VDH Interim Guidance for Implementing Safety Practices for Critical Infrastructure Workers (Non-Healthcare) During Widespread Community Transmission in Virginia:  Meat and Poultry Processing Focus

Summary of recent changes:

  • November 16: updated hyperlinks, background and creating a COVID-19 plan sections
  • October 26: Updated close contact definition to align with updated CDC guidance
  • July 21: Updated close contact definition and return to work criteria to align with updated CDC guidance
  • June 22: Updated return to work criteria to align with VDH guidance for exposed household contacts
  • June 17: Included new CDC Guidance: Testing Strategy for Coronavirus (COVID-19) in High-Density Critical Infrastructure Workplaces after a COVID-19 Case Is Identified
  • June 8: Included return to work criteria for asymptomatic PCR-positive persons
  • May 26: Updated exposure definition to align with updated CDC exposure definition
  • May 11: Updated guidance for asymptomatic exposed workers

Background

Meat and poultry processing facilities are a component of the critical infrastructure within the Food and Agriculture sector. All meat and poultry processing facilities developing plans for continuing operations in the setting of COVID-19 occurring among workers or in the surrounding community should: 

  1. work directly with appropriate state and local public health officials and occupational safety and health professionals; 
  2. incorporate relevant aspects of CDC and VDH guidance, including but not limited to this document and the CDC’s Critical Infrastructure Guidance; and 
  3. incorporate guidance from other authoritative sources or regulatory bodies as needed.

Lessons learned from investigating early outbreaks of COVID-19 in meat and poultry processing facilities can also be applied to inform investigations in and recommendations for other food production and agricultural workplaces.

While functioning critical infrastructure is imperative during the response to COVID-19, critical infrastructure employers have an obligation to manage the continuation of work in a way that best protects the health of their workers and the general public. Employers are encouraged to create and maintain an updated COVID-19 response plan in accordance with the CDC’s COVID-19 Critical Infrastructure Sector Response Planning guidance and CDC’s Guidance for Businesses and Employers to Plan and Respond to Coronavirus Disease 2019 (COVID-19). Employers are also encouraged to work with state and local officials to coordinate on activities like worker communication, infection control and case investigation.

CDC’s critical infrastructure guidance advises that critical infrastructure workers may be permitted to continue work following potential exposure to COVID-19, provided they remain asymptomatic, have not had a positive test result for COVID-19, and additional precautions (such as measuring the employee’s temperature and assessing for symptoms of COVID-19 before each work shift [“pre-screening”], asking the employee to self-monitor for symptoms during their work shift, and wearing a cloth face mask) are implemented to protect them and the community. Reintegrating exposed, asymptomatic workers to onsite operations, while discussed in the critical infrastructure guidance, should not be misinterpreted as always being the first or most appropriate option to pursue in managing critical work tasks.

If a meat or processing plant worker is exposed, or potentially exposed to COVID-19, it is recommended that that worker self-quarantine for 14 days since the last potential exposure, if possible. This may be particularly helpful to decrease illness in the workplace if a worker has been assessed as exposed due to contact with a COVID-19 case within the employee’s household. 

For this population, an exposure (or potential exposure) is defined as having close contact with a person with COVID-19 while they were contagious*. Close contact includes:

  • being within 6 feet of a person who has COVID-19 for a total of 15 minutes or more over a 24-hour period, or
  • having exposure to a person with confirmed or suspected COVID-19’s respiratory secretions (e.g., coughed or sneezed on; shared a drinking glass or utensils; kissing); or
  • being a household contact of a confirmed or suspected case of COVID-19; or
  • providing care for a person with confirmed or suspected COVID-19.

*A person with COVID-19 is considered to be contagious starting from 2 days before they became sick (or 2 days before they tested positive if they never had symptoms) until they meet the criteria to discontinue isolation.

COVID-19 in Processing Plants

The virus is thought to spread mainly from person to person (either between people who are in close contact with one another or through respiratory droplets produced when an infected person coughs, sneezes, or talks). Recent studies indicate that people who are not showing symptoms can spread the virus, though people are believed to be the most infectious to others while they are symptomatic.

