CDC Issues New Guidance for Return to Work of Critical Infrastructure Workers After Potential Exposure to COVID-19


On April 9, 2020, the Centers for Disease Control and Prevention (CDC) issued new guidance on how employers in certain essential businesses should respond to employees who have been exposed to COVID-19. In its 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 agency addressed critical infrastructure workers – those workers in sectors and industries identified by the Cybersecurity and Infrastructure Agency (CISA) as essential. In that many state stay-at-home orders exempt essential businesses, in whole or in part, by reference to the CISA list of critical infrastructure, the new CDC guidance applies to many employers who have remained in operation during the current pandemic. For asymptomatic critical infrastructure workers potentially exposed to COVID-19, the April 9 guidance emphasizes workplace screening, mask wearing, and other protective measures over any requirement to stay at home for 14 days. The new guidance does not apply to healthcare workers; they are subject to different guidelines.

The new guidance first defines “potential exposure” as household contact or close contact (within six feet) of an individual with confirmed or suspected COVID-19. The time frame for having had contact with the afflicted individual is 48 hours before the individual became symptomatic.

In the case of a critical infrastructure worker who has had exposure but remains asymptomatic, the CDC permits those employees to continue working, subject to the employer implementing the following measures:

  • Pre-Screen: Employers should measure the employee’s temperature and assess symptoms prior to starting work, ideally before the individual enters the facility.
  • Regular Monitoring: As long as the employee has no temperature or symptoms, he/she 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 face masks or can approve employees’ supplied cloth face coverings in the event of shortages.
  • Social Distance: The employee should maintain six feet and practice social distancing as work duties permit in the workplace.
  • Disinfect and Clean Work Spaces: Routinely clean and disinfect all areas such as offices, bathrooms, common areas, and shared electronic equipment.

The guidance goes on to advise that where the individual with confirmed or suspected COVID-19 is another employee, the employer should compile information on persons who had contact with the afflicted individual during the time the afflicted had symptoms and two days prior to the onset of symptoms. Employees who had close contact (within six feet) with the afflicted during that time period should be informed of their possible exposure, and the employer should implement the measures listed above.

CDC offers several additional considerations, all of which involve workplace practices which employers should implement (if they have not already):

  • Employees should not share headsets or other objects that are 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 air exchanges in rooms.
  • Employees should physically distance when they take breaks together. Stagger breaks, don’t congregate in the break room, and don’t share food or utensils.

The new CDC guidance further reminds employers to implement the recommendations in CDC’s Interim Guidance for Businesses and Employers to Plan and Respond to Coronavirus Disease 2019, last updated on March 21, 2020. The March 21 guidance included, by reference to separate CDC guidance Public Health Recommendations for Community-Related Exposure, advice that asymptomatic persons who had close contact with an individual with confirmed COVID-19 should stay home until 14 days after last exposure. Absent from CDC’s April 9 guidance on critical infrastructure workers is any reference to a 14-day stay-at-home requirement.

Takeaways for Employers

Workers exposed or potentially exposed to COVID-19, but who are asymptomatic: Employers in critical infrastructure sectors should follow the above-listed measures recommended by CDC in its April 9 guidance. For employers outside of CISA’s 16 critical infrastructure sectors, the new guidance offers a possible glimpse of what measures CDC may require for all businesses at such time when more workers are permitted to return to work, so employers should familiarize themselves with and begin preparing for these guidelines.

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