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In an April 20, 2020, update to its General Business Frequently Asked Questions, the U.S. Centers for Disease Control and Prevention (CDC) included some advice to employers on how to conduct employee temperature screens. While noting that there are several methods employers could utilize to conduct temperature screenings, the CDC provides three particular examples for employers to consider:

1. Social Distancing

Under this example, the CDC suggests that employers could structure screenings in a way that fully maintains social distancing. Employees would take their own temperatures before work or upon arrival. The person conducting the screening upon the employee’s arrival to work would stay at least six feet away from the employee at all times while (a) asking the employee to confirm verbally that the employee’s temperature is less than 100.4o F and that the employee is not coughing or experiencing shortness of breath; and (b) “mak[ing] a visual inspection of the employee for signs of illness, which could include flushed cheeks or fatigue.” Under this approach, the CDC states that screening personnel “do not need to wear personal protective equipment (PPE) if they can maintain a distance of 6 feet.”

2. Barrier/Partition Controls

Under this approach, screening personnel would “stand behind a physical barrier, such as a glass or plastic window or partition, that can protect the screener’s face and mucous membranes from respiratory droplets that may be produced when the employee sneezes, coughs, or talks.” The CDC recommends that “the screener should wash hands with soap and water for at least 20 seconds” (or use an alcohol-based hand sanitizer with at least 60 percent alcohol) upon arrival.

When screening employees, the screener would “[m]ake a visual inspection of the employee for signs of illness” and check the employee’s temperature with a thermometer. In this scenario, the CDC recommends the screener measure the employee’s temperature using the following steps:

  1. put on disposable gloves;
  2. reach around the partition (or through a hole in the partition) to use the thermometer but while keeping the screener’s face behind the partition at all times;
  3. use a clean pair of gloves between each employee unless the screener is using a disposable or non-contact thermometer and did not have physical contact with the employee;
  4. clean and disinfect thermometers in accordance with manufacturing instructions and any facility policies; and
  5. remove and discard all PPE (e.g., gloves) and wash hands with soap and water for at least 20 seconds (or use a hand sanitizer with at least 60 percent alcohol).

3. PPE

Where social distancing is not maintained and there is not a physical partition in place as with the above examples, the CDC states that screeners could visually inspect employees and measure their temperatures using the same procedures as outlined in the barrier/partition approach above, except wearing additional PPE for each screening. Specifically, the CDC advises the screener to “put on a facemask, eye protection (goggles or disposable face shield that fully covers the front and sides of the face), and a single pair of disposable gloves.” The CDC notes that a “gown could be considered if extensive contact with an employee is anticipated.” The CDC states the PPE should be removed and discarded after each screening, and screeners then should wash their hands for at least 20 seconds with soap and water (or use a hand sanitizer with at least 60 percent alcohol).

As employee temperature screening becomes more common across the country, employers may see differing or more detailed recommendations from state and local public health authorities, which should be considered when determining the company’s screening protocols.

Ogletree Deakins will continue to monitor and report on developments with respect to the COVID-19 pandemic and will post updates in the firm’s Coronavirus (COVID-19) Resource Center as additional information becomes available. Critical information for employers is also available via the firm’s webinar programs.


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