The work environment inside of processing plants, particularly processing lines and other areas in busy plants where workers have close contact with coworkers and supervisors, may contribute substantially to their potential exposures. The risk of occupational transmission of SARS-CoV-2, the virus that causes COVID-19, depends on several factors. Distinctive factors that affect workers’ risk for exposure to SARS-CoV-2 in meat and poultry processing workplaces include:

  • Distance between workers: Meat and poultry processing workers often work close to one another on processing lines. Workers may also be near one another at other times, such as when clocking in or out, during breaks, or in locker/changing rooms.
  • Duration of contact: Meat and poultry processing workers often have prolonged closeness to coworkers (e.g., for 10-12 hours per shift). Continued contact with potentially infectious individuals increases the risk of SARS-CoV-2 transmission.
  • Type of contact: Meat and poultry processing workers may be exposed to the infectious virus through respiratory droplets in the air – for example, when workers in the plant who have the virus cough or sneeze. It is also possible that exposure could occur from contact with contaminated surfaces or objects, such as tools, workstations, or break room tables. Shared spaces such as break rooms, locker rooms, and entrances/exits to the facility may contribute to their risk.
  • Other distinctive factors that may increase risk among these workers include:
    • A common practice at some workplaces of sharing transportation such as ride-share vans or shuttle vehicles, car-pools, and public transportation.
    • Frequent contact with fellow workers in community settings in areas where there is ongoing community transmission.

Creating a COVID-19 Plan

A qualified workplace coordinator should be identified who will be responsible for COVID-19 assessment and control planning. All workers in the facility should know how to contact the identified coordinator with any COVID-19 concerns. Infection control and occupational safety and health plans should apply to anyone entering or working in the plant (e.g., all facility workers, contractors, and others). 

Facility management should reach out to state and/or local public health officials and occupational safety and health professionals and establish ongoing communications to make sure they are getting relevant and up-to-date information concerning COVID-19. The workplace coordinators and management should also be aware of and follow all applicable federal regulations and public health agency guidelines. Worksite assessments to identify COVID-19 risks and prevention strategies should be done periodically as part of sound occupational health and public health practice. As part of these assessments, facilities should consider the appropriate role for testing and workplace contact tracing, and how such efforts can best be aligned with those of their local health department.

Prevention and Control Strategies

COVID-19 control strategies for critical infrastructure workers should be employed in a way that tailors to the individual processing plant while adequately protecting workers. Worker infection prevention recommendations are based on an approach known as the hierarchy of controls. This approach groups actions by their effectiveness in reducing or removing hazards. In most cases, the preferred approach is to eliminate a hazard or processes; install engineering controls; and implement appropriate cleaning, sanitation, and disinfection practices to reduce exposure or shield workers. Administrative controls are also an important part of an approach to prevention in these workplaces.

Engineering Controls:

  • Configure communal work environments so that workers are spaced at least six feet apart, if possible. Current information about the asymptomatic spread of SARS-CoV-2 supports the need for social distancing and other protective measures within a meat and poultry processing work environment. Changes in production practices may be necessary in order to maintain appropriate distances among workers.
  • Modify the alignment of workstations, including along processing lines, if feasible, so that workers are at least six feet apart in all directions (e.g., side-to-side and when facing one another). Ideally, modify the alignment of workstations so that workers do not face one another. Consider using markings and signs to remind workers to maintain their location at their station away from each other and practice social distancing on breaks.
  • Use physical barriers, such as strip curtains, plexiglass or similar materials, or other impermeable dividers or partitions, to separate meat and poultry processing workers from each other, if feasible.
  • Facilities should consider consulting with a heating, ventilation, and air conditioning engineer to ensure adequate ventilation in work areas to help minimize workers’ potential exposures.
  • If fans such as pedestal fans or hard mounted fans are used in the facility, take steps to minimize air from fans blowing from one worker directly at another worker. Personal cooling fans should be removed from the workplace to reduce the potential spread of any airborne or aerosolized viruses. If fans are removed, employers should remain aware of, and take steps to prevent, heat hazards.
  • Place handwashing stations or hand sanitizers with at least 60% alcohol in multiple locations to encourage hand hygiene.
    • Install touchless faucets, soap dispensers, paper towel dispensers and trash recepticles, where possible.
    • Provide single-use paper towels at all handwashing stations. Avoid air hand dryers, which may disperse virus particles in the air.
    • Choose hand sanitizer stations that are touch-free.
    • See OSHA’s Sanitation Standard (29 CFR 1910.141), which requires employers to provide handwashing facilities for workers.
  • Add additional clock in/out stations, if possible, that are spaced apart, to reduce crowding in these areas. Consider alternatives such as touch-free methods or staggering times for workers to clock in/out.
    • Mark out 6-foot distances (or circles) for workers to stand in while they wait to punch in.
    • Alternatively, create methods for employee time-tracking other than using a common time-clock.
  • Remove or rearrange chairs and tables, or add partitions to tables, in break rooms and other areas workers may frequent to increase worker separation. Identify alternative areas to accommodate overflow volume such as training and conference rooms, or using outside tents for break and lunch areas.
  • Create separate shift entry and exit points to avoid unnecessary comingling of staff.
  • Remove unnecessary doors, turnstiles, or other physical barriers to increase circulation and decrease high touch areas.
  • Noise levels in production areas might require the use of hearing protection. Consider devising a method of non-verbal communication using sign language or pictograms for the most common communications to facilitate worker communication while maintaining physical distance.

