A change in the definition of “close contact” for purposes of COVID-19 exposure increases the number of people advised to quarantine following an exposure incident, creating an additional challenge for employers in dealing with positive cases.

The CDC released new guidance last week, updating “close contact” to mean someone who was within 6 feet of an infected person for a cumulative total of 15 minutes or more over a 24-hour period, from two days before illness onset or specimen collection until isolation. The prior definition required 6-feet proximity to an infected person for 15 consecutive minutes during this period.

The change comes as a result of an outbreak investigation related to a prison in Vermont. The investigation found that one infected employee most likely caught the illness during a series of relatively brief encounters with infected but asymptomatic inmates.

If an employee tests positive for COVID-19, an employer should identify all others who worked in “close contact” with the infected individual and advise those employees to self-quarantine. The expanded definition of “close contact” therefore creates a lower threshold for quarantine and may result in fewer employees available to work – especially for restaurants and other industries where employees move around often and may be in repeated “close contact” with multiple other employees for a few minutes at a time.

The CDC guidelines exempt critical infrastructure businesses from the quarantine recommendation, allowing asymptomatic but potentially exposed employees to continue working while self-monitoring and wearing a face mask. Masks are required in all Pennsylvania businesses, in any event.

Employers should review their COVID-19-related infection-control plans and update any contact-tracing questionnaires. In the event of an exposure event and in light of the difficulty of identifying close contacts, employers also may want to review clock-in documentation and security footage rather than simply rely on employee memories.

The Barley Snyder Employment Practice Group can assist you in creating a process for contact tracing or consulting on specific cases. If you have any questions or concerns, please contact me or reach out to anyone in the group.