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EDMUND G. BROWN JR.
Governor

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


June 16, 2020


TO:
Local Health Departments

SUBJECT:
Responding to COVID-19 in the Workplace


This checklist is intended for use by local health departments (LHD) assisting workplaces experiencing an outbreak of COVID-19 in their jurisdiction. 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 applies.

LHDs and employers should also consult:

See Resources section at end 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 the Novel Virus inbox or calling the reporting hotline at 510-255-8922 and specifying a request for workplace outbreak assistance.

Because employers may have employees who live in different health jurisdictions, and because COVID-19 test results are reported to the local health department in which an individual resides, the jurisdiction in which a workplace is located may not receive reports of all COVID-19 cases among employees in that workplace. It is therefore especially important for local health departments to work with employers in their jurisdictions to establish clear expectations about reporting outbreaks at their workplaces to the local health department in the jurisdiction where the workplace is located, even if employees reside in other jurisdictions.

Outbreak Management

Local health departments should prepare for identification of COVID-19 outbreaks at workplaces in their jurisdiction.

  • Identify a point-of-contact at the LHD to receive communications from employers about COVID-19 outbreaks among employees.

    • An outbreak at a non-healthcare or congregate setting workplace is three or more laboratory-confirmed cases of COVID-19 among employees who live in different households within a two-week period. 

  • LHDs may be notified of residents in their jurisdiction who are employed in a workplace experiencing an outbreak, even if that workplace is within a different LHD's jurisdiction.

    • If an LHD is notified that a resident of their jurisdiction is employed in a workplace outside of their jurisdiction that is experiencing an outbreak, 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. 

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 employees in a facility are unionized, identify appropriate union contact or employee representative for the LHD and employer. Additionally, clarify the role of the union in the investigation and in communication with employees. If employees in a facility are not unionized, ask employer to identify an employee representative to serve as a contact for the LHD and employer.
  • Confirm the presence of contract or temporary employees in the facility and how communication and instructions will be communicated to these individuals and their employers.
  • LHD should request that employers share information (employee 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.

Understand requirements for reporting employee 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. For COVID-19, this includes inpatient hospitalizations and deaths among employees.

  • Employers should 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 (Cal/OSHA Accident Report Inbox). Details on reporting, contact information for district offices , and the Title 8 section 342 requirement are available online.

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

  • Testing all employees 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 employees (i.e., testing close contacts of laboratory-confirmed cases first, or employees who work in parts of the workplace with higher numbers of cases).
    • LHDs may also be able to help facilitate testing options, if needed. Employers should offer on-site COVID-19 testing of employees or otherwise arrange for testing through the company's occupational or general medical services provider. The employer is responsible for ensuring all employees are offered and provided testing. Employers should also provide information to employees who may prefer to contact their personal medical provider or visit a CA Coronavirus Testing Task Force site for testing.
  • When testing all employees 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 or temporarily closing the workplace and quarantining all employees. 
  • 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 employees 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 employee 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 employees 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 employees with whom they had close contact during their infectious period.
    • Use employment records to verify shifts worked during the infectious period and other employees 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., fever, chills, shaking chills, cough, difficulty breathing, sore throat, congestion or runny nose, fatigue, body or muscle aches, loss of taste or smell, nausea or vomiting, diarrhea, loss of appetite).

Notification and management of employees

  • LHD should emphasize the need to maintain confidentiality of employees with suspected or confirmed COVID-19 infection when communicating with other employees.

  • LHD should instruct the employer to notify all employees 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 and symptom monitoring, and COVID-19 testing as described in step #4. Employers should provide any employees 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, employees 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 employees 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)

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 employees who experienced symptoms of COVID-19 and employees who tested positive for COVID-19 but never had symptoms. The table below is updated per CDC guidance and CDPH Occupational Health Branch recommendations as of June 7, 2020.

 

 Employees

Minimum Criteria for Return to Work

(As of June 7, 2020)

CDC Reference Page

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

Symptomatic Positive

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

At least 3 days (72 hours) have passed since recovery, defined as resolution of fever without the use of fever-reducing medications and improvement in respiratory symptoms (e.g., cough, shortness of breath); and, at least 10 days have passed since symptoms first appeared.

 

Asymptomatic Positive

Employees 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

Employees 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

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

Employees 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 an employee in a critical infrastructure industry in which the essential operations of the workplace would be compromised by quarantine of the employee and no alternate staff can perform the same role.*  

Symptomatic Untested

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

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

 

 

Asymptomatic Untested

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

OR

Employees 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.

Employees 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 an employee 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 employee and no alternate staff can perform the same role.*

 

Employees 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 employees
    • employees who were close contacts to confirmed cases
  • Where 14-day quarantine would compromise essential operations, the LHD may determine that some employees in these two groups may return to work sooner than 14 days by considering certain criteria specific to the workplace and employee:
    • The employee is able to wear a surgical mask throughout the work day, 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 employee temperature and symptoms prior to starting work has been implemented, ideally before entering the facility.
    • Employee is able to self-monitor for temperature and symptoms prior to starting work.
    • Employee is able to maintain a minimum of six feet of distance from other employees in the workplace.
    • Physical barriers are in place between fixed employee 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 an employee's status at a single point in time only. If an employee 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.

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 employees 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 employees. 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 employees
  • Screening employees for illness, through symptom screening and/or temperature checks, periodic testing for SARS-CoV-2, or similar strategies
  • Providing employees with adequate sick leave to allow them to stay home from work if symptomatic

Additional Resources

CDC guidance

Cal/OSHA guidance

Governor's Office Resilience Roadmap guidance and employer checklists

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