Administrative Controls:

Employers should do the following to promote social distancing:

  • Encourage single-file movement with a six-foot distance between each worker through the facility, where possible.
  • Mark out a 6-foot line in front of supervisor/management desks.
  • Designate workers to monitor and facilitate distancing on processing floor lines.
  • Stagger break times or provide temporary break areas and restrooms to avoid groups of workers gathering during breaks. Workers should maintain at least six feet of distance from others at all times, including on breaks.
    • Consider putting up tents with tables so employees can spread out at break and lunchtimes.
  • Have in-person meetings only when needed. Limit the number of people in attendance and maintain 6-foot distancing between participants as much as possible.
  • Stagger workers’ arrivals and departure times to avoid congregations of workers in parking areas, locker rooms and near time clocks.
  • Try to keep people in one production area as much as possible to avoid population mingling and increased exposure risk.
  • Restrict access to plant areas to only those who need to be there.
  • Encourage workers to avoid carpooling to and from work, if possible.
  • If carpooling or using company shuttle vehicles is a necessity for workers, the following control practices should be used:
    • Limit the number of people per vehicle as much as possible. This may mean using more vehicles or making multiple trips.
    • Encourage employees to maintain social distancing as much as possible.
    • Encourage employees to use hand hygiene before entering the vehicle and when arriving at the destination.
    • Encourage employees in a shared van or car space to wear cloth face masks that cover the nose and mouth.
    • Clean and disinfect commonly touched surfaces after each carpool or shuttle trip (e.g., door handles, handrails, seatbelt buckles).
    • Encourage employees to follow coughing and sneezing etiquette when in the vehicle.
    • Encourage cohorting those who ride share such that the same group rides together consistently.
  • Encourage the message that social distancing needs to continue at home and in the community as well as in the workplace.
  • Provide ongoing training to all management, supervisors and workers. All training should be easy to understand and provided in languages that are understood by the worker. Training may need to be verbal. Options include pre-shift briefings or refresher training in settings where social distance can be maintained. Training topics should include symptoms of COVID-19, how it spreads, risks for workplace exposures, and how workers can protect themselves at work and in the community.

Employers may determine that processing or production lines, shifts, and staggering workers across shifts would help to maintain overall meat and poultry processing capacity while measures to minimize exposure to SARS-CoV-2 are in place. For example, a plant that normally operates on one daytime shift may be able to split workers into two or three shifts throughout a 24-hour period. In meat and poultry processing plants, one shift may need to be reserved for cleaning and sanitization.

Monitor and respond to absenteeism at the workplace. Implement plans to continue essential business functions in cases of higher than usual absenteeism.

Consider employee incentive and support measures to increase the likelihood that sick employees and employees at increased risk for severe illness will stay home:

  • Educate workers about reporting illness to their supervisors and the importance of not coming to work while ill.
  • Institute flexible workplace and paid time off policies that are shared with all workers. Relax attendance policies and suspend any putative actions associated with missed work.
  • Employers that do not currently offer sick leave to some or all of their employees should consider drafting non-punitive “emergency sick leave” policies.
  • Remove high risk employees from work AND offer leave of absence with pay.
  • Analyze sick leave policies and consider modifying them to make sure that ill workers are not in the workplace. Make sure that employees are aware of and understand these policies.
  • Waive the short term disability waiting period to start immediately when an employee is diagnosed with COVID-19.
  • Analyze any incentive programs and consider modifying them so that employees are not penalized for taking sick leave if they have COVID-19.
  • Additional flexibilities might include giving advances on future sick leave and allowing employees to donate sick leave to each other.
  • Assess workforce and staffing needs with self-quarantine in mind to see how exposed workers might be able to stay home or work in a way that allows for social distancing for 14 days after exposure.
  • Support workers who meet the definition of close contact so that they can quarantine at home (as opposed to continuing to work if asymptomatic). For instance, help with income, food and social needs to support up to 2 weeks of quarantine.
  • Encourage workers to share their place of work with the health department to facilitate contact tracing and let them know that doing this will not result in punitive action. Further, employees should be encouraged to share the specific section(s) of the plant they work in so that contact tracing can be effective.
  • Encourage workers to allow the health department to share their name with their employer to make contact tracing easier.
  • Help secure isolation housing for symptomatic workers who need to be isolated but cannot isolate themselves adequately at home.

