You know it’s the holiday season when the kids come home from college, the Griswolds take vacation, and Santa Claus comes to town. But for many, the most wonderful time of the year has become a cause for concern. With COVID-19 cases on the rise and family gatherings inevitable, you may be worried the virus will spread in your workplace faster than holiday cheer. Don’t have a blue Christmas—plan now to keep your workplace safe this season by revisiting your COVID-19 policies.
Review the Updated CDC Guidelines
As the medical community learns more about COVID-19, the CDC continues to update its guidance. For example, the CDC recently expanded the definition of a “close contact” to include more brief encounters. Before, “close contact” was defined as being within six feet of a confirmed positive COVID-19 case for 15 consecutive minutes or more. Now, “close contact” is defined as being within six feet of a confirmed positive case for a total of 15 minutes (see “Updated Definition of ‘Close Contact’” elsewhere in this blog).
The CDC also shortened the recommended length of quarantine time after exposure. Until recently, the CDC advised that individuals in close contact with a confirmed COVID-19 case should quarantine for 14 days. Though 14 days is still the gold-standard, the CDC now says that individuals who do not develop symptoms may end their quarantine after just 10 days, or even seven days if they test negative.
Employers should also be careful to review the latest guidelines issued by their state and local health departments. If there are discrepancies between state, local, and federal COVID-19 guidelines, talk with your attorney about how to best minimize your risk of liability. Make sure your workplace is following all applicable COVID-19 safety guidelines and update your policies accordingly.
Revisit Your Return-to-Work Policy
Before your employees head home for the holidays, it’s a good idea to revisit your COVID-19 return-to-work policy and remind employees of their safety obligations. At a minimum, employees should be advised to:
- Do their part to help prevent the spread of COVID-19 by frequent handwashing, social distancing, wearing a mask in public spaces, and staying home when they feel sick;
- Self-check for COVID-19 symptoms, including temperature-taking, before reporting to work each day and report any COVID-like symptoms to their supervisor; and
- Follow all applicable quarantine rules, especially those regarding COVID-19 symptoms, exposures, and travel restrictions.
Also, employers should decide before the holidays how to handle out-of-state or international travel. Travel restrictions vary from state to state, and most international destinations are still subject to mandatory quarantines. Given this, some employers may wish to limit employees’ out-of-state travel this holiday season; others may wish to adopt a strict quarantine policy after travel. If you want to adopt a travel policy, do so well before the holidays and with the advice of counsel, and enforce the policy consistently.
When possible, telework is a good option for employees after holiday break, whether they have traveled or not. Giving employees flexibility to work from home for a few weeks after the holidays could minimize the risk of spread in the workplace and help your company get off to a healthy start in the new year.
Now is the best time to protect your employees from an increased holiday spread of COVID-19. Before the hustle and bustle begin, revisit your COVID-19 safety protocols and return-to-work policies. Consult with counsel, update your policies as needed, and inform employees of their obligations. Provide telework and other flexible options when possible. And, have a safe and happy holiday season.