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CDC’s Updated Definition of “Close Contact” with COVID-19 May Apply to More Employees[1]

By Paula Jackson

February 24, 2021


Employers have been tasked with investigating and identifying potential COVID-19 exposure among employees in the workplace through “contact tracing” to further eliminate the disease’s spread. Employers should be aware that the CDC’s definition of which persons are “close contacts” who must be traced and alerted of potential exposure has recently changed. The CDC’s revised definition of “close contact” has now been expanded to include being within 6 feet of an infected person for a combined total of 15 minutes within 24 hours.[2] The CDC indicated that this 24-hour period begins two days before the onset of illness (or two days before the date the specimen was collected for testing if the person was asymptomatic).


For example, employee Susan developed COVID-19 on the morning of February 22. Susan was within 6 feet of employee Ricky on three separate occasions from the 24 hours starting on February 20 at 11 am through February 21 at 11 am. However, each contact was only for 5 minutes. Under the CDC’s revised definition, Ricky may still be considered a “close contact” for purposes of potential exposure. Those small increments of time that he was within six feet of Susan two days before the onset of her illness can now be combined to equal 15 minutes of close contact with her within the appropriate 24-hour time frame.


According to the CDC, an employer of the general public should generally determine if a person qualifies as a “close contact” under this definition without regard to whether the employees involved were wearing masks or face coverings.[3]

[1]This article is for general informational purposes and is not intended to be and should not be taken as legal advice. It does not address standards for healthcare personnel or first responders, whom the CDC may treat differently. Please consult legal counsel for guidance in those areas. [2]See https://www.cdc.gov/coronavirus/2019-ncov/php/contact-tracing/contact-tracing-plan/appendix.html#contact. The CDC acknowledged that although it is difficult to “precisely define “close contact[]” due to limited data, “15 cumulative minutes of exposure at a distance of 6 feet or less can be used as an operational definition for contact investigation.” Id. According to the CDC, other “[f]actors to consider when defining close contact include proximity . . . , the duration of exposure . . . , whether the infected individual has symptoms . . . , if the infected person was likely to generate respiratory aerosols . . . , and other environmental factors . . . .” Id.

[3]Id.

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