Consider cohorting (grouping together) workers. This can increase the effectiveness of altering the plant’s normal shift schedules by making sure that groups of workers are always assigned to the same shifts with the same coworkers. Cohorting may reduce the spread of workplace SARS-CoV-2 transmission by minimizing the number of different individuals who come into close contact with each other over the course of a week. Cohorting may also reduce the number of workers quarantined because of exposure to the virus.

Establish a system for employees to alert their supervisors if they are experiencing signs or symptoms of COVID-19 or if they have had recent close contact with a suspected or confirmed COVID-19 case.

  • In addition to general illness reporting procedures, have a plan as to where an employee who becomes sick while at work can be isolated until they can be safely transported to their home or other location where they will continue to isolate until illness resolves.

Provide workers access to soap, clean running water, and single use paper towels for handwashing.

  • Consider installing touch-free faucets, soap dispensers and hand towel dispensers, if not already in place.
    • Air hand dryers may disperse virus particles in the air.
  • Provide alcohol-based hand sanitizers containing at least 60% alcohol if soap and water are not immediately available.
  • Place hand sanitizers in multiple locations to encourage hand hygiene. If possible, choose hand sanitizer stations that are touch-free.
  • Consider other workplace programs to promote personal hygiene, such as:
    • building additional short breaks into staff schedules to increase how often staff can wash their hands with soap and water or use hand sanitizers with at least 60% alcohol;
    • educating workers that cigarettes and smokeless tobacco use can lead to increased contact between potentially contaminated hands and their mouth, and that avoiding these products may reduce their risk of infection.

Workers should be educated to avoid touching their faces, including their eyes, noses, and mouths, particularly until after they have thoroughly washed their hands upon completing work and/or removing personal protective equipment (PPE).

CDC recommends wearing cloth face masks as a protective measure in addition to social distancing (i.e., staying at least 6 feet away from others). Masks are especially important when social distancing is not possible or feasible based on working conditions.

  • A cloth face mask may reduce the amount of large respiratory droplets that a person spreads when talking, sneezing, or coughing. People may or may not not know that they have the virus that causes COVID-19 (asymptomatic infection). Masks may prevent people with the virus that causes COVID-19 from spreading it to others.
  • Cloth face masks are not PPE. They are not appropriate substitutes for PPE such as respirators (like N95 respirators) or medical facemasks (like surgical masks) in workplaces where respirators or facemasks are recommended or required.
  • While wearing cloth face masks is a public health measure intended to reduce the spread of COVID-19, it may not be practical for workers to wear a single mask for the full duration of a work shift (e.g., eight or more hours) in a meat or poultry processing facility if they become wet, soiled, or otherwise visibly contaminated during the work shift.
    • Employers should provide readily available clean masks (or disposable facemask options) for workers to use when the masks become wet, soiled, or otherwise visibly contaminated.
  • Employers should ensure that employee masks:
    • fit over the nose and mouth and fit snugly but comfortably against the side of the face;
    • are secured with ties or ear loops;
    • include multiple layers of fabric;
    • allows for breathing without restriction;
    • can be laundered using the warmest appropriate water setting and machine dried daily after the shift, without damage or change to shape (a clean mask should be used each day);
    • are not used if they become wet or contaminated;
    • are replaced with clean replacements, provided by employer, as needed;
    • are handled as little as possible to prevent transferring infectious materials to the cloth; and
    • are not worn with or instead of respiratory protection when respirators are needed.

Educate and Train Employees and Supervisors

Supplement workers’ normal and required job training (e.g., training required under OSHA standards) with additional training and information about COVID-19, including recognizing signs and symptoms of infection, and ways to prevent exposure to the virus. Signage educating workers about infection prevention and control strategies can complement this training. The CDC has additional information about effective sign strategies and provides basic signage translated into multiple languages as a resource for employers.

