Yesterday, the Centers for Disease Control and Prevention (CDC) redefined “close contact” for purposes of potential higher risk of exposure to COVID-19.
Until yesterday, the CDC had defined closed contact generally as 15 consecutive minutes within six (6) feet of someone who having (or suspected as having) COVID-19. The operative word for this blog is “consecutive.”
Yesterday, the CDC changed the definition of “close contact ” as follows:
“Someone who 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 .”
We are now looking at cumulative rather than consecutive. The CDC gives the following example: “Individual exposures added together over a 24-hour period (e.g., three 5-minute exposures for a total of 15 minutes).”
The new definition of “close contact” is important for employers for at least these three (3) reasons:
First, employers have or should have a protocol pursuant to which employees must report certain circumstances including “close contact” with someone having (or suspected as having) COVID-19. Employers will want to revisit their protocols to make sure that the definition of close contact takes into account the new CDC guidance.
Second, employers will need to rethink their on-site operations and redouble their education and monitoring with regard to social distancing. A few minutes here and there may be close contact. Employers do not want employees (or others working with them) to come close to the cumulative line.
Third, the importance of wearing masks to help prevent exposure is even more important. The wearing of masks can make less likely, not eliminate, the possibility that the cumulative impact of multiple short exposures will result in someone contracting COVID-19.
The new CDC definition: https://www.cdc.gov/coronavirus/2019-ncov/daily-life-coping/contact-tracing.html
Be careful, please.
+This blog should not be construed as legal advice.
Jonathan A. Segal is a partner at Duane Morris LLP in the Employment, Labor, Benefits and Immigration Practice Group . He is also the managing principal of the Duane Morris Institute . The Duane Morris Institute provides training for human resource professionals, in house counsel, benefits administrators and managers at Duane Morris, at client sites and by way of webinar on myriad employment, labor, benefits and immigration matters. Read Jonathan's blog at the Duane Morris Institute or follow him on Twitter @Jonathan_HR_Law .
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