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Helpful Guidance from CDC/OSHA on Screening Workers for COVID-19 Symptoms

May 15, 2020Alerts

The Centers for Disease Control (CDC) and Occupational Safety and Health Administration (OSHA) have recently issued workplace safety guidance for workers and employers in the manufacturing industry. While the guidance goes into detail about steps manufacturing industry employers can take to minimize worker exposure to COVID-19, the section on screening and monitoring workers for COVID-19 symptoms may be helpful to all employers.

The following comes directly from the CDC Guidance:

Screening* and monitoring workers

Workplaces, particularly in areas where community transmission of COVID-19 is occurring, should consider developing and implementing a comprehensive screening and monitoring strategy aimed at preventing the introduction of COVID-19 into the work site. Consider a program of screening workers before entry into the workplace, criteria for exclusion of sick workers, including asymptomatic workers who have tested positive for COVID-19; and criteria for return to work of exposed and recovered (those who have had signs or symptoms of COVID-19 but have gotten better). This type of program should be coordinated to the extent possible with local public health authorities and could consist of the following activities.

Screening of workers for COVID-19

Screening manufacturing workers for COVID-19 symptoms (such as temperature checks) is an optional strategy that employers can use. If implemented for all workers, policies and procedures for screening workers should be developed in consultation with state and local health officials and occupational medicine professionals. Options to screen workers for COVID-19 symptoms include:

  • Screen before entry into the facility.
  • Provide verbal screening in appropriate language(s) [spoken by the employees] to determine whether workers have had symptoms including a cough, shortness of breath or difficulty breathing, fever, chills, repeated shaking with chills, muscle pain, headache, sore throat, and new loss of taste or smell in the past 24 hours.
  • Check temperatures of workers at the start of each shift to identify anyone with a fever of 100.4°F or greater (or reported feelings of feverishness). Ensure that screeners:
    • Are trained to use temperature monitors and monitors are accurate under conditions of use (such as cold temperatures); and
    • Wear appropriate PPE.
  • Do not let employees enter the workplace if they have a fever of 100.4°F or greater (or reported feelings of feverishness), or if screening results indicate that the worker is suspected of having COVID-19.
  • Encourage workers to self-isolate and contact a healthcare provider;
  • Provide information on the facility’s return-to-work policies and procedures; and
  • Inform human resources, employer health unit (if in place), and supervisor (so the worker can be moved off schedule during illness and a replacement can be assigned, if needed).

Protect Personnel that Screen Your Workers

Ensure that personnel performing screening activities, including temperature checks, are appropriately protected from exposure to potentially infectious workers entering the facility:

  • Implement engineering controls, such as physical barriers or dividers or rope and stanchion systems, to maintain at least 6 feet of distance between screeners and workers being screened.
  • If screeners need to be within 6 feet of workers, provide them with appropriate PPE based on the repeated close contact the screeners have with other workers.
    • Such PPE may include gloves, a gown, a face shield, and, at a minimum, a face mask.
    • N95 filtering facepiece respirators (or more protective) may be appropriate for workers performing screening duties and necessary for workers managing a sick employee in the work environment…if that employee has signs or symptoms of COVID-19. If respirators are needed, they must be used in the context of a comprehensive respiratory protection program that includes medical exams, fit testing, and training in accordance with OSHA’s Respiratory Protection Standard (29 CFR 1910.134).

* Employers should evaluate the burdens and benefits of recording workers’ temperatures or asking them to complete written questionnaires. These types of written products become records that must be retained for the duration of the workers’ employment plus 30 years. See OSHA’s Access to Employee Exposure and Medical Records standard (29 CFR 1910.1020).

This CDC guidance is intended for employers and employees in manufacturing industry. There are many industry-specific guidelines issued by the CDC and OSHA that may impose different or additional obligations for certain employers. Be sure to consult guidance pertinent to your industry as appropriate, as well as federal, state or local laws when you formulate your return-to-work plans.

For more information, please contact Lucy Li at 609.896.3600 or [email protected], or any member of Fox Rothschild LLP’s Labor & Employment Department.

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