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EDMUND G. BROWN JR.
Governor

State of California—Health and Human Services Agency
California Department of Public Health


September 18, 2020


TO:
All Californians

SUBJECT:
Responding to COVID-19 in the Workplace for Employers



Click here for a pdf of the checklist

Released June 16, 2020                                                             

  • Revised on September 18, 2020 to:
  1. require all employers to notify local health departments when they meet the reporting threshold of three or more cases of COVID-19 in their workplace within a two-week period.
  2. align return to work criteria with updated guidance from CDC on release from isolation, issued on July 17, 2020.
  3. provide employers information on how COVID-19 exposure or infection in the workplace may impact operations.

Responding to COVID-19 in the Workplace

This checklist is intended for use by employers identifying cases of COVID-19 in their workplace. In non-healthcare or non-residential congregate setting workplaces, CDPH requires employers to report cases of COVID-19 to the local health department (LHD) in the jurisdiction in which they are located and the LHD where the infected workers reside. Employers must use the reporting threshold of three or more laboratory-confirmed cases of COVID-19 among workers who live in different households within a two-week period to notify the LHDs. Employers should be proactive and keep in mind that identification of even a single positive case among workers may quickly develop into a large outbreak. As outbreak circumstances and work practices vary, employers may need assistance from their LHD to plan and coordinate a response that meets the needs of the workplace.

This guidance is not intended for use in managing or preventing outbreaks in healthcare, congregate living settings, or other workplaces where the California Aerosol Transmissible Diseases (ATD) standard (title 8 section 5199) applies.

Employers should also consult:

Outbreak Management

1.   Employers should prepare for identification of COVID-19 cases in their workplace.

  • Designate a workplace infection prevention coordinator to implement COVID-19 infection prevention procedures and to manage COVID-related issues among workers.
  • Instruct workers to stay home and report to the employer if they are having symptoms of COVID-19, were diagnosed with COVID-19, or are awaiting test results for COVID-19.
    • Symptoms of COVID-19 include subjective or measured fever (>100.4°F or 38°C), chills, cough, shortness of breath, fatigue, muscle or body aches, headache, new loss of taste or smell, sore throat, congestion or runny nose, nausea, vomiting, or diarrhea.
    • Develop mechanisms for tracking suspected and confirmed cases among workers.
    • Ensure that sick leave policies are sufficiently generous and flexible to enable workers who are sick to stay home without penalty and ensure that workers are aware of such policies.
      • California has additional services for workers, including supplemental paid sick leave for food sector workers at companies with 500 or more workers nationwide. Covered employers must provide notice to their workers of this benefit.
      • The Families First Coronavirus Response Act requires certain employers to provide workers with paid sick leave or expanded family and medical leave for specified reasons related to COVID-19.
      • Some cities and counties require employers to provide sick leave benefits to workers.
  • Identify contact information for the local health department (LHD) in the jurisdiction where the workplace is located.

2.   Employers must prepare to share information with the LHD and other stakeholders. 

  • Employers must notify the LHD in the jurisdiction where the workplace is located if there is a known or suspected outbreak in the workplace. An outbreak in non-healthcare or non-residential congregate setting workplaces is defined as three or more laboratory-confirmed cases of COVID-19 among workers who live in different households within a two-week period. Employers are also encouraged to contact the LHD regarding any laboratory confirmed case of COVID-19 in the workplace.
    • The LHD in the jurisdiction where the workplace is located may have specific additional criteria for outbreak reporting requirements. Employers must follow the specific instructions of their LHD, if available.
    • LHDs regularly transmit and protect confidential health information. Securely sharing confidential information about workers with COVID-19 is critical for the LHD to provide comprehensive support to the employer and protect the health of the community.
  • Workers in a workplace may live in counties/jurisdictions outside of where the workplace is located. When the case reporting threshold is met, employers must contact the LHD in any jurisdiction where a COVID-19 positive worker resides and let them know about the outbreak.
    • Typically, the LHD in the jurisdiction where the workplace is located gives guidance to the employer on managing the outbreak.
  • Communicate with the LHD on how frequently the LHD expects updates from the employer on newly identified cases and symptomatic workers in the workplace.
    • Determine how this information will be shared (e.g., telephone, fax directed to a specified person, secure e-mail).
  • Share a roster of all workers with the LHD in the jurisdiction where the workplace is located.
    • An employer may be asked by the LHD to provide additional information on the workers, including job description, location, work schedule, city and county of residence, and other details that could help inform the investigation and determine which other workers in the workplace may be at risk of COVID-19 infection.
  • If workers in a facility are unionized, identify a union contact and clarify the role the union can play in communication with workers. If workers in a facility are not unionized, identify a worker representative to serve as a point of contact for the LHD.
  • If the facility uses contract or temporary workers, identify who should communicate information and instructions on the outbreak to these individuals.
    • The host employer should notify temporary, contract, or other agencies that have workers in the workplace of the outbreak.
    • All workers in the workplace, regardless of employment arrangement, should follow all instructions for infection prevention and outbreak management measures from the host employer, the LHD where the workplace is located, and the LHD were they reside.

