Return to Work: Are You Prepared When COVID-19 Tags Along?


Return to Work: Are You Prepared When COVID-19 Tags Along?

Getting back to business as usual might look a bit different these days. Whether you have employees who are subject to a quarantine or isolation order, employees who are reluctant to return to work, or employees who tested positive or have related symptoms, you need to respond appropriately to keep your workforce safe, while maintaining productivity. Read on to find out what you can do if COVID-19 tags along to work.


You have obligations to provide safe work and a safe workplace. Part of that likely involves taking steps to keep COVID-19 out of the workplace. One such way is to make sure that no one enters the workplace if they have or may have the disease. This can include screening employees (and visitors) before they enter the building.


In some jurisdictions, employers are mandated to screen employees before they enter the building, and this can include temperature scanning.

If you are required or wish to perform such screenings, you will need to determine which scanning equipment to use. Whichever methods you use to screen employees, they should be accurate and performed consistently.

Under the federal Americans with Disabilities Act, employees’ medical information must be kept confidential; therefore, any information about temperatures must be treated as confidential medical information and kept separate from the general personnel files. This means that you should not disclose to the entire workforce which employee tested positive or was exposed.

Designate who will be responsible for employees’ health information and determine which types of methods are used to collect the information, with consideration given to applicable state laws.

Employees who develop symptoms while at work are expected to come forward. The employees may be asked health-related questions and have their temperatures taken. Employees who are found to have COVID-19 symptoms as defined by a public health agency, should be isolated from the rest of the workforce and sent home.


Employees may be required to wear face coverings while at work (either all the time or in specific circumstances). Depending on an employee’s exposure to COVID-19, face masks may include cloth coverings, surgical masks, or N95 respirators.

Using a standard washing machine, cloth face masks should be routinely washed depending on the frequency of use. Employees should be careful not to touch their eyes, nose, or mouth when removing their face coverings and wash hands immediately after removing.


There are many ways for employers to create distance within the workplace, often at no extra cost. For instance, employers can easily establish one-directional hallways. They may also set limits on group numbers and duration of gatherings, such as in conference rooms, lunchrooms, and onsite fitness centers.

Staggering break or meal periods can also help minimize the number of people within a designated area during in between times. Common areas where employees congregate may be closed or expanded to allow for greater distances.

To further help facilitate distancing, open-office arrangements should be adjusted to allow for more space between workstations. As standard protocol to avoid spreading the disease, employees should maintain a six-foot distance from one another. This might mean that you have reconfigured your workplace to allow for this distance.

Apps have been developed to track the distance from each other and to alert the individual if the six-foot distance is breached. The information might even capture information about the other employee to help with contact tracing.

Designate someone at work (like a manager) who will be responsible for determining proper social distancing standards. This person will monitor social distancing at work and address any concerns or issues with employees who do not comply (whether unknowingly or willfully). To reduce the spread of germs, the designated person may also set limits and restrictions on nonessential work-related activities like shared treats, company picnics, social gatherings, celebrations, and potlucks.

Employees can be expected to comply with the standards set at work, as well as be prepared to adapt based on safety and health protocols. To maintain the highest level of health and safety at work, employers should encourage employees to follow all public health guidelines while off work.


Sometimes the best laid plans aren’t enough. No matter how you learn an employee has or may have COVID-19, you will need to respond appropriately. The Centers for Disease Control (CDC) and other public health agencies indicate that, if you learn of an employee’s exposure, you should not let that employee enter the workplace.

If the employee is already onsite, you are to separate the employee and send him or her home. Critical infrastructure workers may be allowed to continue work following potential exposure to COVID-19, provided they remain asymptomatic and additional precautions are implemented to protect them and the community.

An employee who had an exposure but remains asymptomatic should adhere to the following practices prior to and during a shift:

  • Pre-screen: Measure the employee’s temperature and assess symptoms prior to work. Ideally, temperature checks should happen before the individual enters the facility.
  • Regular monitoring: As long as the employee doesn’t have a temperature or symptoms, he or she should self-monitor under the supervision of your occupational health program.
  • Wear a mask: The employee should wear a face mask at all times while in the workplace for 14 days after last exposure. You may issue facemasks or approve employees’ supplied cloth face coverings in the event of shortages.
  • Social distance: The employee should maintain a six-foot distance and practice social distancing as work duties permit.
  • Disinfect and clean workspaces: Clean and disinfect all areas such as offices, bathrooms, common areas, and shared electronic equipment routinely.

If an employee becomes sick during the day, he or she should be sent home immediately. Surfaces in the workspace should be cleaned and disinfected. Information on persons who had contact with the ill employee up to two days prior to symptoms should be compiled. Others at the facility who came within six feet of the ill employee would be considered exposed.

Employees who have COVID-19 symptoms should notify their supervisor, stay home, and follow CDC-recommended steps. Employees should not return to work until the criteria to discontinue home isolation are met, in consultation with health care providers and public health agencies.

