What ALL Employers Must Know About The 6-15-48 Rule

By Obasi Bryant, ELS Summer Associate

On June 12, 2020, in anticipation of businesses opening back up across the country, the CDC provided updated guidelines on contact tracing in an effort to control the number of employees who may be exposed to COVID-19 in the workplace.

Four (4) Steps to Stop the Spread

According to the CDC, contact tracing is an effective four-step disease control strategy that includes: (1) Investigation, (2) Identification, (3) Support, and (4) Self-Quarantine. The strategy involves investigating diagnosed employees and their possible contacts and then interrupting the transmission of the disease by supporting those who have been in contact with the infected employee (“contact employees”) and asking them to quarantine at home for at least fourteen (14) days.

Investigations

The investigation mandates employers to help diagnosed employees recall everyone they have had close contact with during the infection period. The CDC defines a “close contact” as any individual who has been (a) within six (6) feet of an infected person; (b)  for at least fifteen (15) minutes; (c) starting from forty-eight (48) hours before the person began feeling sick until the time the person is isolated – The 6-15-48 Rule

Identification

Once 6-15-48 contacts have been identified, the employer must notify those contact employees of their possible exposure without releasing the identity of the employee who may have exposed them to COVID-19.  The idea is to protect and maintain the infected employee’s privacy while stopping the spread of the disease.

Support

The CDC also recommends that employers support its contact employees by disseminating information to them as soon as possible in order to help them understand their risks, what they should do to separate themselves from others who are not exposed, and how to monitor themselves for illness. Employers may also incorporate business practices that support its contact employees such as: implementing daily check-in calls, while respecting contact employees’ privacy, and giving contact employees’ scheduling flexibility.

Self-Quarantine

After an employer has followed the three previous steps, the CDC provides that the employer urge the 6-15-48 contact employees take the following measures:

  1. Self-quarantine for at least 14 days after last notification of possible exposure and maintains social distancing, at least six (6) feet, from others at all times; (2) Check temperature at least twice a day;
  2. Monitor for common COVD-19 symptoms including but not limited to: shortness of breath, fever or chills, cold, and cough; and
  3. Avoid exposure with people at higher risk for severe illness.

In conclusion, the CDC describes contact tracing as the key to addressing employee exposure in the workplace. Although COVID-19 is a novel virus, with adequate planning and execution employers can ensure that its employees are as safe as possible from those exposed to COVID-19 and can also prevent community spread of the virus.

Please consult ELS or an employment lawyer to get additional and specific information.

Sources:

https://www.shrm.org/resourcesandtools/hr-topics/employee-relations/pages/contact-tracing-employers.

https://hrexecutive.com/7-best-practices-for-supporting-employees-during-covid-19/

https://www.cdc.gov/coronavirus/2019-ncov/downloads/php/contact-tracing-CDC-role-and-approach.pdf