Memo from State Public Health officer Dr. Sonia Y. Angell:
This checklist is intended for use by employers experiencing an outbreak of COVID-19 in their workplace. Employers should be proactive and keep in mind that identification of even a single positive case among employees may quickly develop into an outbreak. As outbreak circumstances and work practices vary, employers may need assistance from their local health department (LHD) to plan and coordinate a response to the outbreak that meets the needs of the workplace.
This guidance is not intended for use in managing or preventing outbreaks in healthcare, congregate living settings, or other workplaces where the California Aerosol Transmissible Diseases (ATD) standard applies.
Employers should also consult:
- CDC guidance for businesses and small businesses for information on preventing outbreaks;
- Cal/OSHA guidance to ensure that they are complying with legal requirements for worker protection; and
- the California statewide industry-specific guidance to reduce risk during and after reopening of businesses.
Employers should prepare for identification of COVID-19 outbreaks in their workplace.
- Designate a workplace infection prevention coordinator to implement COVID-19 infection prevention procedures and to manage COVID-related issues among employees.
- Instruct employees to stay home and report to the employer if they are having symptoms of COVID-19, were diagnosed with COVID-19, or are awaiting test results for COVID-19.
- Symptoms of COVID-19 include fever, chills, shaking chills, cough, difficulty breathing, sore throat, body or muscle aches, loss of taste or smell, loss of appetite, diarrhea, or loss of appetite.
- Develop mechanisms for tracking suspected and confirmed cases among employees.
- Ensure that sick leave policies are sufficiently generous and flexible to enable employees who are sick to stay home without penalty.
- California has additional services for employees, including supplemental paid sick leave for food sector workers at companies with 500 or more employees nationwide.
- The Families First Coronavirus Response Act requires certain employers to provide employees with paid sick leave or expanded family and medical leave for specified reasons related to COVID-19.
- Some cities and counties require employers to provide sick leave benefits to workers.
- Identify contact information for the local health department (LHD) in the jurisdiction where the workplace is located.
Employers should prepare to share information with the LHD and other stakeholders.
- Notify the LHD where the workplace is located if there is a known or suspected outbreak in the workplace or if there is a laboratory confirmed cases of COVID-19 at the workplace.
- The LHD in the jurisdiction where the workplace is located may have specific criteria for outbreak reporting requirements. Employers should follow the specific instructions of their LHD, if available.
- LHDs regularly transmit and protect confidential health information. Securely sharing confidential information about employees with COVID-19 is critical for the LHD to provide comprehensive support to the employer and protect the health of the community.
- Employees in a workplace may live in counties/jurisdictions outside of where the workplace is located. When there is an outbreak in a workplace, employers should contact the LHD in any jurisdiction where a COVID-19 positive employee resides and let them know about the outbreak.
- Typically, the LHD in the jurisdiction where the workplace is located gives guidance to the employer on managing the outbreak.
- Communicate with the LHD on how frequently the LHD expects updates from the employer on newly identified cases and symptomatic employees in the workplace.
- Determine how this information will be shared (e.g., telephone, fax directed to a specified person, secure e-mail)
- Share a roster of all employees with the LHD in the jurisdiction where the workplace is located.
- Employer may be asked by LHD to provide additional information on the employees, including job description, location, work schedule, city and county of residence, and other details that could help inform the investigation and determine which other employees in the workplace may be at risk of COVID-19 infection.
- If employees in a facility are unionized, identify a union contact and clarify the role the union can play in communication with employees. If employees in a facility are not unionized, identify an employee representative to serve as a point of contact for the LHD.
- If the facility uses contract or temporary employees, identify who should communicate information and instructions on the outbreak to these individuals.
- The host employer should notify temporary, contract, or other agencies that have employees in the workplace of the outbreak.
- All employees in the workplace, regardless of employment arrangement, should follow all instructions for infection prevention and outbreak management measures from the host employer, the LHD where the workplace is located, and the LHD where they reside.
Understand requirements for reporting employee cases to Cal/OSHA.
