PMAA Guidance to Municipal Authorities During COVID-19 Pandemic


As the COVID-19 (coronavirus) pandemic develops, the health and safety of municipal authority customers and their employees is PMAA’s top priority as they provide essential services like drinking water, wastewater, trash disposal and other critical community services to homes and businesses across the Commonwealth.
 

Though we have suspended office hours for the time being, PMAA staff is working remotely and will continue to provide information and resources to our members.

We encourage you to refer to this page for up-to-date information and to contact us by visiting our staff listing page or by calling 717-737-7655. We will respond to all phone calls and emails as quickly as possible.
 

In an effort to mitigate impacts of COVID-19, PMAA encourages municipal authorities to initiate continuity of operations and preparedness response plans, as well as enact measures to assist anticipated economic impact on customers, including but not limited to the below guidance:

• Placing moratorium on shutoffs
• Restoring service to previously shutoff customers
• Suspending or waiving late charges or fees
• Instituting payment assistance plans

PMAA continues to monitor and evaluate updates from and consult daily with state and federal agencies, as well as other appropriate organizations, and will provide additional guidance, as necessary, to support municipal authorities, their employees and the communities they serve.

Thank you for your dedication in keeping your customers, employees and communities safe while maintaining reliable service during this critical time.
 

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Plan, Prepare, and Respond
The CDC has issued guidance on resuming operations for businesses and employees.


Free Cloth Face Masks Available for PA Water/Wastewater Sector
FEMA is providing washable, reusable free cloth face masks to Water & Wastewater purveyors in Pennsylvania and distributed by the PaWARN network. Read more for information and request form.


Webinar Recording: Impact of COVID-19 on Municipal Authorities & Considerations on How to Move ForwardFinancial_COVID
The impact of COVID-19 has caused a concern among municipal authorities regarding anticipated loss of revenues  associated with non-consumption of services. Consequently, many PMAA members have reached out asking what options they have at their disposal should they require financial relief.

In this webinar, we discuss details on a few options authorities have to address COVID-19-related cash flow problems as the economic picture continues to evolve.


PMAA Supports Passage of Infrastructure Bill
PMAA recently sent a letter to Senators Casey and Toomey regarding the association supporting the passage of an infrastructure bill. Such stimulus would provide financial assistance for authorities to address aging infrastructure systems throughout the Commonwealth.

PMAA strongly believes that an infrastructure package consisting of grants will enable its members to undertake necessary system repairs. It would be difficult for the cost of such repairs to be borne by our members’ ratepayers, whose economic situation may not see relief at any time in the foreseeable future.


New Workplace Requirements Ordered by the PA Secretary of Health
The new order identifies protection measures for critical workers who are employed at businesses that are authorized to maintain in-person operations during the COVID-19 disaster emergency. These new measures go into effect on Sunday, April 19th, at 8:00 p.m. Please refer to the order for detailed information.


DEP COVID-19 Update
DEP posted guidance on its website outlining a series of actions they are taking during the COVID-19 pandemic related to inspections, permit holders, water and wastewater operator certification exams and other pertinent information. Further details can be found here: DEP COVID-19 Update


Physical Presence for Attendance at Authority Meetings
With concerns regarding Coronavirus, authorities are asking for clarification on board meeting quorums for conducting business. PMAA Solicitor, Michael Witherel has provided the following opinion regarding quorums specifically for conference call attendance. Read more>>


The Families First Coronavirus Response Act

  • The Families First Coronavirus Response Act (FFCRA) passed Congress on March 18, 2020 which amends the Federal Family Leave Act (FMLA). Prior to this new law, the FMLA did not apply to employers with fewer than 50 employees. It now includes employers with 1 to 500 employees and they must provide up to 12 weeks emergency paid sick leave and family medical leave.It takes effect from April 1 to December 30, 2020. Click here for the fact sheet on the new law.

  • With the recent publication of the regulations in the Federal Register implementing the law, more details on types of employers and their employees exempt from these requirements are provided. Public works personnel are within the definition of emergency responders all of whom may be excluded from Paid Sick Leave or Expanded Family and Medical Leave by their Employer under the FFCRA.

