Client Alert: CDC Releases Reopening Guidance

By Cesira Newcomb  •  April 29, 2020

As local, state, and federal authorities begin to endorse phased reopening plans in response to the COVID-19 pandemic, employers nationwide are considering how to “return to a new normal” in the workplace.  To assist employers, the CDC has released reopening guidance that focuses on cleaning and disinfecting public spaces, workplaces, businesses, and schools.

The guidance offers practical advice applicable to all employers with a physical workspace.  Some highlights are below:

• Develop a plan. Employers should develop a flexible plan with staff that addresses how (and how often) to clean and disinfect surfaces prior to and after reopening.  Surfaces and objects not frequently touched should be routinely cleaned with soap and water, but may not need to be disinfected.  On the other hand, frequently touched surfaces and objects like light switches and doorknobs need to be routinely cleaned and disinfected.  The CDC has released additional guidance regarding how to properly clean and disinfect.
• Returning to unoccupied areas. If your workplace, school, or business has been unoccupied for seven days or more, it will only need normal routine cleaning to reopen because COVID-19 has not been shown to survive on surfaces longer than this time.  Spaces that have not been unoccupied for seven days should be cleaned and disinfected as necessary prior to reopening.
• Regarding custodial staff. Employers’ plans should include considerations about the safety of custodial staff and other people who are carrying out the cleaning or disinfecting.  These staff should wear appropriate PPE for cleaning and disinfecting.  The CDC directs employers to OSHA’s website on “Control and Prevention” for additional information on concerns related to cleaning staff.
• Industry-specific guidance. The guidance contains several links to other industry-specific resources that contain more targeted recommendations for cleaning and reopening.  These include a detailed interim guidance for businesses and employers, guidance and FAQs for colleges and universities, and resources for healthcare facilities.
• Maintain safe behavioral practices. The CDC advises us all to continue safe behavioral practices including social distancing, frequent hand washing, wearing cloth face coverings, avoiding touching eyes, nose, mouth, and staying home when sick.  Employers should monitor updates to local, state, and federal guidance regarding reopening and alter their plans to conform to the guidance if necessary.