Last week the Center for Disease Control (CDC) revised its definition of “close contact” with someone with COVID-19 to include shorter, repeated contacts. Previously, the CDC defined “close contact” as 15 consecutive minutes within 6 feet of someone who had tested positive for COVID-19. The revised guidance now considers a total of 15 minutes of exposure within a 24-hour period to constitute “close contact” as well.
Many employers previously adopted CDC guidance that anyone who had been in close contact with someone who had tested positive for COVID-19 should quarantine for two weeks. This change may result in a dramatic increase in the number of employees now required to quarantine, due to the relative ease with which co-workers may accumulate 15 minutes of contact in small increments spread over the course of a workday. Employers should also anticipate that state and local agencies will revise their guidelines as well.
In light of this change, employers should revisit their mitigation and tracking protocols. Specifically, employers will now need to consider not only the length of employee gatherings, but also the frequency. Additionally, contact tracing procedures and inquiries will require modification to capture a broader range of contacts and survey a larger number of individuals.
Meredith S. Campbell Chair, Employment and Labor Group
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