The safety of our research workforce, learners, and broader communities is our leading priority. Research and research training protocols must be optimized to provide the lowest risk for COVID-19 transmission feasible. This may require innovative approaches and enabling new, more flexible ways of conducting research.
The most effective way to reduce the risk of spreading COVID-19 is to minimize the amount of time people are within 6 feet of each other. However, some complex research procedures, involving multiple personnel, cannot physically be performed while maintaining 6-foot physical distancing.
Close Proximity Research Guidance
Alternative measures to eliminate the need for close contact should be rigorously explored prior to seeking an exception to physical distancing during research procedures. Measures to consider include, but are not limited to:
- Remaining more than 6 feet apart and alternating positions near the sample or equipment, with frequent decontamination of surfaces and equipment.
- Introducing a temporary plexiglass barrier(s) or partition(s).
- Rearrangement of laboratory instruments and/or equipment to better accommodate distancing.
Evidence suggests that enhanced Personal Protective Equipment (PPE) minimizes the potential transmission of SARS-CoV-2, the strain of coronavirus that causes COVID-19.
Close proximity research procedures may be permissible under the following conditions:
- Enhanced PPE : Lab coat, gloves, and surgical face mask with the addition of a face shield must be used when at least 6 feet of physical distancing cannot be achieved.
- Surgical masks may be reused but should be replaced if the mask becomes wet or visibly soiled.
- Face shields should be decontaminated after each use and stored in a clean area or discarded, if not reusable.
- Physical distancing: Use of this PPE regimen in lieu of 6-foot distancing is only permissible in situations where distancing is physically impossible; otherwise, physical distancing expectations must be maintained. If at any time during the procedure physical distancing is possible, it must be practiced.
- Avoid sharing tools: Use of separate high-touch tools, where practicable, to avoid sharing.
- Minimize time in close proximity: Measures to minimize the time within 6 feet must be employed.
To request a modification to the 6-foot physical distancing directive, the Request to Perform Close Proximity Research must be submitted to the Associate Dean for Research for review and approval. Here is an example of a completed form.
Each request will be reviewed to determine whether alternatives to close proximity work are feasible, and the potential incremental risk for COVID transmission. Justifications based on convenience or solely on room/equipment availability will not be accepted. If approved, the Request to Perform Close Proximity Research form should be uploaded as an addendum to your laboratory SOP. Please share the updated SOP with your Unit Administrator.
Principal Investigator Attestation
The Principal Investigator assumes the responsibility to ensure that all parties involved in close proximity research understand their responsibilities and that they comply with all the safety requirements of the Close Proximity Research Exception outlined above and in the approval notification. The PI should confirm all parties are comfortable with the plan as proposed and describe the escalation process if, at any point, personnel have concerns about their safety.
As part of the application process, the PI will attest to the following:
- I have discussed the requirements for close proximity training with all lab members.
- Laboratory personnel involved in the close proximity work will comply with all enhanced PPE requirements to perform close proximity work and follow all cleaning/disinfection protocols that are appropriate for the procedure(s) and, if required, that have been approved by EHS.
- Laboratory personnel will adhere to existing 6-foot physical distancing and maximum room density directives in place by the University of Michigan when not performing work approved under this Close Proximity safety plan.
- Laboratory personnel have been made aware that lab safety issues, including personnel who are ill or not following safety protocols, may be reported via the U-M compliance hotline website, by calling 866-990-0111, or contacting EHS at 734-647-1143 or emailing EHS-Covid-19-Reporting@umich.edu