COVID-19 Workplace Safety Plan

January 22, 2024

Table of Contents

I. Purpose

II. EEOC COVID-19 Coordination Team

III. Communications with EEOC Employees, On-Site Contractors, Visitors, and Service Recipients

IV. COVID-19 Community Levels

V. Vaccination

A. Nationwide Injunctions

B. Leave to Obtain Vaccination

C. Leave to Accompany a Family Member to Obtain Vaccination

D. Leave for Post-Vaccination Recovery

E. Pausing Collection of Vaccination Information

F. Vaccination Information Systems and Records

VI. Mask-Wearing

A. Mask-Wearing When COVID-19 Community Level is HIGH

B. Optional Mask-Wearing When COVID-19 Community Levels is LOW or MEDIUM

C. Types of High-Quality Mask and Respirators

D. Protocols When Mask-Wearing is Required

VII. Screening Testing

VIII. Symptom Screening

A. No Entry for Individuals with COVID-19 Symptoms or Suspected COVID-19

B. Symptom Screening Before Entering Federal Facilities

C. Developing COVID-19 Symptoms While Onsite

IX. Post-Exposure Precautions

A. Instructions to Those Known to Have Been Exposed

B. Testing for Those Known to Have Been Exposed

C. COVID-19 and Federal Workers’ Compensation

X. Isolation and Post Isolation Precautions

A. Isolation for Individuals with Probable or Confirmed COVID-19

B. Returning to Working Onsite After Isolation

C. Post-Isolation Precautions

XI. Official Travel

A. Instructions for Traveling Individuals

B. Travel for Individuals with Known Exposure

C. Travel for Individuals with COVID-19 Symptoms or a Positive COVID-19 Test

XII. Meetings, Events, and Conferences

XIII. Hygiene

XIV. Ventilation and Air Filtration

XV. Collective Bargaining Obligations

I.   Purpose

The purpose of this document is to set forth the U.S. Equal Employment Opportunity Commission’s (the EEOC) COVID-19 Workplace Safety Plan (Safety Plan) for employees, onsite contractors, individuals receiving services, and visitors. This Safety Plan is updated to include Model Agency COVID-19 Safety Principles (September 15, 2022). These updated model COVID-19 safety principles set forth the protocols agencies must follow to comply with their obligations under section 2(a) of E.O. 13991, as well as protocols agencies need to follow to implement Safer Federal Workforce Task Force (Task Force) guidance issued pursuant to E.O. 13991. The Task Force will reassess the model safety principles over time, as conditions warrant and as the Centers for Disease Control and Prevention (CDC) guidelines are updated.

Since the start of the pandemic, the EEOC has continued to work to balance delivery of our mission with adapting to the evolving challenges that COVID-19 presents to our workforce and the public. The health and safety of the EEOC workforce, its contractors, and the public we serve are paramount. The agency will follow the health and safety protocols and procedures outlined in this Safety Plan. This is a living document dependent on federal, state, and local government guidance about public health conditions and may be updated as circumstances require. 

II.   EEOC COVID-19 Coordination Team

The EEOC has established a COVID-19 Coordination Team. Currently, the members are: 

• Chief Operating Officer
• Acting Deputy Chief Operating Officer
• Chief of Staff, Office of the Chair
• General Counsel, Acting General Counsel or designee
• Legal Counsel or designee
• Associate Director, Office of Communications & Legislative Affairs or designee
• Acting Director, Office of Field Programs
• Chief Human Capital Officer
• Deputy Chief Human Capital Officer
• Chief Information Officer
• Chief Financial Officer
• Director, Security and Safety Division

Because the EEOC does not have a public health expert on staff, the EEOC will consult with a delegate provided by the CDC through the Task Force when necessary.

The COVID-19 Coordination Team will meet regularly to review compliance with the agency’s Safety Plan, protocols, and policies; consider potential revisions to the Safety Plan pursuant to guidance from the Task Force and current CDC guidelines; and evaluate any other operational needs related to COVID-19 workplace safety. The Team will consult with the General Services Administration (GSA), the Office of Personnel Management (OPM), and the Office of Management and Budget (OMB), as appropriate. For privately owned and federally leased space, the COVID-19 Coordination Team will coordinate with GSA, building management, facility security and safety committees, and/or facility pandemic coordinators.

