The Centers for Disease Control and Prevention (CDC) recently updated its definition for close contact in its COVID-19 guidelines. As a result, employers should immediately reevaluate both their social distancing protocols and their contact tracing protocols to ensure full compliance with CDC standards.

The updated definition clarifies that it is contact within 6 feet of an infected person for a cumulative total of 15 minutes or more over a 24-hour period. Further, close contact is relevant for contact tracing start two days before the onset of symptoms through the time the infected person is removed from the workplace. Likewise, close contact with asymptomatic individuals will trigger exclusion based on qualifying contact up to two days prior to the asymptomatic individual’s positive COVID-19 test. As a result of these changes, employers should evaluate two key issues.

First, the change to a cumulative approach for assessing close contact may require changes to employer social distancing policies. To date, many employers have based their policies around the concept that limited, incidental close contact does not trigger an exclusion obligation. With this new definition, those same contacts can trigger exclusion if they aggregate to 15 minutes in a 24-hour period. For instance, employers should evaluate whether additional measures are needed in elevators, passageways, printers, and other places where brief encounters are more likely to occur.

Second, under the CDC’s guidelines, contact tracing must be conducted for close contacts of laboratory-confirmed or probable COVID-19 patients. The new CDC guidelines expand both the type of qualifying contact and the period of qualifying contact. As a result, employers may need to revise their current contact tracing program to look further back following a given incident and questionnaires or other means of interviewing potentially affected individuals should be revised to capture cumulative time rather than discrete 15 minute contact events.

If you have any questions about the CDC’s new definition for close contact or how it affects your company, Reed Smith’s experience Labor & Employment Group is ready to speak with you.