It’s a daunting task to keep current with the constantly evolving, and sometimes conflicting, health agency guidance on workplace safety amid COVID-19. A good example is the CDC guidance on what to do when workers come in close contact with an individual who has a confirmed or suspected case of the virus. Initially, the CDC recommended that potentially exposed workers should self-quarantine for 14 days. The CDC then recommended that potentially exposed workers who remained asymptomatic could remain at work so long as additional precautions were taken, like temperature checks and wearing face coverings. The CDC is now distinguishing between critical infrastructure workers and “other employees.” It recommends that other workers who have been potentially exposed should self-isolate for 14 days, and cautions that home isolation may still be the best option even for essential workers.

The CDC’s comprehensive FAQs for business is at https://www.cdc.gov/coronavirus/2019-ncov/community/general-business-faq.html. To help you stay on top of this evolving maze of CDC guidance, below is the current CDC guidance on when employees who tested positive for COVID-19 can return to work, and what to do when an employee has been potentially exposed to COVID-19.

RETURNING TO WORK

Employees with COVID-19 should not return to work until they meet the CDC’s criteria to discontinue home isolation, and have consulted with a healthcare provider and state or local health department. This criteria is dependent on whether the employee has been tested or not, and has symptoms.

Employees with COVID-19 who have stayed home can return to work under the following conditions:

If they have not had a test to determine if they are still contagious, they can return to work after these three things have happened:

  1. They have had no fever for at least 72 hours (without the use of medicine that reduces fevers)
    AND
  2. other symptoms have improved (for example, symptoms of cough or shortness of breath have improved)
    AND
  3. at least 10 days have passed since their symptoms first appeared

If they have had a test to determine if they are still contagious, they can return to work after these three things have happened:

  1. They no longer have a fever (without the use of medicine that reduces fevers)
    AND
  2. other symptoms have improved (for example, symptoms of cough or shortness of breath have improved)
    AND
  3. they have received two negative tests in a row, at least 24 hours apart. Their doctor will follow CDC guidelines.

Employees who DID NOT have COVID-19 symptoms, but tested positive and have stayed home can return to work under the following conditions:

If they have not had a test to determine if they are still contagious, they can return to work after these two things have happened:

  1. At least 10 days have passed since the date of their first positive test
    AND
  2. they continue to have no symptoms (no cough or shortness of breath) since the test.

If they have had a test to determine if they are still contagious, they can return to work after:

  1. They have received two negative tests in a row, at least 24 hours apart. Their doctor will follow CDC guidelines.
  2. If they develop symptoms, follow guidance above for people with COVID19 symptoms.

ACTION ITEMS FOR KEY WORKERS POTENTIALLY EXPOSED

Critical infrastructure workers who had been in close proximity to confirmed or suspected individuals with COVID-19 may be permitted to remain at work provided they remain symptom-free and follow the below additional precautions. A potential exposure means being a household contact or having close contact within 6 feet of an individual with confirmed or suspected COVID-19. The timeframe for having contact with an individual includes the period of time of 48 hours before the individual became symptomatic.

  • Pre-Screen: Employers should measure the employee’s temperature (ideally before entering the worksite) and assess symptoms prior to them starting work.
  • Regular Monitoring: As long as the employee doesn’t have a temperature or symptoms, they should self-monitor under the supervision of their employer’s occupational health program.
  • Wear a Mask: The employee should wear a face mask at all times while in the workplace for 14 days after last exposure.
  • Social Distance: The employee should maintain 6 feet and practice social distancing as work duties permit in the workplace.
  • Disinfect and Clean workspaces: Clean and disinfect all areas such as offices, bathrooms, common areas, shared electronic equipment routinely.

If the employee becomes sick during the day, they should be sent home immediately. Surfaces in their workspace should be cleaned and disinfected. Information on persons who had contact with the ill employee during the time the employee had symptoms and 2 days prior to symptoms should be compiled. Others at the worksite with close contact within 6 feet of the employee during this time would be considered exposed.

Even this guidance comes with a recent caveat by the CDC, it “should not be misinterpreted as always being the first or most appropriate option to pursue in managing critical work tasks” and “home isolation may still be the most viable option for exposed workers.”

NON-CRITICAL EMPLOYEES WHO MAY HAVE BEEN EXPOSED

Non-critical infrastructure employees who have been potentially exposed and have symptoms of COVID-19 should self-isolate and follow the CDC recommended steps on what to do if you are sick.

Non-critical infrastructure employees who have been potentially exposed and do not have symptoms should remain at home or in a comparable setting, practice social distancing and self-monitor for symptoms for 14 days.

According to the CDC, employees may have been exposed if they are a “close contact” of someone who infected, which is defined as being within approximately 6 feet of a person with COVID-19 for a prolonged period of time (approximately 10 minutes or more).

As more businesses are reopening, the takeaway from this fluid and ever-changing guidance: frequently monitor for updates on what to do with confirmed and suspected cases, and implement new guidance whenever your operations permit. The CDC advises that most workplaces should follow the Public Health Recommendations for Community-Related Exposure, and critical infrastructure workplaces should follow the guidance for Implementing Safety Practices for Critical Infrastructure Workers Who May Have Had Exposure to a Person with Suspected or Confirmed COVID-19.