The COVID Coordination Team is responsible for keeping the Chair informed regarding conclusions and recommendations from the Team.

III.     Communications with EEOC Employees, On-Site Contractors, Visitors, and Service Recipients

1. General. The EEOC communicates with, educates, and informs employees, contractors, visitors, and service recipients in a variety of ways. The EEOC will be transparent in communicating information to the workforce, as relevant and appropriate, consistent with local and federal privacy and confidentiality laws and regulations.
   
   The COVID-19 Coordination Team, in coordination with the Office of the Chair, has the responsibility to make disclosures to local public health officials as required or necessary to provide for the public health and safety of federal employees and contractors in accordance with local public health mandates.
2. Communications with Employees and On-Site Contractors. The EEOC’s internal email is the primary tool for communicating internal messages to staff. There is a COVID-19 dedicated SharePoint site accessible to all employees and contractors and all-staff COVID-19 Update emails.
3. Communications with Visitors and Service Recipients. The EEOC’s primary means of communicating safety plans and protocols with individual visitors and service recipients is through its public facing website, www.eeoc.gov and email. Additionally, the EEOC will also post signage and key messages at entrances, doors, reception desks, common areas, and conference rooms.

IV.   COVID-19 Community Levels

The CDC designates COVID-19 Community Levels, which measure the impact of COVID-19 illness on health and healthcare systems and inform the appropriate prevention strategies to utilize at a given time. The CDC provides county-level data showing the COVID-19 Community Levels in the United States. The EEOC will utilize COVID-19 Community Level data to determine prevention strategies recommended for each county in which an EEOC office is located. The EEOC will review the COVID-19 Community Level for each of our locations on a weekly basis to determine any changes that should be made to agency COVID-19 workplace safety protocols for the upcoming week. The chart below sets out the new guidance for each of the COVID-19 Community Levels.

When COVID-19 Community Levels are HIGH, EEOC may consider establishing occupancy limits for indoor common areas and meeting rooms.

FAQs regarding local conditions can be found on SaferFederalWorkforce.gov here.

See Updated Implementation Guidance on COVID-19 Community Levels | Safer Federal Workforce Task Force (updated August 17, 2022)

V.   Vaccination

1. Nationwide Injunctions. To ensure compliance with an applicable nationwide preliminary injunction, which may be supplemented, modified, or vacated, depending on the course of ongoing litigation, EEOC will take no action to implement or enforce the COVID-19 vaccination requirement pursuant to Executive Order 14043 on Requiring Coronavirus Disease 2019 Vaccination for Federal Employees. Any aspects of this Safety Plan related to the vaccination requirement pursuant to E.O. 14043 are not in effect and will not be implemented or enforced by the EEOC while the injunction is in place.
   
   To ensure compliance with an applicable nationwide injunction, EEOC will take no action to implement or enforce E.O. 14042 on Ensuring Adequate COVID Safety Protocols for Federal Contractors. For existing contracts or contract-like instruments that contain a clause implementing requirements of E.O. 14042, EEOC will take no action to enforce the clause, absent further written notice from EEOC.
2. Leave to Obtain Vaccination. Consistent with Task Force guidance, employees who seek any non-required dose of FDA-authorized COVID-19 vaccine during work hours should be granted administrative leave and not use duty time. This includes employees who are not required to be vaccinated due to the nationwide preliminary injunction on implementation and enforcement of E.O. 14043.
   1. The administrative leave will cover the time it takes to travel to the vaccination site, receive the vaccine dose, and return to work. If an employee needs to spend less time getting the vaccine dose, only the needed amount of administrative leave should be granted. Employees should obtain advance approval from their supervisor before using administrative leave for purposes of obtaining a COVID-19 vaccine dose.
   2. Employees may not be credited with administrative leave or overtime for time spent getting a vaccine dose outside their tour of duty.
3. Leave to Accompany a Family Member to Obtain Vaccination. Consistent with Task Force guidance, the EEOC will provide employees with administrative leave to accompany a family member being vaccinated. For this purpose, a “family member” is an individual who meets the definition of that term in OPM leave regulations (see 5 CFR 630.201).
4. Leave for Post-Vaccination Recovery. Consistent with Task Force guidance, EEOC will provide employees with administrative leave to address any side effects related to a recent vaccination.
   
