New COVID-19 Contact Tracing Procedures Expands "Exposure" Definition

New COVID-19 contact tracing procedures released by the Centers for Disease Control and Prevention (CDC) last week have expanded the category of individuals who are deemed to be in close contact with each other – and will complicate the task of trying to maintain a safe workplace environment. The updated guidance now indicates that workers should be considered to be at risk of contracting COVID-19 if :

The employee was 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. This latest guidance also states that the determination of close contact does not change if employees are using fabric face coverings.

Employers 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. This expansion means the quarantining of employees who have brief, but frequent, interactions with positive coworkers, which will likely result in additional employees having to quarantine. 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.

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.

What if exposure could be close to 15-minutes? For employees who were exposed to a cumulative period of time that could be close to 15 minutes, the CDC provides additional factors that may be useful in determining whether the employee should be quarantined:

• 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.

Please know that while we strive for relevant and accurate information, this remains a fluid and evolving situation. We are not lawyers so please understand the information provided here does not, and is not intended to, constitute legal advice; instead, all information is for general informational purposes only.

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