The Centers for Disease Control and Prevention (CDC) has issued a guidance document titled “Testing Strategy for COVID-19 in High-Density Critical Infrastructure Workplaces after a COVID-19 Case is Identified,” which describes different testing strategy options for exposed employees when companies determine testing is needed to help support existing disease control measures.

Considerations for use of a testing strategy include:

  • A testing strategy that will lead to specific actions
  • A comprehensive approach to reducing transmission including quarantining
  • A risk-based approach to testing co-workers of an employee confirmed with COVID-19
    • Tier 1 – testing known exposed co-workers
    • Tier 2 – testing co-workers on the same shift but in different areas of the establishment
    • Tier 3 – testing co-workers who have shared common spaces such as break rooms, locker rooms, etc.
  • Testing strategy that can protect worker health while keeping the establishment open
  • Who performs the testing and privacy considerations
  • Leave policy which CDC recommends are flexible and consistent with public health guidance

An optional flow diagram of critical infrastructure testing can be found here and a detailed memo developed by Hogan Lovells covering the various aspects of the new guidance can be found here.