  • Based upon this language, water and sewer authorities are permitted to claim exemption from the requirements of the FFCRA. Please consult with your solicitor on this possible exemption. Click here for the regulation and refer to section 826.25 (c)(2)(i) starting on page 19351 and continuing on page 19352.


The Sunshine Act and COVID-19: The Office of Open Records has issued an advisory regarding Pennsylvania’s Sunshine Act and the Coronavirus (COVID-19)


The Right-to-Know Law and COVID-19: The Office of Open Records has issued an advisory regarding Pennsylvania’s RTKL and the Coronavirus (COVID-19)


Commonwealth of Pennsylvania Proclamation of Disaster Emergency
On March 6, 2020, Governor Wolf signed an emergency disaster declaration to provide increased support to the Commonwealth, counties, municipalities, and other entities involved in the response to the COVID-19 virus.

PMAA Solicitor, Michael Witherel believes this emergency disaster declaration is sufficient for any municipal authority as to its general overall operations. If you believe that your authority has unique or particular situations beyond what is described in the Governor’s proclamation, check with your solicitor if it is necessary for you to adopt your own emergency declaration.
 

FEMA Intergovernmental Affairs ADVISORY
On March 13, 2020, the President declared the ongoing Coronavirus Disease 2019 (COVID-19) pandemic of sufficient severity and magnitude to warrant an emergency declaration for all states, tribes, territories, and the District of Columbia pursuant to section 501 (b) of the Robert T. Stafford Disaster Relief and Emergency Assistance Act, 42 U.S.C. 5121-5207 (the “Stafford Act”). State, territorial, tribal, and local government entities and certain private non-profit organizations are eligible to apply for Public Assistance. See Fact Sheet for further information.


Water Treatment Practices Effective Against COVID-19
The World Health Organization states that current water treatment practices are effective against COVID-19. For additional information, click here.


Statement from the United States Environmental Protection Agency (EPA):
Coronavirus and Drinking Water and Wastewater


COVID-19 Related Phone Scams and Phishing Attacks: The CDC provides guidance on protecting yourself from falling victim to these scams.

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Resources

Model Coronavirus Response Plan: Coronavirus response plan and sample FAQ for employers created by Cozen O'Connor

Lehigh County Authority Employee Wellness ‐ COVID‐19 Decision Trees: What steps are you taking with your employees when they feel sick or know someone who has been in contact with the virus?
*This document of scenarios is meant as a guide only and should not replace your own review of CDC recommendations*

FEMA Intergovernmental Affairs Advisory: Coronavirus (COVID-19) Pandemic - Eligible Emergency Protective Measures

Pennsylvania Department of Community and Economic Development (DCED): Local Government COVID-19 FAQs

Pennsylvania Office of the Governor: Daily updates from Governor Tom Wolf in response to COVID-19 in Pennsylvania

Pennsylvania Department of Health: Up to date information on the current situation within the Commonwealth

Pennsylvania Emergency Management Agency (PEMA): Important alert details regarding preparation and response to emergencies within Pennsylvania

Centers for Disease Control and Prevention: CDC’s resource page includes what you should know about the virus, how to protect yourself and the latest updates from around the world.

World Health Organization (WHO): Coronavirus disease (COVID-19) outbreak daily press briefings.

Coronavirus Graphics: Help share and spread the word with these "post-ready" images for your social media network.

National Institutes of Health (NIH): Get the latest public health information from CDC and the latest research news from NIH.

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COVID-19 Practices & Policies

PMAA has developed a guide of plans and policies that may help answer questions you have during these uncertain times. This information, shared by PMAA members, is meant to be a guide only and will be updated as this situation evolves.

Have you made a decision on how to classify time-off for “self-quarantine”?  If your benefits include sick leave, would self-quarantine be considered sick or would you require other time to be taken (vacation, leave without pay, etc)?

At this time we are requiring employees who wish to stay home voluntarily to use PTO.  If they do not have sufficient PTO accrued, we will advance additional PTO paid leave, and they can catch up later as their time accrues.