- Any serious injury, illness, or death occurring in any place of employment or in connection with any employment must be reported by the employer to the local Cal/OSHA district office immediately. For COVID-19, this includes inpatient hospitalizations and deaths among employees.
- Employers should report serious injury, illness, and death, including hospitalization and death from COVID-19, even if work-relatedness is uncertain.
- Cal/OSHA prefers calls by phone but will also accept email reports (Cal/OSHA Accident Report inbox). Details on reporting, contact information for district offices, and the Title 8 section 342 requirement are available online.
Identify additional employee cases and close contacts of cases to control further spread in the workplace.
- Testing all employees in a workplace should be the first strategy considered for identification of additional cases. Testing may be done at a single point in time or at repeated intervals.
- Employers should seek guidance from the LHD when developing a testing strategy, including how testing can be arranged and how to prioritize testing of employees (i.e., testing close contacts of laboratory-confirmed cases first).
- Employers should offer on-site COVID-19 testing of employees or otherwise arrange for testing through the company’s occupational or general medical services provider. The employer is responsible for ensuring all employees are offered and provided testing. Employers should also provide information to employees who may prefer to contact their personal medical provider or visit a CA Coronavirus Testing Task Force site for testing. LHDs may also be able to help facilitate testing options, if needed.
- When testing all employees is not available or not recommended by the LHD, consider alternative methods for controlling the outbreak, in consultation with the LHD, including but not limited to tracing all close contacts of confirmed cases and instructing those individuals to quarantine or temporarily closing the workplace and quarantining all employees.
- Conduct contact tracing and quarantining of close contacts of confirmed cases in the workplace.
- Employer should provide information to the LHD on the confirmed COVID-19 case employees in the workplace, including job titles, work areas, close contacts in the workplace, dates of symptom onset, and shifts worked while infectious.
- Establish if the employer, LHD, or both will conduct interviews of the cases to determine their close contacts.
- Close contacts should be instructed to quarantine at home for 14 days from their last known contact with the employee with COVID-19. Close contacts should be tested for COVID-19 when possible.
- A close contact is someone who spent 15 minutes or more within 6 feet of an individual with COVID-19 infection during their infectious period, which includes, at a minimum, the 48 hours before the individual developed symptoms.
- Interview employees with laboratory-confirmed COVID-19 by phone to determine when their symptoms began, the shifts they worked during their infectious period, and to identify other employees with whom they had close contact during their infectious period.
- Use employment records to verify shifts worked during the infectious period and other employees who may have worked closely with them during that time period.
- While at home, close contacts should self-monitor daily for COVID-19 symptoms (e.g., fever, chills, shaking chills, cough, difficulty breathing, sore throat, congestion or runny nose, fatigue, body or muscle aches, loss of taste or smell, nausea or vomiting, diarrhea, loss of appetite).
Notification and management of employees
- Employers must maintain confidentiality of employees with suspected or confirmed COVID-19 infection when communicating with other employees.
- Employers should notify all employees who were potentially exposed to the individuals with COVID-19. Employers should provide any healthcare consultations needed to advise workers regarding their exposure, which may be especially important for those with high-risk medical conditions (e.g., immune compromise or pregnancy).
- Close contacts of cases should be given instructions on home quarantine and symptom monitoring, and COVID-19 testing as described in step #4.
- Provide any employees who are sent home before or during a shift with information about what to expect after they are sent home (e.g., instructions about testing, sick leave rights under federal, state, and local laws and company policies, return-to-work requirements, etc.).
- In some outbreaks, but not all, employees who were never symptomatic and did not have close contact with any of the laboratory confirmed cases may continue to work, as long as the employer has implemented all control measures as recommended by public health authorities, Cal/OSHA, or other regulatory bodies. The LHD will make this determination based on strategies being used to control the outbreak and identify new cases.
Determine when it is appropriate for cases and contacts of cases to return to work
- Consult with the LHD and most recent CDC guidance for when a confirmed case may be released from home isolation and return to work. The local health department may recommend a strategy for return to work similar to the following, although some variation may occur by jurisdiction and outbreak.