   See FAQs regarding vaccination-related leave for more information about the use of duty time and administrative leave, including how much duty time or administrative leave agencies should provide for the above circumstances.
5. Pausing Collection of Vaccination Information. Consistent with CDC guidance, the EEOC has paused efforts to require, request, or collect vaccination status information from any individual—including employees, contractors, visitors to EEOC facilities, or in-person attendees at agency-hosted meetings, events, and conferences—for the purposes of implementing agency COVID-19 workplace safety protocols.
6. Vaccination Information Systems and Records. The EEOC will preserve its vaccination information collection systems and the information collected to date from employees in accordance with the Federal Records Act and other records requirements. Further, it is important to preserve this information as COVID-19 workplace safety protocols may change in the future, or collection of this information from Federal employees may need to resume.
   
   All medical information collected from individuals, including vaccination information, test results, and any other information obtained as a result of testing or symptom monitoring, will be treated in accordance with applicable laws and policies on confidentiality and privacy, and will be accessible only to those with a need to know.Retention of employee information conforms with the confidentiality requirements of Section 501 of the Rehabilitation Act.
   
   See Task Force FAQs on vaccination documentation and information for more information about how agencies should maintain any documentation provided by employees regarding vaccination.

VI.   Mask-Wearing

1. Mask-Wearing When COVID-19 Community Level is HIGH. When the COVID-19 Community Level is HIGH in a county where an EEOC facility is located, pursuant to E.O. 13991 and consistent with CDC guidance, the EEOC requires individuals—including employees, contractors, and visitors—who are 2 years or older, to wear a high-quality mask indoors in the facility, regardless of their vaccination status. This includes when federal employees are interacting with members of the public as part of their official responsibilities.
2. Optional Mask-Wearing When COVID-19 Community Level is LOW or MEDIUM. When the COVID-19 Community Level is LOW or MEDIUM in a county where an EEOC facility is located, in most settings, consistent with Task Force guidance, mask-wearing is optional, and the agency should not require individuals to wear a mask. If an EEOC staff member visits a facility that maintains different protocols, they may be required to wear a mask.
3. Types of High-Quality Mask and Respirators. When COVID-19 Community Levels are HIGH, and for post-exposure and post-isolation precautions, individuals are required to wear a “high quality” mask or respirator. Consistent with Task Force guidance, high-quality masks or respirators include respirators that meet U.S. or international standards (e.g., N95, KN95, KF94), masks that meet a standard (e.g., ASTM), or “procedure” or “surgical”-style masks. If high-quality masks are not required, the EEOC will not limit the types of masks that can be worn by individuals in EEOC facilities. Nothing in CDC or Task Force guidance precludes an individual from wearing a mask if the individual so chooses when the COVID-19 Community Level is LOW or MEDIUM.
   
   The agency will notify employees about the community levels in each office each Friday through email. Employees should refer to the chart provided in the email for masking requirements under each community level. In addition, offices will maintain signage indicating the community level as of the most recent posting.
4. Protocols When Mask-Wearing is Required. When individuals are required to wear a high-quality mask or respirator (e.g., N95, KN95, KF94) in EEOC facilities, agency mask-wearing protocols should reflect that:
   1. Masks and respirators should be well-fitting and worn consistently and correctly (over mouth and nose).
   2. Masks or respirators should be worn in any common areas or shared workspaces (including open floorplan office space, cubicle embankments, and conference rooms).
   3. Individuals do not need to wear masks or respirators when outdoors.
   4. Limited exceptions to mask-wearing include, when an individual is alone in an office with floor to ceiling walls and a closed door or for a limited time when an individual is eating or drinking and maintaining distance from others.
   5. Masked individuals may be asked to lower their masks briefly for identification purposes in compliance with agency safety and security requirements.

VII.   Screening Testing

Consistent with Task Force guidance, the EEOC will not implement COVID-19 serial or point-in-time screening testing.