3.   Understand requirements for reporting worker cases to Cal/OSHA.

  • Any serious injury, illness, or death occurring in any place of employment or in connection with any employment must be reported by the employer to the local Cal/OSHA district office immediately but not longer than 8 hours after the employer knows. For COVID-19, this includes inpatient hospitalizations and deaths among workers.
  • Employers must report serious injury, illness, and death, including hospitalization and death from COVID-19, even if work-relatedness is uncertain.
  • Cal/OSHA prefers calls by phone but will also accept email reports (caloshaaccidentreport@tel-us.com). Details on reporting (www.dir.ca.gov/dosh/coronavirus/Reporting-Requirements-COVID-19.html), contact information for district offices. (www.dir.ca.gov/dosh/districtoffices.htm), and the Title 8 section 342 requirement (www.dir.ca.gov/title8/342.html) are available online.

4.   Identify additional worker cases and close contacts of cases to control further spread in the workplace. 

  • Testing all workers in a workplace should be the first strategy considered for identification of additional cases. Testing may be done at a single point in time or at repeated intervals.
    • Employers should seek guidance from the LHD when developing a testing strategy, including how testing can be arranged and how to prioritize testing of workers. Examples of strategies may include testing close contacts of laboratory-confirmed cases first; prioritizing workers in parts of the workplace with higher case counts; or, if testing capacity is limited, sample pooled testing, also known as "group testing," should be conducted to obtain critical information about the extent of infection with fewer testing resources.
    • Employers should offer on-site COVID-19 testing of workers or otherwise arrange for testing through the company's occupational or general medical services provider. The employer is responsible for ensuring all workers are offered and provided testing. Employers should also provide information to workers who may prefer to contact their personal medical provider or visit a CA Coronavirus Testing Task Force site (testing.covid19.ca.gov) for testing. LHDs may also be able to help facilitate testing options, if needed.
  • When testing all workers is not available or not recommended by the LHD, consider alternative methods for controlling the outbreak, in consultation with the LHD, including but not limited to tracing all close contacts of confirmed cases and instructing those individuals to quarantine, conducting sample pooling (group testing), or temporarily closing the workplace and quarantining all workers.
  • Conduct contact tracing and quarantining of close contacts of confirmed cases in the workplace.
    • Employers must provide information to the LHD on the confirmed COVID-19 case workers in the workplace, including job titles, work areas, close contacts in the workplace, dates of symptom onset, and shifts worked while infectious.
    • Establish if the employer, LHD, or both will conduct interviews of the cases to determine their close contacts.
    • Close contacts should be instructed to quarantine at home for 14 days from their last known contact with the worker with COVID-19. Close contacts should be tested for COVID-19 when possible.
    • A close contact is someone who spent 15 minutes or more within 6 feet of an individual with COVID-19 infection during their infectious period, which includes, at a minimum, the 48 hours before the individual developed symptoms.
    • Interview workers with laboratory-confirmed COVID-19 by phone to determine when their symptoms began, the shifts they worked during their infectious period, and to identify other workers with whom they had close contact during their infectious period.
    • Use employment records to verify shifts worked during the infectious period and other workers who may have worked closely with them during that time period.
    • While at home, close contacts should self-monitor daily for COVID-19 symptoms (e.g., subjective or measured fever (>100.4°F or 38°C), chills, cough, shortness of breath, fatigue, muscle or body aches, headache, new loss of taste or smell, sore throat, congestion or runny nose, nausea, vomiting, or diarrhea). 

