The Centers for Disease Control and Prevention (CDC) has updated its definition of “close contact,” which is now referred to as the “6-15-24-48 analysis.” This complicates the already difficult task faced by employers when trying to maintain a safe workplace environment as well as comply with the Occupational Safety and Health Administration (OSHA) guidelines regarding employers’ obligations to report employee in-patient hospitalizations and fatalities resulting from work-related cases.
The updated CDC guidance now indicates that workers should be considered at risk of contracting the novel coronavirus if someone was:
- Within 6 feet of an infected person
- for a cumulative total of 15 minutes or more
- over a 24-hour period
- starting from two days (48 hours) before illness onset (or, for asymptomatic patients, two days prior to test specimen collection) until the time the patient is isolated.
This means that an employer must now determine which employees were within six feet of an infected employee for a combined total of 15 minutes or more over any 24-hour period within the 48 hours prior to the sick individual showing symptoms, and not just during one 15-minute period. For example, an employee who was within six feet of an infected person on three occasions of five minutes in length each, or eight occasions of two minutes each, is now considered to have had “close contact” with that person and must quarantine.
This new guidance complicates an employer’s efforts to conduct contact tracing because employees who come into contact for short periods of times multiple times over a 24-hour period will need to be examined to determine whether they were cumulatively exposed for 15 minutes or more. This expansion is going to require quarantining of employees who have brief, but frequent, interactions with positive coworkers, which will likely result in additional employees having to quarantine.
In addition to the general definition of “close contact,” the CDC has also provided factors to consider when defining close contact, including:
Proximity – closer contact likely increases exposure risk.
Duration – longer exposure time likely increases exposure risk.
Symptomatic/Asymptomatic – the period around onset of symptoms is associated with the highest levels of viral shedding.
Respiratory aerosols – if the infected person was coughing, singing, or shouting; and
Environmental factors – crowding, adequacy of ventilation, whether exposure was indoors or outdoors.
Unfortunately, addressing and contact tracing per CDC Guidelines for confirmed COVID-19 cases in a workplace will likely be an issue for the foreseeable future. Employers should prepare for confirmed COVID-19 cases in the workplace by implementing contact tracing policies that comply with the latest CDC guidelines. This is a constantly evolving area, as scientists continue to learn more about the COVID-19 virus. We should be prepared to adapt our policies to changing guidance.
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