Consider utilizing a variety of ways to utilize signs and convey key messages about COVID-19 to workers. Examples might include signage on bulletin boards, in common areas, electronic communications, or having messages printed on disposable placemats that workers use in dining areas.

Prepare employees for changes in operations that may need to occur due to COVID-19. Examples include:

  • Cross-training workers to perform essential functions to maintain operations.
  • Assessing essential functions and how operations will be carried out with a reduced workforce.
  • Developing a communications plan to share information daily to reinforce educational messages, provide updated information about the number of confirmed cases at the plant, and to share updates about steps being taken to keep the workers safe, including testing and contact tracing.
  • Educating workers about reporting illness to their supervisors and the importance of not coming to work while ill.
  • Working with health department officials to distribute information about COVID-19, how it is transmitted and the importance of social distancing, handwashing and other measures to prevent illness. Consider using media resources available to the plant, such as closed circuit TV in breakrooms and/or posted written materials in locker rooms or other common areas, to emphasize the importance of this information.

Cleaning and Disinfection

Increased cleaning and disinfection are important to decrease the amount of virus in the environment. Refer to List N on the EPA website for EPA-registered disinfectants that have qualified under EPA’s emerging viral pathogens program for use against SARS-CoV-2.

  • Increase staffing for cleaning and disinfection, and increase the frequency of these activities.
  • Clean and disinfect all areas such as offices, bathrooms, common areas and shared electronic equipment routinely.
  • Conduct targeted, more frequent cleaning of high-touch areas and shared spaces (e.g., time clocks, bathroom fixtures, stair railings, break room tables and chairs, locker rooms, vending machines, railings, door handles and computers).
  • If tools are used by multiple workers – disinfect between shared use.
  • If a worker becomes ill at work, pay special attention to cleaning and disinfecting the areas where that person was working. Follow the guidance entitled cleaning and disinfecting your building or facility if someone is sick with the CDC’s guidelines for cleaning and disinfecting your facility.
  • Check that you are following label directions and observing contact times.
  • Ensure the facility is adequately ventilated and use air filters in systems where this is feasible and that ventilation systems blow clean air in the worker’s breathing zone.

Employee Self-Monitoring

VDH recommends that ALL critical infrastructure/essential personnel, regardless of known exposure, self-monitor for symptoms under the supervision of their employer’s occupational health program. Key points related to self-monitoring include:

  • In Virginia, there is currently increased community transmission occurring throughout the state. The recommendation for essential personnel to self-monitor their health should be implemented until the risk of COVID-19 in Virginia communities decreases.
  • A VDH monitoring log is available (optional) to assist with self-monitoring.
  • All businesses/employers should request that their staff self-monitor for illness even in the absence of a formal, onsite occupational health program.
  • On days that workers are scheduled to work, the employer’s occupational health program could consider measuring employee temperature and assessing for symptoms prior to starting work/before each shift.
  • Employers should consult with their local health department regarding COVID-19 activity in the community and any planned changes in employee monitoring.

Employee Screening

Screening meat and poultry processing workers for COVID-19 symptoms (such as temperature checks) is another strategy that employers may use as part of their COVID-19 prevention and control plan. Symptom screening will not identify workers with asymptomatic or pre-symptomatic infections, but may help to keep those with illness (and therefore are presumably more infectious) out of the workplace. When presenting for work, have the employer’s occupational health program administer a verbal screening questionnaire and record the worker’s temperature. Ensure that screeners are trained to use temperature monitors and monitors are accurate under conditions of use (such as cold temperatures) and that screeners wear appropriate PPE.

  • The occupational health program may be located onsite or remotely.
  • If the employer does not have an occupational health program, determine if there are remote occupational health resources (e.g., telemedicine) available, or the employer can designate an individual responsible for administering the screening questionnaire and recording results.
  • If the employer employs <5 people or is located in a rural area, the operator may assume the responsibility of verbal screening and documenting the screening after receiving training. In these situations, workers should take their temperature before arriving at work and report the findings to the operator.
  • Screening communication should ideally be done in a language the worker can readily understand and be at an appropriate literacy level. Images to depict common signs and symptoms might be considered as a screening option if there are language barriers.
  • Consider posting screening questions in the most commonly spoken languages at the screening point to assist with this process.

Questions to consider for verbal screening of employees include:

“YES or NO, since your last time at work have you had any of the following?”