5.   Consider whether to temporarily suspend operations due to COVID-19 infection in the workplace

  • Businesses may elect to voluntarily suspend operations when a case of COVID-19, exposure to COVID-19, or an outbreak has occurred in the workplace. This would allow investigation of the exposure and thorough cleaning and disinfection. Businesses may elect to do this if the exposure is in a worker, customer, or visitor of the workplace. To understand more about if this decision is right for your business, you can contact your local health department (LHD) for guidance.
  • The LHD in the jurisdiction where the workplace is located has the authority to close business operations while an exposure is being investigated or an outbreak is being managed. Cal/OSHA also has authority to prohibit use and access of affected areas of a workplace if it identifies an imminent hazard to workers.
  • Criteria for making a determination for closure may include the size of the workforce, the number or percentage of the workforce impacted, the vulnerability of consumers who visit the business to severe COVID-19 infection, or many other local factors, including the epidemiology of disease spread in the community at large. 
  • LHDs may vary in their specific requirements for workplace outbreak investigations, reporting, and suspension of operations.

6.   Notify and provide instruction to workers.

  • Employers must maintain confidentiality of workers with suspected or confirmed COVID-19 infection when communicating with other workers.
  • Employers should notify all workers who were potentially exposed to the individuals with COVID-19. Employers should provide any healthcare consultations needed to advise workers regarding their exposure, which may be especially important for those with high-risk medical conditions (e.g., immune compromise or pregnancy).
  • Close contacts of cases should be given instructions on home quarantine, symptom monitoring, and COVID-19 testing.
  • Provide any workers who are sent home before or during a shift with information about what to expect after they are sent home (e.g., instructions about testing, sick leave rights under federal, state, and local laws and company policies, return-to-work requirements, etc.).
  • In some outbreaks, but not all, workers who were never symptomatic and did not have close contact with any of the laboratory confirmed cases may continue to work, as long as the employer has implemented all control measures as recommended by public health authorities, Cal/OSHA, or other regulatory bodies. The LHD will make this determination based on strategies being used to control the outbreak and identify new cases.

7.   Determine when it is appropriate for cases and contacts of cases to return to work.

  • Consult with the LHD and most recent CDC guidance for when a confirmed case may be released from home isolation and return to work. The local health department may recommend a strategy for return to work similar to the following, although some variation may occur by jurisdiction and outbreak.

 

 

Minimum Criteria for Return to Work

(As of September 18, 2020)

CDC Reference Page

(The most recent CDC guidance should be consulted prior to allowing the worker to return to work)

Symptomatic Positive

Workers with symptoms who are laboratory confirmed to have COVID-19

At least 10 days have passed since symptoms first appearedand at least 24 hours have passed since last fever without the use of fever-reducing medications; and symptoms (e.g., cough, shortness of breath) have improved.

For worker cases who did not require hospitalization: www.cdc.gov/coronavirus/2019-ncov/hcp/disposition-in-home-patients.html

For worker cases who require hospitalization: www.cdc.gov/coronavirus/2019-ncov/hcp/disposition-hospitalized-patients.html

Asymptomatic Positive

Workers who never had symptoms and are laboratory confirmed to have COVID-19 

A minimum of 10 days have passed since the date of their first positive COVID-19 test. If they develop symptoms, then the criteria for laboratory confirmed cases with symptoms apply.  

www.cdc.gov/coronavirus/2019-ncov/hcp/disposition-in-home-patients.html 

Symptomatic Negative

Workers who had symptoms of COVID-19 but test result returned negative

Use the same criteria for return to work as laboratory confirmed cases.  