VIII.   Symptom Screening

1. No Entry for Individuals with COVID-19 Symptoms or Suspected COVID-19. If an EEOC employee, contractor, or visitor, including service recipients, has a fever or chills, or if they have other new or unexplained symptoms consistent with COVID-19 such as new or unexplained onset of cough, shortness of breath, or difficulty breathing, new or unexplained loss of taste or smell, or new or unexplained muscle aches, they should not enter an EEOC workplace. If an individual suspects that they have COVID-19, but they do not have test results yet, they should not enter an EEOC workplace and should get tested for COVID-19 if they have not already done so.
2. Symptom Screening Before Entering EEOC Facilities. Consistent with Task Force guidance, the EEOC requires that all employees and contractors working onsite at an agency workplace and all visitors, including service recipients, to EEOC facilities complete symptom screening before entering an EEOC facility. The EEOC will also require that all staff complete symptom screening prior to interacting with members of the public in person as part of their official responsibilities. Symptom screening can be self-conducted using the tool developed by the CDC and does not need to be verified by agency personnel.The EEOC will ensure that appropriate signage is posted at the entrances to EEOC office space.
3. Developing COVID-19 Symptoms While Onsite. Any individual who develops fever, chills, or other new or unexplained symptoms consistent with COVID-19, or who tests positive for COVID-19, while onsite during the workday must immediately wear a high-quality mask or respirator (such as an N95), notify their supervisor, and promptly leave the workplace.
   
   See FAQs regarding symptom screening on SaferFederalWorkforce.gov here.

IX.   Post-Exposure Precautions

1. Instructions to Those Known to Have Been Exposed. Consistent with CDC guidance on post-exposure precautions, the EEOC will instruct individuals who are known to have been exposed to someone with COVID-19, regardless of their vaccination status, to:
   1. Wear a high-quality mask or respirator (such as an N95) while indoors at an agency workplace or interacting with members of the public in person as part of their official responsibilities as soon as possible after notification of exposure and continue to do so for 10 full days from the date they were last known to have been exposed;
   2. Take extra precautions, such as avoiding crowding and physically distancing from others, when around people who are more likely to get very sick from COVID-19 while onsite at an agency workplace or interacting with members of the public in person as part of their official responsibilities, for 10 full days from the date they were last known to have been exposed; and
   3. Watch for COVID-19 symptoms for 10 full days from the date they were last known to have been exposed. For purposes of calculating the 10 full days, day 0 is the day of their last known exposure to someone with COVID-19, and day 1 is the first full day after their last known exposure.
2. Testing for Those Known to Have Been Exposed. Consistent with CDC guidance, the EEOC will require an employee or contractor who is known to have been exposed to COVID-19 and is onsite at an agency workplace or interacting with members of the public in person as part of their official responsibilities be tested for current infection with a viral test at least 5 full days after their last known exposure (ideally, on or after day 6).
   1. The test can be both self-administered and self-read by the employee if the employee certifies as to when they took the test and that they received a negative result.
   2. If the individual tests negative, consistent with CDC guidance, EEOC will instruct the individual to continue to follow the above precautions for 10 full days from the date they were last known to have been exposed. If they test positive, or if they at any time develop COVID-19 symptoms, they must follow agency protocols on isolation.
   3. If the individual is not working onsite at an agency workplace or interacting with members of the public in person as part of their official responsibilities within 10 days of the known exposure, then the agency should not require them to be tested.
   4. If the individual tested positive for COVID-19 with a viral test within the previous 30 days and subsequently recovered and remains without COVID-19 symptoms, then they do not need to get tested after a known exposure. If the individual that had been known to be exposed to COVID-19 had tested positive for COVID-19 with a viral test within the previous 31-90 days and subsequently recovered and remains without COVID-19 symptoms, then they should be tested using a viral antigen test.
      
      (See CDC guidance on specific testing recommendations for those that have had COVID-19 within the past 90 days.

3. COVID-19 and Federal Workers’ Compensation. The American Rescue Plan Act of 2021 makes it easier for federal workers diagnosed with COVID-19 to establish coverage under the Federal Employees’ Compensation Act. To establish a COVID-19 claim, you simply need to establish:

   • You were diagnosed with COVID-19 via a positive test result (excluding home tests) or by a medical professional; and
   • Within 21 days of your diagnosis of COVID-19, you carried out duties that required contact with members of the public, or co-workers.

   The interaction does not have to be direct physical contact. Nor is there a specified time for such interaction, any duration qualifies. General office contact and interaction is sufficient. This includes but is not limited to interaction in shared workspaces such as lunchrooms, break areas and common restrooms.

   However, an employee that is exclusively teleworking during a covered exposure period is not considered a "covered employee" under the ARPA. See FECA Bulletin 20-09.

   More information may be found in the DOL/OSHA FECA flyer.

