee worked, the last day that the employee was in the healthcare setting before removal, the date of that employee’s positive test for, or diagnosis of, COVID-19, and the date the employee first had one or more COVID-19 symptoms, if any were experienced, to all employees.

29 CFR §1910.502(q)

Adopted:  August 23, 2022