  • A new fever (100.4 F or higher), or a sense of having a fever?
  • A new cough that you cannot attribute to another health condition?
  • New shortness of breath that you cannot attribute to another health condition?
  • New chills that you cannot attribute to another health condition?
  • A new sore throat that you cannot attribute to another health condition?
  • New muscle aches that you cannot attribute to another health condition, or that may have been caused by a specific activity (such as physical exercise)?
  • A new loss of taste or smell?

“YES or NO, in the last 4 hours have you:”

  • Taken any fever reducing medication?

If a worker answers YES to any of the above screening questions, the employer should:

  • Immediately isolate the ill worker from others and ask them to wear a face mask.
  • Determine if the worker needs medical care.
    • Most cases of COVID-19 are mild and do not require medical care. In these situations, workers can self-isolate at home. If the worker is severely ill, then refer to a healthcare facility and call ahead to the facility before arrival.
  • Contact the occupational health program (if available) or supervisor.

Critical Infrastructure Workers Potentially Exposed to COVID-19

If a meat or processing plant worker is exposed, or potentially exposed to COVID-19, it is recommended that that worker self-quarantine for 14 days since the last potential exposure. This may be particularly helpful to decrease illness in the workplace if a worker has been assessed as exposed due to contact with a COVID-19 case within the employee’s household.

If self-quarantine is not possible, because of the negative impact this would have on maintaining critical business operations, the worker may continue to work as long as additional safety precautions, as described in CDC guidance, are implemented (including wearing a face mask) and the worker remains asymptomatic.

  • Reintegrating exposed, asymptomatic workers to onsite operations, while discussed in the critical infrastructure guidance, should not be misinterpreted as always being the first or most appropriate option to pursue in managing critical work tasks. Home quarantine is the preferred option for exposed workers.
  • Additional safety precautions include measuring the employee’s temperature and assessing for symptoms of COVID-19 before each work shift (“pre-screening”), asking the employee to self-monitor for symptoms during their work shift, and wearing a cloth face mask.
  • If resources are not available to measure worker’s temperatures, employers may rely on verbal screening questionnaires.

If symptoms develop, or if the worker subsequently tests positive for COVID-19, the worker must stop working immediately and self-isolate.

  • Employers are encouraged to have a plan for where workers who become ill while at work can be isolated at the workplace while waiting to be transported to either their home, alternate isolation facility (if the home environment can not facilitate appropriate isolation from others), or to a healthcare facility.
  • Employers are encouraged to adopt flexible sick leave policies.

Testing Exposed Workers after a COVID-19 Case is Identified

Early experience from COVID-19 outbreaks in a variety of settings suggests that when symptomatic workers with COVID-19 are identified, there are often asymptomatic or pre-symptomatic workers with SARS-CoV-2 present at the workplace. Testing is important to identify such individuals, as they may not know they are infected. SARS-CoV-2 transmission from asymptomatic or pre-symptomatic persons can result in additional cases and potentially outbreaks of COVID-19. Implementing screening for symptoms of COVID-19, testing, and contact tracing may be used to detect infected workers earlier and exclude them from the workplace, thus preventing disease transmission and subsequent outbreaks. Workers include, but are not limited to, all employees, contractors, and others who perform work at the facility or worksite.

After a COVID-19 case is identified, testing strategies for exposed co-workers may be considered to help prevent disease spread, to identify the scope and magnitude of SARS-CoV-2 infection, and to inform additional prevention and control efforts that might be needed. Viral (nucleic acid [PCR] or antigen) testing should be used to diagnose acute infection. Testing practices should aim for rapid turnaround times in order to facilitate effective action.

Viral testing detects infection at the time the sample is collected. Very early infections at the time of sample collection might test negative and not be identified. Similarly, those who are exposed to SARS-CoV-2 after the time of sample collection can go on to develop infection. Testing at different points in time, also referred to as serial testing, may be more likely to detect acute infection among workers with repeat exposures than testing done at a single point in time.

