Contact Tracing under CDC Revised Definition for “Close Contact”

Since the start of COVID-19 being in the workplace, many employers who have had an exposure have engaged in an investigation or type of contact tracing to determine who else the exposed worker was around and would be considered exposed at the work place. There are several reasons employers engage in contact tracing such as safety of workers, protection of further spread among the work force and loss of productivity, identification of safety concerns not being followed, limiting liability and meeting expectations of federal, local or state health department guidelines. Of course during the COVID-19 Pandemic, the EEOC has openly stated that the Americans with Disabilities Act even under the pandemic rules will not allow for disclosure of the employee’s name so employers have been forced to work backward in contact tracing from the exposed individual themselves in order to maintain confidentiality.

Employers interviewing the COVID-19 positive employee generally ask such questions as where they were in the facility, who did they talk to or come in contact with and what did they physically touch. Due to the person being exposed, these interviews often times are being conducted by text, phone, or video conference and timing can be critical. Often times this interview is based in part on the “close contact” definition from the CDC so the employer can identify other potentially exposed individuals.

The most recent definition of “close contact” prior to the recent revision stated that a COVID-19 exposure or “close contact” was defined when someone is within 6 feet of the infected person for 15 minutes or more and that the exposure could occur 48 hours before the onset of symptoms.

Under the revised definition of the CDC, a “close contact” is someone who was within 6 feet of an infected person for a cumulative total of 15 minutes or more over a 24-hour period* starting from 2 days before illness onset (or, for asymptomatic patients, 2 days prior to test specimen collection) until the time the patient is isolated. This may seem like a slight adjustment initially upon reading, but it is significant in the sense that the CDC is basing this change on a study where someone was determined to have been exposed and contracted COVID-19 from an individual they were not around for a total of 15 minutes in a block of time but a cumulative exposure of 15 minutes over a 24 hour period. Depending on how closely employers have been following the COVID-19 “close contact” definition by the CDC, this could obviously change the questioning in a contact tracing situation and change the identified individuals that were determined to be exposed. Employers should consider revisiting their policies and procedures based on this revised definition. Also note that the CDC states on their website, “Data are limited, making it difficult to precisely define close contact.” Further information, can always be found on the CDC website here.