Revised CDC Guidance for Critical Industry Workers

On April 8, 2020, Director Robert Redfield announced at a White House press briefing that the CDC was modifying it previous Guidance in order to allow workers in Critical Infrastructure businesses who had been exposed to the coronavirus to return to work if they did not have symptoms of the illness.  Prior guidance had been that any worker exposed to someone who tested positive for COVID-19 should self-quarantine for fourteen (14) days.

The new Guidance can be found here, and the CDC has also issued a pdf summarizing this new approach for some workers.

Director Redfield made clear this change was not a wholesale waiver of the prior guidance and he strongly urged workers not to remain at work if they feel sick, and to refrain from congregating in crowded places, such as breakrooms.

Under the revised Guidance, Critical Infrastructure workers who have had an exposure but remain asymptomatic are permitted to return to work, but the CDC says employers and employees should adhere to the following practices before and during the work shift:

• Pre-Shift: An employer should measure the employee’s temperature and assess symptoms prior to letting him or her start work. It is best if temperature checks occur before entering the facility.
• Daily Monitoring: So long as a temperature or other symptoms do not develop, an asymptomatic employee should self-monitor during the workday under supervision of the employer’s occupational safety manager.
• Masks Required: An employee should always wear a mask while in the workplace for at least fourteen (14) days after the exposure.  An employer may want to pilot test the use of face masks to ensure they do not interfere with work assignments.  An employer can issue the face masks or can approve the employee’s supplied cloth face coverings in the event of shortages.
• Physical Distancing: The employee shall maintain at least six (6) feet and practice social distancing as work duties permit.
• Breaks/Food: Breaks should be staggered so that employees do not congregate in the breakroom and do not share food or utensils.
• Headsets/Personal Gear: Employees in general should not be sharing headsets or other objects that are near the mouth or nose.  For asymptomatic employees who work, this is especially important.
• Increased Frequency of Cleaning Commonly Touched Surfaces: All areas such as offices, bathrooms, common areas and shared electronic equipment must be cleaned and then disinfected, and it is suggested that these steps be taken more than once per day or per shift.
• Environmental Conditions. An employer should consider whether it is possible and advisable to increase the amount of air exchanges in the common work areas and other rooms employees share.
• Prompt Action if Sick Employee: If the employee becomes sick during the day, he or she must be sent home immediately.
• Response and Analysis: If and when an employee is sent home, information should be compiled on who had contact with the ill employee during the time the employee had symptoms and at least two (2) days before the employee’s symptoms and what other employees at the facility with close contact (within six (6) feet) of the employee during this time period should be considered exposed.
• Cleaning and Disinfecting the Facility: The employer will need to take prompt action to clean and disinfect all areas of the facility where the employee has worked over the past week. See the latest Guidance for Cleaning and Disinfecting the Workplace in this context.

Each business with Critical Infrastructure workers will need to evaluate its own circumstances to determine how this change in guidance impacts how it responds to this evolving situation, and whether it can comply with the practices outlined above.  Moreover, as the pandemic continues to impact business operations and workplaces, all employers are reminded that when implementing any changes in protocols or safety procedures it is essential to check the CDC website for the most current guidance and Virginia Health Department rules to ensure compliance.