On October 21, 2020, the Centers for Disease Control and Prevention (“CDC”) updated its definition of “close contact” with an individual infected with the novel coronavirus (“COVID-19″). Under its previous guidance, the CDC defined “close contact” as 15 minutes of continuous contact with an individual with a confirmed case of COVID-19.
The CDC’s updated definition of “close contact” is now “someone who was within 6 feet of an infected person for a cumulative total of 15 minutes or more over a 24-hour period starting from 2 days before illness onset (or, for asymptomatic patients, 2 days prior to test specimen collection) until the time the patient is isolated.” This means, an individual exposed to an infected person for any increment of time totaling at least 15 minutes within a 24 hour period should quarantine and take additional protective measures.
Because of the limited data on COVID-19, the CDC states that it is “difficult to precisely define “close contact;” however, 15 cumulative minutes of exposure at a distance of 6 feet or less can be used as an operational definition for contact investigation. Factors to consider when defining close contact include proximity (closer distance likely increases exposure risk), the duration of exposure (longer exposure time likely increases exposure risk), whether the infected individual has symptoms (the period around onset of symptoms is associated with the highest levels of viral shedding), if the infected person was likely to generate respiratory aerosols (e.g., was coughing, singing, shouting), and other environmental factors (crowding, adequacy of ventilation, whether exposure was indoors or outdoors).”
Employers should update their COVID-19 procedures and policies to reflect this change and continue updating their procedures and policies as more information becomes available. Additionally, employers should make employees aware of this and any procedure and policy updates they implement. Employers who do not have COVID-19 procedures and policies need to consider creating and implementing one with both CDC and state specific guidelines.