If an employee reports that a coworker looks ill, investigate and determine your next steps. If the coworker appears to have symptoms or reports symptoms, the coworker should be isolated and sent home. Contact tracing could follow. Employees who are well but who have a sick family member at home with COVID-19 should notify their supervisor and follow CDC-recommended precautions.


As part of the response to an employee being exposed, having symptoms, or testing positive, you may ask the employee the names of other coworkers to which the employee had close contact. If any are identified, they should be notified of the potential threat. You should also contact your local public health agency regarding the exposure.

Digital contact tracing tools are available and can help collection efforts. Some allow for electronic self-reporting and can use location data to identify contacts who might otherwise be unknown. Other tools might use employee cell phones to identify when they got within six feet of each other, but the employees would need to have their phones with them. Some apps will even anonymously contact anyone with which an employee breached the six-foot distance for a period of time.


If an employee is at the workplace and complains of feeling ill, immediately isolate the employee and send him or her home. Then, determine where the employee was in the workplace so the area can be cleaned and disinfected. This means that all items and surfaces that the employee could have come into contact with need to be addressed.

Examples of frequently touched surfaces and objects that will may need disinfection following possible contamination by the ill employee include:

  • Machinery or equipment
  • Tables
  • Doorknobs
  • Light switches
  • Countertops
  • Handles
  • Desks
  • Phones
  • Keyboards
  • Toilets
  • Faucets and sinks
  • Touch screens

If the ill employee was coughing excessively, that must be taken into consideration as droplets can travel and land on surfaces up to six feet away. Items or surfaces that have visible dirt on them need to be cleaned with soap and water before being disinfected.

Frequently touched surfaces and objects will need to be cleaned and then disinfected to further reduce the risk of germs. Follow these sanitizing steps:

  • First, clean the surface or object with soap and water.
  • Then, disinfect using an EPA-approved disinfectant.
  • If an EPA-approved disinfectant is unavailable, you can use one third cup of bleach added to one gallon of water, or 70 percent alcohol solutions to disinfect. Do not mix bleach or other cleaning and disinfection products together. Bleach solutions will be effective for disinfection up to 24 hours.

When you are cleaning or disinfecting a hard and non-porous material or item like glass, metal, or plastic, use an EPA-approved product. You can also use diluted household bleach solutions if appropriate for the surface.

Pay special attention to the personal protective equipment (PPE) that may be needed to safely apply the disinfectant and follow the manufacturer’s recommendations concerning any additional hazards. Always wear gloves appropriate for the chemicals being used for routine cleaning and disinfecting. In specific instances, personnel with specialized training and equipment may be required to apply certain disinfectants such as fumigants or fogs.


If an employee contracts COVID-19 at work, it must be treated as a work-related incident and recorded as such. An injury or illness is recordable on your OSHA 300 Log if it meets all three of the following conditions:

  1. It is work-related according OSHA’s definition in 29 CFR 1904.5
  2. It is new according to OSHA’s definition in 29 CFR 1904.6
  3. It meets one or more of the general recording criteria.

OSHA says that a case is work-related if an event or exposure in the work environment either caused or contributed to the resulting condition or significantly aggravated a preexisting injury or illness. Basically, if an injury or illness happened at work, or while the employee was doing work for the employer, the case will be work-related.

Per OSHA standards, if an exposure to the novel coronavirus in the workplace led to an employee’s illness, then it’s considered a “discernible cause.” In some cases, it may be easy to make this determination. Health care workers, for example, may be regularly exposed to people carrying the virus. In other cases, you may have an employee exposed to a coworker who tested positive for COVID-19. If the employee later becomes sick with COVID-19, that’s a discernible cause.

A “new” case, according to OSHA’s definition, is one that has not occurred before or that has occurred before, but the employee had recovered completely before an event or exposure in the workplace caused the signs and symptoms to reappear.

Work-related cases of COVID-19 would be new cases on your OSHA 300 Log. But if a sick employee who had been self-treating at home later needed to go to the hospital for medical treatment, or in the worst-case scenario, died, you would need to update your records with the new information. You would not consider it to be a new case.

An employee exposure to the illness in the workplace is not automatically recordable. The exposure must result in signs or symptoms of the disease and be confirmed by a laboratory test. In addition, it must meet one or more of the general recording criteria.

Once an employee exhibits signs and symptoms, however, you must begin counting the days. In a situation where an employer sends the employee home to self-quarantine, the best practice is to begin counting the case on your OSHA 300 Log when you send the employee home. That way, if the employee becomes ill with COVID-19, you have an accurate start date recorded. If the employee does not become ill, you may delete or line out the entry. Keep in mind that states may handle this differently.

If an employee is formally admitted to the hospital for in-patient care or treatment because of a work-related, diagnosed case of COVID-19, you must report it to OSHA. Worst-case scenario, if an employee dies because of a work-related case of COVID-19, the death must be reported to OSHA within eight hours. If an employee dies more than 30 days after the workplace exposure to COVID-19, you would not have to report the death to OSHA.

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