PLAN SUMMARY
This plan provides the Pala Gaming Commission (PGC) with a re-opening and operating plan for Pala Casino Spa Resort.  The plan establishes criteria and protocol that help mitigate the risks associated with the transmission of COVID-19 and ensures that the gaming facility is operating in a manner that adequately protects the public health and safety.

PREOPENING PLAN SUMMARY
In addition to this, detailed departmental preopening plans have also been created to ensure effective implementation of this Plan..

All NIGC and PGC  safety guidelines relating to COVID-19 will be implemented, continually monitored, evaluated, and improved upon as needed.  Additionally, other Governmental Health Agency (GHA) safety protocols, including but not limited to the CDC, will be continually evaluated, and implemented as needed.

Deep Cleaning/Sanitization: Prior to reopening the entire facility was deep cleaned and sanitized.  This includes, but is not limited to, the following:

    • All high touch – high traffic areas including carpets, walls, and ceilings.
    • All restrooms have and will be monitored continuously and sanitized as traffic dictates.
    • All furniture, fixtures, and equipment.
    • All table gaming equipment including chips, tables, chairs, felts, rails, and table signage, have been cleaned and sanitized.
    • Hotel rooms, elevators, common areas, and check-in.

Health/Fire and Life Safety:

    • All safe food handling and preparation checklists provided by the California Area Indian Health Services have been reviewed and completed prior to reopening.
    • The facilities Fire and Life Safety systems including but not limited to the smoke detectors, visual and audible alarms, sprinkler system pump, emergency egress, egress routs have all been tested and inspected by the local fire agency and are in compliance with Life Safety codes applicable to Title 19 of the California Code of Regulations relevant to similar facilities in the County.

Social Distancing: All public areas have been evaluated for Engineering Controls and reconfigured/modified to facilitate the safe social distancing of 6 feet and/or utilization of effective protective barriers.   This includes, but is not limited to, the following:

    • Maximum facility occupancy has been reduced to 50% to facilitate safe social distancing. Occupancy levels will be monitored 24/7 with computer software. Guest Safety will be notified when the occupancy level reaches 50% of the maximum and access will be restricted at all points of entry by Guest Safety to ensure the 50% occupancy level is maintained.
    • All areas have been reengineered to meet six feet spacing between standing persons everywhere possible.
    • All guests will be advised of social distancing protocols upon entering the property.
    • The number of slot machines has been reduced by up to 50% and the slot chairs removed to facility social distancing.
    • All table games have been moved or closed to facilitate social distancing.
    • Blackjack has been reduced to 3 players, Baccarat has been reduced to 4 players on 7 spot and 3 players on 6 spot and Pai Gow Poker has been reduced to 3 players to maintain social distancing.
    • Seating and hours of operation have been reduced at all open food outlets and bars to maintain social distancing.
    • All Concerts, Special Events and Tournaments have been cancelled until it is safe to resume.
    • All queuing areas such as the Entrances, Hotel Front Desk, ATM’s, and Cage have floor markers in place to maintain social distancing.
    • Choices Buffet, Poolside Café, Oak Room, Pool, Spa, Banquets, Valet, RV Resort Clubhouse and Pool have all been closed to facilitate social distancing.
    • Guests will be continually monitored for compliance with safety protocols.

Personal Protective Equipment (PPE):  All processes that require the exchange of personal items like currency, credit cards, luggage etc. have been evaluated for Administrative Controls to eliminate and/or minimize exposure with the use of alternative processes or the use of) and/or sanitization methods.

    • Guests
      Masks will be required and provided at no cost.
    • Team members (TM’s) conducting COVID-19 sanitization/disinfection activities will be provided with and shall wear the appropriate Personal Protective Equipment (PPE) including but not limited to disposable latex free gloves, eye protection, face masks for all tasks in the sanitization/disinfection process, including the handling trash. All sanitization/disinfection products and equipment used will be established to be effective for COVID-19 and approved by management. All sanitization/disinfection products, equipment and PPE will be used in accordance with the manufacturer recommendations and departmental training and policies & procedures in addition to the guidelines below.
    • A variety of Personal Protective Equipment (PPE) may be required based on the recommendations of the cleaning/disinfectant products being used. All gloves and gowns will be compatible with the EPA approved disinfectant products being used.
    • Team Members will be trained and reminded that: PPE should be removed carefully in a designated area to avoid contamination of the wearer and the surrounding area. Be sure to wash hands after removing PPE.
    • Team Members will be trained and reminded that: Gloves should be changed after cleaning a room or area. Wash hands immediately after gloves are removed.
    • All sanitization/disinfection activities shall be performed in accordance with departmental guidelines, training, and product/equipment manufacturer recommendations.
    • TM’s should immediately report breaches in PPE (e.g., tear in gloves) or any potential exposures to their Supervisor/Manager and handled in accordance with current COVID-19 exposure plan.

REOPENING PLAN SUMMARY
All NIGC and PGC  safety guidelines relating to COVID-19 will be implemented, continually monitored, evaluated, and improved upon as needed. Additionally, other Governmental Health Agency (GHA) safety protocols, including but not limited to the CDC, will be continually evaluated, and implemented as needed.

