Responding to COVID-19 in the Workplace
This checklist is intended for use by local health department (LHD) assisting employers in their jurisdictions who have identified cases of COVID-19 at
the workplace. In non-healthcare or non-residential congregate setting workplaces, an employer 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 LHD. While CDPH also defines
a workplace outbreak as three
or more cases identified within two weeks in individuals of different
households, LHDs may use epidemiological tracing methods to determine if the
cases in a workplace constitute an outbreak, and LHDs may set other criteria
for more detailed outbreak investigation. LHDs should report workplace outbreaks to CDPH via CalREDIE
or their usual reporting mechanism. As outbreak
circumstances and work practices vary, LHDs may need to tailor their
recommendations to meet the specific 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.
LHDs and employers should also consult:
See Resources section at end of document for links.
For
further assistance with COVID-19 outbreaks in workplaces, LHDs may seek
consultation from the California Department of Public Health,
Occupational Health Branch, by emailing novelvirus@cdph.ca.gov or calling the reporting hotline at 510-255-8922 and specifying a request for workplace outbreak assistance.
1. Local health departments should prepare for identification of COVID-19 cases at workplaces in their jurisdiction.
- Identify a point-of-contact at the LHD to receive communications from employers about COVID-19 cases among workers.
- An outbreak
at a non-healthcare or non-residential congregate setting workplace is
three or more laboratory-confirmed cases of COVID-19 among workers who
live in different households within a two-week period.
- This
outbreak definition aligns with the reporting threshold that employers
must use to notify the LHD. The LHD may determine that the case reports
from the workplace do not constitute an outbreak with epidemiological
links among cases.
- LHDs will be notified of
residents in their jurisdiction who are employed in a workplace with
three or more cases, even if that workplace is within a different LHD's
jurisdiction.
- If an LHD is notified that a resident of
their jurisdiction is a case in a workplace outside of their
jurisdiction , the LHD should notify the LHD where the workplace is
located of the case.
- Typically, the LHD in the jurisdiction
where the workplace is located manages the outbreak investigation, but
that LHD relies on other LHDs sharing information on their residents who
are employed in that workplace.
2. Local health departments should determine how information will be shared with partners.
- Confirm
with local health jurisdictions who have residents working in the
facility which LHD will be responsible for coordinating the outbreak
effort (typically the jurisdiction where the facility is located).
- Form
an agreement among jurisdictions about how information on new cases
will be shared for the investigation and documented in CalREDIE
(reported to CDPH).
- If workers in a facility are
unionized, identify an appropriate union contact or worker
representative for the LHD and employer. Additionally, clarify the role
of the union in the investigation and in communication with workers. If
workers in a facility are not unionized, ask the employer to identify a
worker representative to serve as a contact for the LHD and employer.
- Confirm
the presence of contract or temporary workers in the facility and how
communication and instructions will be communicated to these individuals
and their employers.
- LHD should request that employers
share information (worker roster, positive case reports, etc.) that is
vital to understand and control the outbreak and should establish an
agreement with the employer about the manner and frequency of providing
this information.
- In addition to local laws and
ordinances, it is recommended LHDs consider the following authorities
when deciding if and how information can be shared between the LHD and
employer or between LHDs:
- Health and Safety Code sections 120175, 120175.5, 120185, 120190, 120195, and 120205.
- Health and Safety Code sections 120275 through 120300 address violations of public health laws.
- If applicable (HIPAA-covered entities), Title 45 of the Code of Federal Regulation section 164.512; and
- Title 17 of the California Code of Regulations sections 2500, 2501, and 2505.
- Each
workplace is unique and operates under a variety of laws that govern
information and protocols to be followed. LHDs should coordinate with
their own personnel departments, legal departments, and labor unions (if
applicable) to appropriately adjust this general advice to a particular
industry.
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, contact information for district offices, and the Title 8 section 342 requirement 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.
- LHDs should
provide guidance on 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.
- LHDs
may also be able to help facilitate testing options, if needed.
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 for testing.
- When
testing all workers is not available or not recommended by the LHD,
consider alternative methods for controlling the outbreak, 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.
- LHD
should request information from the employer 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. Businesses may seek
guidance from the LHD if this is an appropriate measure for their
workplace.
- 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.
- 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. Notification and instruction to workers.
- LHD
should emphasize the need to maintain confidentiality of workers with
suspected or confirmed COVID-19 infection when communicating with other
workers.
- LHD should instruct the employer to notify all
workers who were potentially exposed to the workers 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. Employers should 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
(e.g., if mass testing is implemented in the workplace, some workers who
were not close contacts to confirmed cases may still be off work while
awaiting test results or if the workplace is closed due to the
outbreak).
7. Determine when it is appropriate for cases and contacts of cases to return to work.
- Consult
most recent CDC guidance for when a confirmed case may be released from
home isolation and return to work. This applies both to workers who
experienced symptoms of COVID-19 and workers who tested positive for
COVID-19 but never had symptoms. The table below is updated per CDC
guidance and CDPH Occupational Health Branch recommendations.
Symptomatic Positive Employees with symptoms who are laboratory confirmed to have COVID-19
| At
least 10 days have passed since symptoms first appeared; and 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. |
|
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.
|
|
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. |
|
- * 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.
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.
LHDs should clarify to
employers 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.
Multiple LHDs with residents employed in a
single workplace experiencing an outbreak should coordinate release from
isolation recommendations with each other and the employer to ensure a
standard approach.
8.
Ensure that employers are taking appropriate steps to reduce ongoing
transmission in the workplace, including appropriate infection control
and physical distancing measures. Additional detail on recommended
measures, both in general and by industry, are available in the
Additional Resources section at the end. General principles include:
- 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.
- Modifying
work processes to maximize physical distancing between workers. Six
feet distance is a minimum and does not prevent all transmission of
SARS-CoV-2.
- Enhanced cleaning and disinfection of work areas.
- Supporting respiratory and hand hygiene for workers.
- Screening
workers for illness, through symptom screening and/or temperature
checks, periodic testing for SARS-CoV-2, or similar strategies.
- Providing
workers with adequate sick leave to allow them to stay home from work
if symptomatic and ensuring 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.
- Communication
with workers regarding the importance of staying home when sick,
physical (social) distancing at home, outside the home, and at work,
appropriate hand and respiratory hygiene, etc.
- Recommend that
employers regularly check for and follow new and updated guidance on
their specific industry from the following sources:
- Governor's Office Resilience Roadmap
- Cal/OSHA
- CDC
Additional Resources
CDC guidance
Governor's Office Resilience Roadmap guidance and employer checklists
Originally Published on June 16, 2020