Vigilant Blog

News, trends and analysis in employment law, HR, safety & workers' comp

Apr 09, 2020

CDC guidance on risk assessment continues to evolve

COVID-19Safety and Health 

The Centers for Disease Control and Prevention (CDC) has issued new guidance on when it’s okay for critical infrastructure workers to return to work after potential exposure to someone with confirmed or suspected COVID-19 (coronavirus). “Exposure” means the employee shares a household with an infected person, or was in close contact with them in the 48 hours before they began exhibiting symptoms. As long as the employee isn’t experiencing any symptoms themselves, here are the steps the CDC recommends you follow in order to return the employee to work:

  • Conduct a health screening before the employee’s shift each day. This includes checking the employee’s temperature and assessing symptoms. The CDC doesn’t specify what you should ask, but the Washington Department of Health has developed guidance that provides five questions for health screeners. If possible, try to set up this health screening area outside the workplace. (Note: It’s important to ensure that the health screening process itself doesn’t create new hazards by putting employees in close proximity to each other. Temperatures should be taken using non-contact or disposable thermometers, and the people conducting the health screenings should wear appropriate protection.)
  • Tell the employee to self-monitor for any COVID-19 symptoms and report symptoms immediately if they occur. The CDC says the employee should self-monitor “under the supervision of their employer’s occupational health program.” The CDC offers a poster which you can display as a reminder to these workers about what to do and not do in the workplace. If they develop symptoms, send them home immediately, clean and disinfect all surfaces in their work area, and identify anyone else at the facility who in the prior two days had close contact within six feet of the employee. Now those individuals are considered to be exposed, and you should follow the same “return to work” protocol for them as well.
  • Tell the employee to wear a mask in the workplace for 14 days after the last exposure. Interestingly, the CDC says employers may issue “facemasks” (without specifying what that means) or may “approve employees’ supplied cloth face coverings in the event of shortages.”
  • Require the employee to keep at least six feet away from others to the extent permitted by work duties.
  • Routinely clean and disinfect the employee’s work area as well as bathrooms, common areas, and any shared equipment.

The CDC also recently updated and split its risk assessment and mitigation guidance for COVID-19 into specific categories for travel, healthcare settings, and communities in general. These updates are significant because the CDC remains one of the primary sources of information for employers as we navigate actual or suspected COVID-19 situations. Some of the key takeaways from the updates include:

Travel: The current recommendation is to avoid all nonessential travel, but there aren’t any restrictions or isolation requirements on individuals who have traveled within the US.

Communities: For non-healthcare settings and travel situations, the communities page is now the primary source for navigating actual or suspected COVID-19 situations. Importantly, the new communities page goes beyond the original risk assessment and mitigation steps. For example, the guidance now includes a recommendation to stay home until 14 days after the last exposure for individuals who have had prolonged close contact (within 6 feet) with a person who has laboratory confirmed COVID-19 or a clinically compatible illness (i.e., someone with the symptoms). Although these recommendations aren’t mandatory, they’re the best advice we have from the highest public health authority.

What to do if symptoms develop: The communities page links to a helpful resource that covers steps to take if symptoms develop, What to Do if You Are Sick. This page also explains when it’s safe to discontinue home isolation after getting sick. For people who come down with COVID-19 symptoms but haven’t been tested to determine if they’re still contagious, the CDC says they may leave home if: (1) they have no fever for at least 72 hours (without using fever-reducing medication); (2) other symptoms have improved; and (3) at least 7 days have passed since their symptoms first appeared. People who have been tested can leave home if: (1) they no longer have a fever; (2) other symptoms have improved; and (3) they receive two negative tests in a row, 24 hours apart. The CDC notes that people who have been sick should follow the directions of their health care provider and local health department.

Tips For Employers: We strongly encourage you to bookmark and regularly review the CDC website. When you call us about a situation involving an employee who’s ill or traveled recently, you can count on these resources being the first thing we pull up, in addition to any local public health guidance. Because the CDC’s guidance continues to evolve, it’s important to keep up with the latest developments on their website.

This article has been revised to reflect the following correction:
Correction: May 13, 2020
A hyperlink to the CDC’s new guidance was added in the first sentence (

This website presents general information in nontechnical language. This information is not legal advice. Before applying this information to a specific management decision, consult legal counsel.