Different testing strategy options exist for exposed co-workers when public health and employers determine testing is needed to help support existing disease control measures. When planning to use a testing strategy for COVID-19 infection in exposed and potentially exposed workers, consider:

  • A testing strategy should only be implemented if results will lead to specific actions.
    • When a confirmed case of COVID-19 is identified, interviewing and testing potentially exposed co-workers should occur as soon as possible to reduce the risk of further workplace transmission.
  • A comprehensive approach to reducing transmission is recommended. Positive test results indicate the need for exclusion from work and isolation at home.
  • A risk-based approach to testing co-workers of a person with confirmed COVID-19 may be applied. Such an approach should take into consideration the likelihood of exposure, which is affected by the characteristics of the workplace and the results of contact investigations.
    • Examining facility and operations work records, conducting walk-throughs, and employee interviews can aid in categorizing co-workers into three tiers of risk and guide testing priorities. Prioritization should be done quickly so that testing of co-workers is not delayed.
    • If ongoing screening for symptomatic workers or contact tracing identifies additional workers who test positive, the algorithm should be also applied to their contacts.
    • If test results indicate infection among workers in multiple areas of the facility or among workers who worked on multiple shifts, then testing may need to be expanded accordingly.
  • Implementation of testing strategies can supplement other measures to reduce transmission in the workplace while keeping the workplace open. If employers elect to conduct facility-wide testing, multiple asymptomatic workers with SARS-CoV-2 infection may be identified. Employers should have a plan for meeting staffing needs while these persons are out of the workplace per COVID-19 Critical Infrastructure Sector Response Planning.
    • A testing strategy should enhance existing disease prevention measures by augmenting the ability to detect infection among asymptomatic or pre-symptomatic workers. For all testing strategies, waiting for test results prior to returning to work is preferred to keep infected workers out of the workplace.
  • Testing might be performed by different organizations, including the public health department, an employee health clinic, a healthcare provider engaged by the employer, or local health care facilities.
    • Symptom screening, testing, and contact tracing must be carried out in a way that protects confidentiality and privacy, to the extent possible, and is consistent with applicable laws and regulations. To prevent stigma and discrimination in the workplace, make employee health screenings as private as possible. Follow guidance from the Equal Employment Opportunity Commission regarding confidentiality of medical records from health checks.
    • Symptom screening upon entry to the workplace should be designed so that the screening process is conducted in as private a manner as possible, without a worker’s personal information being overheard or communicated inappropriately at any time. Because OSHA’s Access to Employee Exposure and Medical Records standard (29 CFR § 1910.1020) requires that covered employers retain medical records for the duration of employment plus 30 years, consider the burdens and benefits of documenting individually identifiable results of entry screenings. Healthcare providers that are covered entities under the Health Insurance Portability and Accountability Act (HIPAA) must abide by HIPAA rules. Due to the “direct threat” posed by COVID-19 to co-workers, healthcare providers who test workers for COVID-19 as described in this guidance should notify employers of tested workers’ fitness for duty, workplace restrictions (e.g., restrictions on ability to enter the worksite, limitation to telework, etc.), and the need for contact tracing of other workers deemed to be in close contact, even if this might allow employers to surmise that employees might have COVID-19. However, providers should not share employees’ test results or diagnoses with employers without employees’ permission, even though at entry screening, employers may ask all employees who will be physically entering the workplace if they have COVID-19, or symptoms associated with COVID-19, or ask if they have been tested for SARS-CoV-2.
    • Providers should report and explain test results to workers and notify the local health department of cases in a timely fashion. When employers become aware of cases, the Recording and Reporting Occupational Injuries and Illnesses standard (29 CFR part 1904), may require certain employers to keep a record of serious work related injuries and illnesses, including work related COVID-19.
    • Contact tracing should be carried out in a way that protects the confidentiality and privacy of an employee with COVID-19, or a SARS-CoV-2 positive test, to the degree possible.

Critical Infrastructure Workers with COVID-19 Illness

VDH recommends that ALL employers within the critical infrastructure sector develop a plan for healthcare support if a worker becomes ill. Symptoms of COVID-19 include fever, chills, muscle pain, headache, cough, sore throat, shortness of breath, and new loss of taste or smell. Workers with signs and symptoms of COVID-19 illness should self-isolate immediately to avoid spreading disease to others. Most people with COVID-19 develop mild to moderate illness, and do not require medical care. In these situations, workers can self-isolate at home. If a worker needs medical care, a healthcare facility other than a hospital emergency room should be used, unless a worker is severely ill. Those who are severely ill should seek care at a local hospital emergency room or dial 911 for medical emergencies. If a worker needs medical care, it is recommended to call ahead to that facility or hospital to describe the situation, especially if there is a concern for COVID-19.