Mechanisms to implement, monitor, test and report on all departmental operations for compliance with all safety protocols relating to COVID-19: Implementation, monitoring, temperature testing, and reporting on all matters relating to Covid-19 are specific to the area of the operation they serve, such as:

Guests Entering the Building:

    • Guest’s body temperature will be screened with a no contact infrared body temperature scanner prior to entry.
    • Guest’s with a body temperature of 100.4 degrees and above will not be allowed entry into the facility on a “pass or fail” basis and will be provided information from GHA’s for guidance (pursuant to HIPPA temperature readings will not be recorded, broadcast or communicated).
    • Notice of Temperature Testing signage will be posted at all points of arrival.
    • All guests will be required to wear a face mask in all public areas of the facility and adhere to the recommendations and orders from GHA’s including but not limited to social distancing, face masks, personal hygiene and self-monitoring for symptoms.
    • Face masks will be available to guests at no cost.
    • All guest entry points and restrooms will have signage posted with the latest prevention requirements from GHA’s including but not limited to social distancing (excluding members of the same household), face masks, personal hygiene and self-monitoring for symptoms.
    • Hand sanitizer will be available to guests at all points of entrance and in convenient locations throughout public areas.

Team Members:

    • TM’s body temperature will be screened daily with a no contact infrared body temperature scanner prior to entry.
    • TM’s with a body temperature of 100.4 degrees and above will not be allowed entry into the facility on a “pass or fail basis” and will be provided information from GHA’s for guidance (pursuant to HIPAA temperature readings will not be recorded, broadcast or communicated). All TM’s that fail the screening and any subsequent call-outs will be reported to HR and will be subject to existing procedures for returning to work.
    • All TM’s will be provided with a washable face mask and will be required to wear them while on property. Replacement masks may be purchased at cost from wardrobe. TM’s may bring their own face mask subject to approval from Management.
    • Face shields and gloves will be provided to TM’s upon request at no cost subject to department approval.
    • All TM entry points and restrooms will have signage posted with the latest prevention requirements from GHA’s including but not limited to social distancing, face masks, personal hygiene and self-monitoring for symptoms.
    • Hand sanitizer will be available to Team members and guests at all points of entrance and in convenient locations throughout public areas.

Vendors

    • Vendors will comply with all existing access controls and will be screened with a no contact infrared body temperature scanner prior to entry.
    • Vendors with a body temperature of 100.4 degrees and above will not be allowed entry into the facility on a “pass or fail basis” and will be provided information from GHA’s for guidance (pursuant to HIPPA temperature readings will not be recorded, broadcast or communicated).
    • All Vendors will be required to provide their own face mask and will be required to wear them while on property and adhere to the recommendations and orders from GHA’s including but not limited to social distancing, face masks, personal hygiene and self-monitoring for symptoms.
    • All Vendors will be required to follow all health and safety regulations, recommendations and orders applicable to their industry while on property.
    • Hand sanitizer will be available at all points of entrance and in convenient locations throughout back house and public areas.

COVID-19 Training

    • Prior to reopening all TM’s will be trained on COVID-19 and its prevention, symptoms, reporting, hygiene and sanitization including departmental hygiene and sanitization policies and procedures. All COVID-19 guidelines and subsequent policies and procedures regarding prevention, sanitization, hygiene and health and safety will be strictly enforced.

OPPERATIONAL PLAN SUMMARY

All cleaning and sanitizing processes utilize safe and efficient technologies such as: Electrostatic foggers that employ static electricity to increase coverage (360 degree) of disinfectants when applied to targeted surfaces.

Our HVAC system utilizes UV light to supplement the filtration system and increase its overall efficiency.  UV Light emits ultraviolet radiation that has been determined to be effective in killing COVID-19.

We use EPA approved sanitization products that are established to be effective for COVID-19, all products are used in accordance with the manufacturer’s recommendations and the use of PPE.

HVAC

    • Maintain UV sanitization of HVAC air handling system to supplement the filtration system and increase its overall efficiency in delivering clean air.
    • UV light emits ultraviolet radiation that has been determined to be effective in killing COVID-19 and is being used to supplement our air filtration system.

PUBLIC and BACKHOUSE AREAS/OFFICES: Thoroughly clean and disinfect/sanitize all hard surfaces, floors and touch point including but not limited to:

    • Slot Machines: wiped down every 4 hours and sooner as needed after use.
    • Gaming Tables and Chairs
    • Gaming chips have been divided into two sets and will be rotated, cleaned and sanitized not less than monthly. Additionally, gloves will be offered to patrons and to TMs.
    • Automated Teller Machines (ATM)/Ticket Redemption Units (TRU)
    • Door handles, push plates, thresholds and hand railings
    • Counters
    • Workstations/Podiums/Point of Sale (POS) and peripherals
    • Telephones and keypads
    • Computers and Keyboards/peripherals
    • Printers and key/touch pads
    • Time Clock
    • Tables and chairs
    • Drapery pull handles
    • Cabinet door and drawer handles
    • Elevator doors and control pads
    • Light/Lamp switches and thermostats
    • Vending and ice machines
    • Privileges/Informational kiosks
    • Free standing promotional signage/kiosks
    • Trash receptacle touch points
    • Machinery, Equipment, Carts and their handles/controls.

