CDC Revises Guidance Impacting Return to Work

According to the Pennsylvania Department of Health, following CDC Guidelines, a person should quarantine for 14-days from the last time s/he had “close contact” with a person known to have COVID-19.  For the entirety of the pandemic, “close contact” has been defined as being within six feet of an infected person for longer than fifteen minutes.  However, the CDC has recently revised the definition of “close contact,” broadly expanding the scope of the definition, and, in turn, the number of employees that may need to quarantine and the scope of necessary contact tracing.

Now, a close contact is viewed cumulatively as any 15 minutes—whether at one time or over multiple smaller meetings—over any 24-hour period within the two days prior to the sickness, regardless of whether face masks or other PPE were worn or not. 

“Close contact” is now defined as “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.”  A comment to the definition states, “the determination of close contact should generally be made irrespective of whether the contact was wearing respiratory PPE.  At this time, differential determination of close contact for those using face coverings is not recommended.” 

Now, any employee that spent any fifteen minutes in a 24-hour period around a known positive person—even if they were both wearing masks—should quarantine under the CDC guidance.  Worse yet, if it was an employee that was the known positive, the contact tracing becomes much more difficult when an employer could face quarantining every employee who spent a total of fifteen minutes in a 24-hour period within six feet of the infected employee, as opposed to a single fifteen minute period.  

The Pennsylvania Department of Health has yet to address the updated definition of close contact, however, the Department’s current Orders make general reference adherence to CDC guidance.    

Please contact a MacDonald Illig attorney or complete this form if you have any questions regarding the new definition of “close contact” and how it might impact your business.  We will keep you updated as more information comes out. 

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