7 Steps to Take When an Employee Has COVID-19

by | Aug 24, 2020 | Employee Benefits

While many experts thought the summer months would bring a reprieve, COVID-19 cases have continued to rise in the United States, and as a result, more employers are dealing with employees testing positive for the coronavirus. Here are the 7 steps to take when addressing a positive COVID-19 case in the workplace:

Step 1: Isolate & Quarantine the Infected Employee

Be sure to instruct the infected employee to remain at home until released by a physician or public health official. If a doctor’s note releasing the employee is unavailable, follow the CDC guidelines on when an employee may discontinue self-isolation, which contain specific requirements dependent upon whether the employee tested positive for COVID-19 and/or exhibited symptoms.

Step 2: Address Employees Who Were In Close Proximity to the Infected Employee

Under guidance of the CDC, you should notify all non-critical infrastructure workers who worked in close proximity to the infected employee that they may have been exposed and send them home for 14 days to ensure the infection does not spread. While quarantined, you should instruct employees to self-monitor for symptoms, avoid contact with high-risk individuals, and seek medical attention if symptoms develop.

The CDC has developed alternative Guidelines for Critical Infrastructure Workers. If you are an essential business, asymptomatic employees who have been directly exposed to a confirmed case of COVID-19 can continue to work if certain guidelines are met.

Step 3: Conduct Contact Tracing

After learning that one or more employees has been diagnosed with COVID-19, it’s important to act quickly, and to have the infected employee identify all other employees and/or third parties who might have been exposed during the infectious period. Ask the infected employee to identify all individuals who fall into what’s known as the “6-15-48 zone.” That means those who worked in “close proximity” (within six feet) for a prolonged period of time (15 minutes or more) with the infected employee during the 48-hour period before the onset of symptoms. For more information please view the CDC Guide to Handling Exposure.

In addition to speaking to the infected employee, consider using apps and technology to help with your contact tracing efforts.

Step 4: Investigating & Reporting

OSHA recently unveiled new record keeping requirements requiring covered employers to make an increased effort in determining whether they need to record and report confirmed coronavirus cases in the workplace. To ensure compliance, you should document your efforts to determine if the positive COVID-19 case was work-related. In most situations, once you learn of an employee’s COVID-19 illness, you should:

  • Ask the infected employee how they believe they contracted the COVID-19 illness.
  • While respecting employee privacy, discuss with the infected individual their work and out-of-work activities that may have led to the COVID-19 illness.
  • Review the employee’s work environment for potential COVID-19 exposure.

Look to the surrounding evidence to aid your efforts. OSHA’s guidance highlights that certain types of evidence weigh in favor of or against work-relatedness. For example, when there is no alternative explanation, a case is likely work related:

  • When several cases develop among workers who work closely together.
  • If it is contracted after lengthy, close exposure to a customer or coworker who has a confirmed case of COVID-19.
  • If an employee’s job duties include having frequent, close exposure to the general public in a locality with widespread transmission.

If you make a reasonable and good faith inquiry but cannot determine whether it is more likely than not that exposure in the workplace played a role in the confirmed case of COVID-19, the agency says that you do not need to record the illness.

You should also check local and state guidance to determine if there are other investigation, reporting, or recording obligations triggered by a positive COVID-19 case. For example, the Los Angeles County, California Order mandates that employers with knowledge of three or more positive COVID-19 cases among employees within a 14-day span must report the COVID-19 “outbreak” by telephone to the Department of Public Health.

Click to view information about COVID-19 Outbreak in the Workplace.

Step 5: Clean & Disinfect the Workplace

After a confirmed COVID case, make sure to follow CDC guidelines for cleaning and disinfecting the workplace. Cleaning staff or third-party sanitation contractors should clean and disinfect all areas. This means offices, bathrooms, and common areas used by the ill person, focusing especially on frequently touched surfaces.

If using cleaners other than household cleaners with more frequency than an employee would use at home, ensure workers are trained on the hazards of the cleaning chemicals used in the workplace and maintain a written program in accordance with OSHA’s Hazard Communication standard. Simply download the manufacturer’s Safety Data Sheet (SDS) and share with employees as needed, and make sure the cleaners used are on your list of workplace chemicals used as part of a Hazard Communication Program.

Step 6: Notify Other Employees Who Might Be At Risk

Following a confirmed COVID-19 case, be sure to notify all employees who work in the location or area where the employee works of the situation. Notification should be done without revealing any confidential medical information such as the name of the employee. You may obtain the employee’s signed authorization to disclose their diagnosis. Also notify any third parties that may have been exposed by the infected employee.

Inform employees and third parties of the actions you have taken, including requiring employees who worked closely to the infected worker to go home (if a non-essential business) and your sanitizing and cleaning efforts. Include a reminder about seeking medical attention if they exhibit symptoms. The failure to notify employees at your location of a confirmed case may be a violation of OSHA’s general duty clause, which requires all employers to provide employees with a safe work environment.

Step 7: Determine If The Infected Employee (and/or Others) Are Eligible For Paid Time Off

Last but not least, be sure to determine if the employee is eligible for paid time off under company policy, local, state, or federal guidelines. If you are a covered employer under the Families First Coronavirus Response Act (FFCRA), the infected employee may be eligible for emergency paid sick leave. Other potentially exposed employees may also be eligible for emergency paid sick leave. Make sure you maintain appropriate documentation for employees on leave.

As we all continue to monitor the rapidly developing COVID-19 situation, don’t hesitate to reach out to your United Agencies representative with any questions or concerns you may have about this important issue.


Dept. of Labor

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