PUBLIC and BACKHOUSE RESTROOMS: Thoroughly clean and disinfect/sanitize all hard surfaces, floors and touch point including but not limited to:

    • Door handles/latches
    • Sink faucets and toilet handles
    • Towel dispenser handle
    • Soap/chemical dispenser push plates
    • Trash receptacle touch points
    • Personal Hygiene Product dispensers
    • Mop sink handles

PUBLIC and BACKHOUSE DINING AREAS: Thoroughly clean and disinfect/sanitize all hard surfaces, floors and touch point including but not limited to:

    • Door handles, push plates, thresholds and hand railings
    • Counters
    • Workstations/Podiums/Point of Sale (POS) and peripherals
    • Telephone and keypad
    • Tables and chairs
    • Self Service Coffee and beverage stations
    • Self Service Salad, Soup and Condiment Stations
    • Vending machines
    • Informational kiosks
    • Menus
    • Trash receptacle touch points

KITCHENS

    • Door handles, push plates, thresholds and hand railings
    • Machinery, Equipment, Carts and their handles/controls.
    • Counters
    • Workstations/Podiums/Point of Sale (POS) and peripherals
    • Beverage stations
    • Ice Machine doors and Ice scoops
    • Refrigerator Freezer handles
    • Walk-in refrigerator and freezer handles and plastic curtains
    • Sink Handles
    • Handwashing and mop sink handles
    • Soap/chemical dispenser push plates
    • Towel and Glove dispensers
    • Trash receptacle touch points
    • Cleaning tools
    • Workstations/Podiums/POS and peripherals
    • Telephones and keypads
    • Computers and Keyboards/peripherals

Garages

    • Door handles, push plates, thresholds and hand railings
    • Elevator doors and control pads

GUEST ROOMS: Thoroughly clean and disinfect/sanitize all hard surfaces, floors and touch point including but not limited to:

    • Door handles, push plates, thresholds, and hand railings
    • Desks, tables, chairs, and lamps
    • Cabinet and Dresser door/drawer handles
    • Counters, Light/Lamp switches, and thermostats
    • Drapery pull handles
    • Mini-bar, menu, and room collateral
    • Telephones and keypads, remote controls and keypads and alarm clocks
    • Televisions and remote controls
    • Safety latch and peephole
    • Trash receptacle touch points
    • Iron handle, hangers, and luggage rack
    • Faucets and toilet handles
    • Hair Dryers
    • Vanity Mirrors

PPE/Exposure Control
All departmental operations and positions have been evaluated and categorized in the Occupational Risk Pyramid as recommended by Federal OSHA based on risk of exposure prior to reopening.  All TM’s will  receive training on all Exposure Controls and will be provided with the necessary PPE and trained on their use, putting on, fitting, removal and sanitization and/or disposal of PPE.

COVID-19 Exposure
Any reported/presumptive cases of COVID-19 by guests or TM will be reported to Guest Safety and Human Resources Guest Safety will isolate exposed individuals that are on property, and secure any exposed areas and follow existing blood borne pathogen protocol.  Guest Safety will investigate, conduct contact tracing and complete an Incident Report that will be provided PGC.  Any TM’s determined to have an exposure risk will be excluded from work until tested for COVID-19.  In the event of a confirmed case of COVID-19 the appropriate GHA will be contacted and  guidelines followed.  The Pala Crisis Management Team will, on a continuous basis, monitor applicable  GHA guidelines and ensure reporting, communication, exposure control, notification, sanitization, and such other actions as may be necessary and appropriate.

Business Continuity
All Departments will identify critical functions and develop a contingency plan in the event of staffing shortages. All TM illness/absenteeism will be reported to and monitored by each department and communicated to HR to ensure staffing levels for critical functions are optimized and maintained.

Operational Integrity
In order to maintain operational integrity all NIGC, PGC and GHA  safety guidelines for COVID-19 will be continually monitored and evaluated daily.  All internal, local and regional infections, infection rates, outbreaks, trends, supply shortages and related data will also be tracked, monitored, and evaluated daily.  Appropriate responses such as adjusting staffing, supply levels and the decision to remain open will be prioritized based on our ability to comply and/or meet the demands dictated by the information gathered above and ensure the health and safety of our Guests and TM’s.

Supplies
All equipment and supplies necessary to ensure the health and safety of our guests and TM will be communicated to Purchasing daily and will be in place prior to reopening.  Inventory levels will be monitored and maintained by Purchasing.  Any supply shortages or disruptions will be communicated daily to optimize inventories and resources.

Compliance
All health and safety procedures and guidelines will be monitored daily by Guest Safety and Risk Management and are subject to existing internal controls.

This plan has been developed to meet and/or exceed the latest applicable  guidelines of  GHAs, including but not limited to the CDC, and is subject to change as the situation and/or guidelines may recommend, as approved by the Pala Gaming Commission.