X.   Isolation and Post Isolation Precautions

1. Isolation for Individuals with Probable or Confirmed COVID-19. Any individual with probable or confirmed COVID-19 infection, regardless of their vaccination status, must not enter an EEOC facility or interact with members of the public in person as part of their official responsibilities, and should monitor their symptoms. This includes people who have an initial positive diagnostic viral test for COVID-19, regardless of whether they have symptoms, and people with symptoms of COVID-19, including people who are awaiting test results or have not been tested.
2. Returning to Working Onsite After Isolation:
   1. Consistent with Task Force guidance, individuals who tested positive for COVID-19 and never developed symptoms may return to working onsite or interacting with members of the public as part of their official responsibilities after 5 full days following their positive COVID-19 test (day 0 being the day the individual was tested).
   2. Consistent with Task Force guidance, individuals who tested positive for COVID-19 and had symptoms may return to working onsite at an agency workplace or interacting with members of the public as part of their official responsibilities after 5 full days from the onset of symptoms (day 0 being the day of symptom onset), once they are fever-free for 24 hours without the use of fever-reducing medication and their other symptoms are improving. Note that loss of taste and smell may persist for weeks or months after recovery and need not delay the end of isolation.
   3. If an individual had moderate illness (if they experienced shortness of breath or had difficulty breathing) or severe illness (they were hospitalized) due to COVID-19, or they have a weakened immune system, then to be consistent with Task Force guidance, the individual must delay returning to working onsite or interacting with members of the public as part of their official responsibilities for a , days. If an individual had severe illness or has a weakened immune system, they should consult their healthcare provider before ending isolation. If an individual is unsure if their symptoms are moderate or severe or if they have a weakened immune system, the individual should consult a healthcare provider for further guidance.
3. Post-Isolation Precautions. Once an individual has returned to working onsite or interacting with members of the public as part of their official responsibilities after having tested positive for COVID-19 and isolated consistent with CDC guidance on isolation, the individual must continue to take precautions consistent with CDC guidance for at least 10 full days after their first day of symptoms, or after the date of a positive viral test for asymptomatic individuals, including:
   1. wearing a high-quality mask or respirator (such as an N95) when around others,
   2. avoiding eating and drinking around others,
   3. avoiding environments such as dining facilities, gyms, or other places where they may need to be unmasked around others, and
   4. avoiding being around people who they know are at high risk for severe disease from COVID-19.
      
      a)  As it relates to mask-wearing after returning from isolation, individuals can opt to take two viral antigen tests authorized by the FDA to detect current COVID-19 infection, starting on day 6. With two sequential negative tests 48 hours apart, the individual may remove their mask sooner than day 10. If either of their antigen test results are positive, the individual should continue taking antigen tests at least 48 hours apart until they have two sequential negative results. This may mean that the individual would continue wearing a mask and testing beyond day 10.
      
      b) If at any point their COVID-19 symptoms recur or worsen, the individual must not enter an EEOC facility or interact with members of the public as part of their official responsibilities, restarting at day 0.

XI.   Official Travel

1. Instructions for Traveling Individuals. Per the Safer Federal Workforce, there are no longer any travel restrictions on domestic travel based on vaccination status, although agency travel policies still apply. The CDC recommends:
   1. Individuals are up to date with their COVID-19 vaccines before travel;
   2. Consider being tested for current infection with a viral test as close to the time of departure as possible (no more than 3 days) before travel;
   3. Adhere strictly to CDC guidance for domestic and, if traveling outside the United States, international travel before, during, and after official travel;
   4. Check the destination’s COVID-19 Community Level before traveling, and wear a high-quality mask or respirator (such as an N95) while on-duty and around others indoors at their destination, if the COVID-19 Community Level in the county where their destination is located is HIGH;
   5. Understand and follow all travel restrictions put in place by State, Tribal, local, and territorial governments; and
   6. Be flexible, as restrictions, policies, and circumstances may change during their travel.
2. Travel for Individuals with Known Exposure. Asymptomatic individuals who have had a known exposure to someone with COVID-19 within the past 10 days, may still go on official travel. If the individual remains without COVID-19 symptoms before traveling, then pursuant to E.O. 13991 and consistent with CDC guidance, the individual, in addition to other standard pre-travel instructions related to COVID-19, must:
   1. Wear a high-quality mask or respirator (such as an N95) the entire time they are on-duty and around others indoors for the full duration of their travel that falls within the 10 full days after their last known exposure;
   2. Not travel on public transportation such as airplanes, buses, and trains if they will not be able to wear a high-quality mask or respirator (such as an N95) when around others indoors for the full duration of their travel within the 10 full days after their last known exposure; and
   3. Follow other aspects of post-exposure protocols, including the requirement for individuals with a known exposure to be tested for COVID-19 after 5 full days following their last known exposure (ideally, on or after day 6)—note testing may need to occur while the individual is traveling, and agencies do not need to require employees wait for the results of this post-exposure diagnostic test to undertake official travel, including return travel.
      