We are now contemplating, but have not yet decided, to grant an additional 40 hours PTO to all employees.

If we send our people home, it will be mandatory leave and paid time, (similar to an office closure for snow) without any deduction of PTO  

If someone is under “self-quarantine” because they have symptoms, they will use their sick time first (in our situation, everyone has an abundance of time accumulated).

No in-home visits (meter replacements, etc.) until (at least) May, except in case of an emergency. System operation remains as normal.

We are paying everyone who is sent home as normal.

Workers who are home being paid were told that they aren’t to go shopping and socializing during work time and were asked to stay home unless absolutely necessary.

Sick or excused time may be used for any of the following situations:

  • If you have been diagnosed with COVID-19

  • If you have been quarantined at home at the instruction of a health-care provider to prevent the spread of COVID-19

  • If you are caring for another member of your household who has COVID-19

  • If you are caring for someone in your home who cannot take care of themselves as a result of a school closure or other COVID-19 related closure.

Emergency Paid Leave Policy – If you currently have a total of less than 10 days of time off available, or you run out of paid time off during this public health emergency – we will offer a one-time emergency paid leave of up to 10 additional days.
 

Have you instituted any kind of “shifting” to avoid the possibility that entire work teams will be quarantined? What about the separation of shifts to avoid “cross-contamination” of shifts?

We have moved some staff to our other office, reassigned some to our training center which is about 4 blocks away, and authorized departmental managers to implement split shifts.  

For this period of “social distancing” that we are currently in, we split all staff into two teams. They rotate by week – Team 1 in week one, team 2, week two. During this time they are paid to be at home but we strongly stressed that they are technically “working from home” even if they don’t have work to do, their job is to social distance – they may not attend gatherings or have social company into their home (at least during working hours), they are to limit their errands to critical only and they are to be available on immediate notice should we need to call them back in. They are NOT to interact with members of the other team socially during this period.

We acted to split distribution, collections, customer service and other, smaller teams into A-B-C teams or A & B teams. For example, customer service persons will work one week on, two weeks off. Those sent home for recent travel concerns to hotspot areas are on the C team, so they are starting with two weeks off.

The supervisors were permitted to work with smaller teams to determine schedules, but are also alternating in most instances where there are employees possibly in contact with one another. The idea is to reduce the concentration of employees interacting by spreading them out, and then keeping a firm separation between crews to maintain our core capabilities in case an employee or family member tests positive.

We are able in many cases to get employees on reduced crews their own trucks, so no one rides together.

Meters are being read as normal, unless the meter is in the home. Service technicians are halting in-home work and concentrating on meter pits and other outside work. Locators are solitary and working as normal.

STAFFING & SCHEDULING CHANGES - If you have a compromised immune system or other underlying health condition that increases your risks associated with COVID-19, please speak with your doctor as soon as possible and advise your manager of your doctor’s recommendation so that alternative work arrangements can be made.

If you have child-care needs that might prevent you from working your normal work hours, please speak with your supervisor about flexible work hours. We will be happy to have you work different hours if possible to help you reduce your time away from work, but still take care of your family’s needs.

We will be working directly with managers to establish alternative work shifts for each Operations department. These alternative work shifts will go into effect as soon as possible and will be designed to keep groups of employees separated from one another to prevent the spread of the virus.

Until further notice, all non-essential projects or programs that require third party vendor entry into one of our facilities will be modified to reduce interaction with authority employees, or will be suspended. Note: Any project or vendor visit that is required to keep an authority facility operational or required to continue meeting regulatory requirements or deadlines would be considered “essential.” Other projects or vendor visits that can be delayed should be delayed.

If you must meet with a vendor and can arrange to meet them outdoors or outside of our facility, that is acceptable. Outdoor construction projects are considered low-risk activities and can continue as normal.

 

How are you handling customer service?  Do you still allow walk-ins?  If so have you instituted separation or something else?

