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Correspondence - #27
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Correspondence - #27
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5/16/2023 9:57:42 AM
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City Clerk
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27
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5/16/2023
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City of Santa Ana—Cabrillo Town Center Project <br /> May 16,2023 <br /> Page 7of12 <br /> communication and training and workplace controls that <br /> meet standards that may be promulgated by the Center for <br /> Disease Control, Occupational Safety and Health <br /> Administration, Cal/OSHA, California Department of <br /> Public Health or applicable local public health agencies. <br /> The United Brotherhood of Carpenters and Carpenters International Training Fund <br /> has developed COVID-19 Training and Certification to ensure that Carpenter union <br /> members and apprentices conduct safe work practices. The City should require that all <br /> construction workers undergo COVID-19 Training and Certification before being <br /> allowed to conduct construction activities at the Project Site. <br /> Southwest Mountain States Carpenters has also developed a rigorous Infection Control <br /> Risk Assessment ("ICRA") training program to ensure it delivers a workforce that <br /> understands how to identify and control infection risks by implementing protocols to <br /> protect themselves and all others during renovation and construction projects in <br /> healthcare environments.' <br /> ICRA protocols are intended to contain pathogens, control airflow, and protect <br /> patients during the construction, maintenance and renovation of healthcare facilities. <br /> ICRA protocols prevent cross contamination, minimizing the risk of secondary <br /> infections in patients at hospital facilities. <br /> The City should require the Project to be built using a workforce trained in ICRA <br /> protocols. <br /> III. THE PROJECT CONSTITUES PEICEMEALED <br /> ENVIRONMENTAL REVIEW AND APPROVAL, IN VIOLATION <br /> OF CEQA <br /> It is well established that projects must not be separated into smaller parts, or <br /> piecemealed, for purposes of environmental review; environmental review must <br /> 6 See also The Center for Construction Research and Training,North America's Building <br /> Trades Unions (April 27 2020) NABTU and CPWR COVIC-19 Standards for U.S <br /> Constructions Sites, available athttgs://www.cpwr.com/sites/default/files/NABTU <br /> CPWR Standards COVID-19.pdf;Los Angeles County Department of Public Works <br /> (2020) Guidelines for Construction Sites During COVID-19 Pandemic, available at <br /> https://dpw.lacounty.gov/building-and-safety/docs/pw guidelines-construction-sites.pdf. <br /> ' For details concerning Southwest Carpenters' ICRA training program,see <br /> https://icrahealthcare.com/. <br />
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