Following a definition change included with a recent California Department of Public Health (CDPH) order, Cal/OSHA has updated the definition of “close contact” for purposes of the current COVID-19 Workplace Emergency Temporary Standards (ETS).
Under the current ETS, “close contact” with a COVID-19 case is defined as follows:
“Close contact” means being within six feet of a COVID-19 case for a cumulative total of 15 minutes or greater in any 24-hour period within or overlapping with the infectious period defined by this section, regardless of the use of face coverings, unless close contact is defined by regulation or order of the CDPH. If so, the CDPH definition shall apply.
On June 8, CDPH issued its order, which also included an update to the definition of “close contact” as follows:
Close Contact is defined as someone sharing the same indoor airspace (e.g., home, clinic waiting room, airplane etc.) for a cumulative total of 15 minutes or more over a 24-hour period (for example, three individual 5-minute exposures for a total of 15 minutes) during an infected person's (laboratory-confirmed or a clinical diagnosis) infectious period.
Therefore, effective June 8, “close contact” under the Cal/OSHA ETS uses the same definition as CDPH (i.e., sharing the same indoor airspace) (See Cal/OSHA’s updated FAQs – Question 7 in the “Addressing COVID-19 Cases in the Workplace” section). This is a material change from the current 6 feet/15 minutes standard. This change has potentially significant implications for testing, notice, and exclusion under the ETS, especially for employers with larger facilities where employees share the same airspace. Special districts may wish to review and update existing policies. CDPH and Cal/OSHA also updated the definition of “infectious period” as specified.
Cal/OSHA’s draft COVID-19 Permanent Standard also incorporates the CDPH “indoor airspace” definition of “close contact.”
CDPH has provided FAQ guidance suggesting allowance for prioritizing response to exposure based on proximity and other factors (see "How should entities respond to a potential exposure when using this updated definition?"). However, ambiguities remain.
CSDA is engaged with its coalition partners and has joined a recent letter to Cal/OSHA seeking clarification of the “close contacts” definition. The coalition letter can be viewed here.
Look for future updates in CSDA’s Advocacy News or CSDA eNews.
#AdvocacyNews#FeatureNews#COVID-19#HumanResourcesandPersonnel#WorkplaceSafety