CDC provides new guidance for returning critical infrastructure workers to work following potential exposure to COVID-19


The Centers for Disease Control (CDC) announced new Interim Guidance for Implementing Safety Practices for Critical Infrastructure Workers Who May Have Had Exposure to a Person With Suspected or Confirmed COVID-19.  The new guidance relaxes restrictions on employees who may have been exposed to COVID-19 but do not show symptoms.

The new guidance applies to Critical Infrastructure Workers who work in the 16 sectors identified in the Cybersecurity & Infrastructure Agency (CISA)’s Memorandum on Identification of Essential Critical Infrastructure Workers During Covid-19 Response.

The CDC guidance contains safety precautions for allowing potentially-exposed workers to remain in the workplace rather than sending them home to self-quarantine, as had been previously recommended.  The stated purpose of the new guidance is to ensure continuity of essential infrastructure functions.

The CDC guidance defines “potential exposure” as a household contact or having close contact within 6 feet of any other individual with confirmed or suspected COVID-19, and includes the period of time 48 hours before the individual became symptomatic.

The CDC indicates that critical infrastructure workers may be permitted to continue to work following potential exposure to COVID-19 provided they remain asymptomatic and adhere to the following practices prior to and during their work shift:

  • Pre-Screen: Employers should measure the employee’s temperature and assess symptoms prior to them starting work. Ideally, temperature checks should happen before the individual enters the facility.
  • Regular Monitoring: As long as the employee doesn’t have a temperature or symptoms, they should self-monitor under the supervision of their employer’s occupational health program.
  • Wear a Mask: The employee should wear a face mask at all times while in the workplace for 14 days after last exposure. Employers can issue facemasks or can approve employees’ supplied cloth face coverings in the event of shortages.
  • Social Distance: The employee should maintain 6 feet and practice social distancing as work duties permit in the workplace.
  • Disinfect and Clean work spaces: Clean and disinfect all areas such as offices, bathrooms, common areas, shared electronic equipment routinely.

If an employee becomes sick, the CDC instructs: (1) the employee should be sent home immediately, (2) surfaces in their workspace should be cleaned and disinfected, (3) information on persons who had contact with the ill employee during the time the employee had symptoms and 48 hours prior to symptoms should be compiled, and (4) others at the facility with close contact within 6 feet of the employee during this time should now be considered exposed (see steps above).

In the new guidance, the CDC identifies the following additional health and safety considerations:

  • Employees should not share headsets or other objects that are used near the mouth or nose.
  • Employers should increase the frequency of cleaning commonly touched surfaces.
  • Employees and employers should consider pilot testing the use of face masks to ensure they do not interfere with work assignments.
  • Employers should work with facility maintenance staff to increase in-room air exchanges.
  • Employees should physically distance when they take breaks together. Stagger breaks and don’t congregate in the break room, and don’t share food or utensils.

The CDC reiterates that employers should also implement the CDC’s prior recommendations set forth in the Interim Guidance for Business and Employers to Plan and Respond to Coronavirus Disease 2019 to help prevent and slow the spread of COVID-19 in the workplace.  The new guidance does not apply to health care workers, for whom the CDC had already issued guidance.

In light of the updated CDC guidance, we recommend that employers that have Critical Infrastructure Workers in the workplace (1) develop an action plan consistent with this guidance, as well as with any state, local, or other requirements, to use in the event an employee is potentially exposed to COVID-19 or develops COVID-19 symptoms, and (2) provide appropriate training.  Employers should also be aware that many states and localities have additional COVID-19 related health and safety requirements that apply to essential businesses.  Employers also still need to comply with EEOC, OSHA, and other applicable requirements.


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