Other workers who might have had close contact with the sick worker should be identified. Those who had close contact (as described in the exposure definition above) with the sick person while the person was symptomatic and for 48 hours prior to symptom onset should be included in a line list of potentially exposed persons. Strategies regarding the management of potentially exposed coworkers are described above and should be implemented in consultation with your local health department.

Housing Considerations for Essential Personnel

If the employer provides housing, ill workers must be separated from well persons. In these situations:

  • Discuss worker grouping options that are available for the operation.
    • Ideally, each ill person should have a private room and a dedicated bathroom.
    • If this is not feasible and there is more than one ill worker, then ill workers may be grouped together, but separated from non-ill workers.
    • For ill individuals, consider using a large, well-ventilated room. In areas where ill workers are staying, keep beds at least 6 feet apart, use temporary barriers between beds (such as curtains), and request that ill persons sleep head-to-toe.
  • Provide care to the worker while sick and recovering.
  • Follow CDC recommendations for cleaning and disinfection of the home or facility.

If the employer does not supply housing, then ill workers should self-isolate at home. An employee’s living situation may be such that it is difficult to appropriately isolate from other people while ill. This has the potential to facilitate additional exposures within the home environment and subsequently promote community transmission. In these instances, employers may want to consider sequestering employees in separate living facilities, such as hotels, where employees can reside in single rooms with single bathrooms and are supported to stay in their rooms by providing wraparound services such as food delivery. Helping workers maintain social distancing while not at work can help to protect the workforce and, by extension, protect continuity of operations.

Return to Work Criteria

A person with confirmed or probable COVID-19 is considered to be no longer infectious (and can therefore be released from isolation) when the following criteria are met:

  • at least 10 days have passed since symptoms first appeared; and
  • there is no fever for at least 24 hours without the use of fever-reducing medicine; and
  • other symptoms have improved.

A person who tested PCR-positive for COVID-19, but never developed symptoms of illness, can return to work 10 days after the date of the positive diagnostic test.

A test-based strategy to guide the discontinuation of isolation is generally no longer recommended. For persons with severe immunocompromise, a test-based strategy for the discontinuation of isolation could be considered, in consultation with infectious disease experts.

Persons advised to self-quarantine due to potential COVID-19 exposure and remain healthy should be allowed to return to work at the end of their 14-day quarantine period.

  • When self-quarantine is not possible due to workforce capacity needs in critical infrastructure, personnel filling essential critical infrastructure roles (as defined in CISA Framework) may continue to work following potential COVID-19 exposure, provided they remain asymptomatic and additional precautions (such as measuring the employee’s temperature and assessing for symptoms of COVID-19 before each work shift [“pre-screening”], asking the employee to self-monitor for symptoms during their work shift, and wearing a cloth face mask) are implemented to protect them and the community.

When an employee is caring for a person with COVID-19 or living in the same household as a person with COVID-19, there can be ongoing exposure. The caregiver or household member should ideally self-quarantine (or wear a face mask and follow the CDC Guidance if continuing to work) until 14 days after the person with COVID-19 has been released from isolation.

  • Note: This means that the household contacts may need to remain at home longer than the initial person with COVID-19. This is because exposure is considered to be on-going within the household.
  • If a worker is able to have complete separation from the person in the home with COVID-19 (this means no contact, no time together in the same room, no sharing of any spaces, such as same bathroom or bedroom), then they can return to work 14 days after their last exposure.

Workers’ Rights

Section 11(c) of the Occupational Safety and Health Act of 1970, 29 USC 660(c), prohibits employers from retaliating against workers for raising concerns about safety and health conditions. Additionally, OSHA’s Whistleblower Protection Program enforces the provisions of more than 20 industry-specific federal laws protecting employees from retaliation for raising or reporting concerns about hazards or violations of laws. OSHA encourages workers who suffer such retaliation to submit a complaint to OSHA as soon as possible in order to file their complaint within the legal time limits, some of which may be as short as 30 days from the date they learned of or experienced retaliation. An employee can file a complaint with OSHA by visiting or calling his or her local OSHA office; sending a written complaint via fax, mail, or email to the closest OSHA office; or filing a complaint online. No particular form is required, and complaints may be submitted in any language.

OSHA provides recommendations intended to assist employers in creating workplaces that are free of retaliation and guidance to employers on how to properly respond to workers who may complain about workplace hazards or potential violations of federal laws. OSHA urges employers to review its publication Recommended Practices for Anti-Retaliation Programs.

Page last reviewed: November 30, 2020