Our business offices are open for emergencies and routine services, but we have locked the front doors, asking customers to make payments on line, ACH, etc. We have suspended late charges, shut offs, etc. We have also cancelled all non-emergency home visits, such as routine meter or MXU change outs, meter readings, etc.

We are located in our Township Building. The Township has shut the building down to customers. They may call or email and we’ve put a mailbox outside for any payments to be dropped off.

Office closed to public. All business will be done by phone, email or fax. No customer walk-ins.

We are installing some sample stations that we have in stock to eliminate those interactions with the public at those stations.

All AUTHORITY buildings will be locked 24 hours a day until further notice. If you have visitors coming by appointment to complete essential work, please meet them at the door. Please consider conducting meetings by phone or other electronic means instead.


How are you handling the reading of meters after the governor’s order?

We are reading external meters and radio meters, and estimating those inside homes.

Our current approach is to continue reading meters that can be read by radio/drive-by. That may change if we end up with more strict travel/documentation requirements for our workers.

We’re sewer with mostly flat rate customers, but we do bill commercial and read water meters, still doing that through remote and/or keeping proper distance.


Implementation of “time off” practices – in other words, sending individuals or teams home with pay?

We have created a full-pay platoon system for distribution and customer service. We have three teams in those business units. The idea is to increase distance between people by thinning the group, and preserve function if someone in one group tests positive – then we’ll have the other groups still going. The one week on, two weeks off system also creates a kind of quarantine for those who are off.

  • Platoon A is working this week.

  • Platoon B will work next week.

  • Platoon C will work in two weeks.

Everyone is fully paid. This creates more physical separation while working, and the firm division keeps whole business units from being quarantined at once.

Right now we are looking at paying everyone who is healthy thru the entire situation. The thinking is that even if a full time staff member is off (not at work) because of a staff “thinning” and/or schedule rotations to minimize exposure, they would all be “on-call” to fill in if another staff person falls into one of the 4 situations (sick, quarantined, caring of another patient, or care for children at home).

If a staff member has to take leave (unavailable to work) due to one of the four categories, we are working on a more liberal leave policy based on the new FMLA and EPSLA guidelines.

If we assign you to stay home in order to reduce exposure, we still pay you but consider you “on call” and have tried to assign some administrative work there – even if it is just getting pricing quotes on things, securing contracts for maintenance work, reviewing pump station manifests, etc. Currently, we are rotating teams one week on one week off and disinfecting on weekends in between.

Currently, our plant employees are rotating teams one week on one week off and disinfecting in between, our outside crew is also rotating one week on and one week off, no dye tests inside anyone’s house, only roof drains at this time. And if you are assigned to stay home, in order to reduce exposure, we will still pay you and you are considered “on call”.


We started a daily “wellness check” to monitor trends for employee illness and/or absence due to related COVID-19 in a more programmatic way. We are starting to get a lot of calls and questions about scenarios such as an employee’s spouse works in healthcare and may have been exposed, so should the employee stay at home or come to work?

In this scenario: the employee’s spouse (or any other person sharing the same living space as employee) is a health care worker that may come in contact with COVID-19 patients and the health care worker is not exhibiting symptoms nor is the employee. The health care worker is not under any specific guidance requiring them, or others they contact, to quarantine. Under these conditions and until scenario changes, the employee is able to work. Should scenario change the employee should notify their supervisor and proper guidance will be issued.

Employees that have called off sick and have not exhibited these symptoms (fever of 100° or greater, persistent dry cough, shortness of breath) are presumed safe to return to work.  When an employee reports off as sick, the supervisor can ask if they are exhibiting any symptoms or if they have traveled or been in contact with someone who has tested positive. l. If employees have symptoms they should consult with their primary care physician. It is recommended to call first, not just show up. We will make a decision based on the opinion of the consulting physician.  

Confirmed Cases: Quarantine for a minimum seven (7) days with a minimum three (3) days in a row of no symptoms then presumed safe

Contact with Confirmed Case: Quarantine for fourteen (14) days

Any confirmed cases will result in county or state health department taking jurisdiction and leading the investigation.