Asymptomatic Negative

Workers who never had symptoms but were tested due to close contact with a laboratory-confirmed case patient and were negative

Workers should quarantine at home for 14 days after the last known close contact with the case patient. Symptoms can develop even after testing negative within 14 days after exposure. The LHD may consider allowing earlier return to work only for a worker in a critical infrastructure industry in which the essential operations of the workplace would be compromised by quarantine of the worker and no alternate staff can perform the same role.*  

Symptomatic Untested

Workers who had symptoms of COVID-19 but were not tested

Testing is highly recommended. If the worker cannot be tested, use the same criteria for return to work as laboratory confirmed cases.  

Asymptomatic Untested

Workers who had close contact to a laboratory-confirmed case patient at work, home, or in the community and do not have symptoms.

OR

Workers who refuse or are unable to be tested after close contact with a laboratory-confirmed case, despite recommendation for testing from LHD or healthcare provider, and do not have symptoms.

Workers should be quarantined at home for 14 days after the last known close contact with the case patient. Testing is highly recommended; if testing has not occurred, the LHD may consider allowing a worker who had close contact to a confirmed case to continue to work only in a critical infrastructure industry in which the essential operations of the workplace would be compromised by quarantine of the worker and no alternate staff can perform the same role.*

Workers who develop symptoms of COVID-19 while in quarantine should contact their healthcare provider. Even if they are not tested, the same criteria for return to work should be used as laboratory-confirmed cases.

www.cdc.gov/coronavirus/2019-ncov/hcp/disposition-in-home-patients.html

 

www.cdc.gov/coronavirus/2019-ncov/community/critical-workers/implementing-safety-practices.html

* Critical infrastructure workplace outbreak

  • asymptomatic negative workers
  • workers who were close contacts to confirmed cases

Where 14-day quarantine would compromise essential operations, the LHD may determine that some workers in these two groups may return to work sooner than 14 days by considering certain criteria specific to the workplace and worker:

    • The worker is able to wear a surgical mask throughout the workday, except while eating, and comply with all infection prevention procedures. A cloth face covering may also be used in the event of mask shortage.
    • The facility has implemented all best practice infection prevention procedures, as determined by the LHD.
    • Pre-screening to assess worker temperature and symptoms prior to starting work has been implemented, ideally before entering the facility.
    • Worker is able to self-monitor for temperature and symptoms at home and work.
    • Worker is able to maintain a minimum of six feet of distance from other workers in the workplace. Of note, six feet does not prevent all transmission of SARS-CoV-2.
    • Physical barriers are in place between fixed work locations to supplement distancing.
    • Cleaning and disinfection of all areas and shared equipment can be performed routinely in the workplace.

Be aware that testing reflects a worker's status at a single point in time only. If a worker tests negative, they may still develop COVID-19 infection from a recent or subsequent exposure and should be instructed to quarantine at home if that occurs. Testing may be needed at repeated intervals to capture all positive cases, especially if an outbreak is ongoing.

8.   Perform more frequent cleaning and disinfection, as well as deep/enhanced cleaning and disinfection after workers with COVID-19 have been at work.

  • Work areas of infected workers should not be entered by workers until they have been cleaned and disinfected with products approved by the EPA for COVID-19. Work should be performed by cleaning staff trained on their safe use and supplied with all required and recommended PPE.
  • Perform ongoing enhanced cleaning/disinfection of work areas when a worker with COVID-19 is identified, following CDC recommendations: www.cdc.gov/coronavirus/2019-ncov/community/organizations/cleaning-disinfection.html
  • Continue to identify and regularly clean and disinfect frequently touched surfaces throughout the workplace, such as doorknobs, equipment, and handrails.
  • Workers should not share headsets or other objects that may come into contact with their face, mouth, or nose.
  • Minimize sharing of other equipment between workers; for equipment that must be shared, conduct frequent cleaning between worker use.
  • Train workers on safe use of cleaners and disinfectants and provide necessary protective equipment.

9.   Employers should regularly check for and follow new and updated guidance on their specific industry from the following sources:

Additional Resources

CDC guidance:

Cal/OSHA guidance:

Governor's Office Resilience Roadmap guidance and employer checklists:

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