The CDC has changed the definition of "close contact" for purposes of COVID-19 exposure. This will change employers' contact tracing requirements and potential exposure notification procedures.
Previously, the CDC stated that "close contact" occurs when you are within 6 feet of an infected individual for 15 minutes.
Today, the CDC changed its guidance, stating that close contact occurs when you are within 6 feet of an infected person for a "cumulative total of 15 minutes or more over a 24-hour period starting from 2 days before illness onset (or, for asymptomatic patients, 2 days prior to test specimen collection) until the time the patient is isolated."
The CDC recognizes this will change contact tracing, stating this is the new operational definition for "contact investigation."
The new CDC guidance provides factors to consider when attempting to determine who was in close contact with an infected individual:
- proximity (closer distance likely increases exposure risk),
- the duration of exposure (longer exposure time likely increases exposure risk),
- whether the infected individual has symptoms (the period around onset of symptoms is associated with the highest levels of viral shedding),
- if the infected person was likely to generate respiratory aerosols (e.g., was coughing, singing, shouting), and
- other environmental factors (crowding, adequacy of ventilation, whether exposure was indoors or outdoors).
What does this mean for employers?
If you have an in-office employee who tests positive for COVID-19, the pool of coworkers who may have been exposed due to "close contact" just got a lot bigger.
It is still best practice to interview the infected employee regarding the names of coworkers he or she was physically close to during the week of the COVID-19 diagnosis. Once the infected individual provides names, the employer has an obligation to reach out to the exposed coworkers to explain the risks and additional precautions required. Employers are prohibited from revealing the identity of the infected individual to coworkers.
In addition, employers should provide a Potential Exposure Notice to everyone who worked at the site with the infected individual during the week leading up to the COVID-19 diagnosis. Given the new, broader definition of "close contact," employers should not limit the Potential Exposure Notice to one department unless that group is completely segregated from the rest of the site, including separate exits, restrooms, and break rooms.
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