      If the individual develops COVID-19 symptoms after official travel has been approved, the individual should not undertake further official travel, including any previously approved travel authorization, and instead follow EEOC travel protocols consistent with the Task Force guidance on travel for individuals with COVID-19 symptoms.

3. Travel for Individuals with COVID-19 Symptoms or a Positive COVID-19 Test.
   The EEOC will not approve official travel (i.e., travel conducted under an official travel authorization) for individuals who have COVID-19 symptoms and are waiting for an initial diagnostic viral test result, nor will the EEOC approve official travel for individuals who have tested positive for COVID-19 for at least 5 full days after their first day of symptoms, or after the date of the initial positive diagnostic viral test for asymptomatic individuals.
   
   If an individual who tested positive for COVID-19 has returned to working onsite or interacting with members of the public as part of their official responsibilities (once they are fever-free for 24 hours without the use of fever-reducing medication and their other symptoms are improving), then the EEOC may approve official travel for the individual. The individual, in addition to other standard pre-travel instructions related to COVID-19, must:

   1. Wear a high-quality mask or respirator (such as an N95) the entire time they are on-duty and around others indoors for the full duration of their travel that falls within the period they are otherwise required to wear a high-quality mask or respirator after ending isolation, consistent with Task Force guidance;
   2. Not travel on public transportation such as airplanes, buses, and trains if they will not be able to wear a high-quality mask or respirator (such as an N95) when around others indoors for the full duration of their travel that falls within the period, they are otherwise required to wear a high-quality mask or respirator after ending isolation, consistent with Task Force guidance; and
   3. Follow other aspects of post-isolation protocols.

   If after official travel has been approved, the individual’s COVID-19 symptoms recur or worsen, then pursuant to E.O. 13991 and consistent with CDC guidance on isolation, the individual must not undertake further official travel, including any previously approved travel authorization, and not enter an EEOC facility or interact with members of the public as part of their official responsibilities, restarting at day 0 of isolation protocols.

   FAQs regarding official travel can be found on SaferFederalWorkforce.gov here.

XII.   Meetings, Events, and Conferences

All in-person attendees at any meetings, conferences, or events hosted by EEOC must
comply with relevant COVID-19 safety protocols, including as it relates to any mask-wearing when COVID-19 Community Levels are HIGH, pursuant to E.O. 13991 and consistent with CDC guidance.

FAQs regarding meetings, events, and conferences can be found on SaferFederalWorkforce.gov here.

XIII.   Hygiene

Hand sanitizer stations will be available at building entrances and throughout workspaces. Hand sanitizers should contain at least 60% alcohol and be manufactured in accordance with the requirements of the U.S. Food and Drug Administration (FDA). Ingredients should be listed on a “Drug Facts” label. EEOC will ensure the hand sanitizer is not on the FDA’s do not use list.

XIV.   Ventilation and Air Filtration

Modifications to ventilation systems will be considered in accordance with CDC’s COVID-19 ventilation recommendations, especially as building population density increases. To the maximum extent feasible, indoor ventilation will be optimized to increase the proportion of outdoor air and improve filtration. Deployment of portable high-efficiency particulate air (HEPA) cleaners will be considered for higher-risk spaces (e.g., intake rooms).

Where compliance with CDC ventilation and air filtration recommendations is not feasible in a particular office, the COVID-19 Coordination Team will evaluate mitigating measures.

XV.   Collective Bargaining Obligations

Consistent with President Biden’s policy to support collective bargaining and EEOC’s commitment to working with its union, the EEOC will satisfy applicable collective bargaining obligations under 5 U.S.C. Chapter 71 when implementing this Safety Plan and any updates, including on a post-implementation basis where necessary. In addition, the EEOC communicates regularly with employee representatives on workplace safety matters.