Why Do Employers Need Touchless Thermometers, Protective Gown/Clothing and Face Shield in Addition to Gloves and Face Masks?

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Wilmerhale.com recently posted an article on the on-site body temperature tests.  See the full article here https://www.wilmerhale.com/en/insights/client-alerts/20200403-screening-employee-temperatures-what-employers-need-to-know

Below is a quick summary of the key points.  The takeaway is that Thermometers, protective clothing and face shield may likely be required for on-site temperature tests in the near future. 

The U.S. Equal Employment Opportunity Commission (EEOC) has re-issued its guidance, confirming specifically that the COVID-19 pandemic permits employers to measure employees’ body temperatures before allowing them to enter the worksite.  The U.S. Centers for Disease Control and Prevention (CDC) also has issued COVID-19 specific guidance urging workplaces located in communities with minimal to moderate COVID-19 risk to implement regular health checks, including temperature and respiratory symptom screening.

Given the increased focus on this particular preventive measure, it is important for employers to ensure that when they take employees’ temperatures, they do so safely.  However, none of the EEOC, CDC, or the Occupational Safety and Health Administration (OSHA) has yet issued guidance on a process or requirements specific to temperature checks.  It is crucial for employers implementing temperature checks to review emerging requirements, including guidance from state and local health authorities.

If an employer is required by a state or local order to conduct on-site temperature tests (or elects to do so), the employer still has options to minimize risk.  One approach is to have employees self-administer tests at designated locations on-site and show the reading to a test facilitator, who determines if the temperature is elevated and has the authority to send home affected employees. Another, more involved, approach is for the employer to administer the test.  In either case, OSHA requires the employer to evaluate reasonably anticipated hazards and assess the risks to which workers may be exposed.  Although OSHA has not yet issued recommendations specific to temperature taking, it has issued general COVID-19 workplace guidance, which was the subject of a prior alert.

That OSHA guidance established categories of worker COVID-19 exposure and related risk.  Although that analysis is workplace specific, it is most conservative to treat temperature test facilitators or administrators as a high/very high exposure risk since they likely will be in close proximity to a large number workers, including potentially infectious individuals.  Workers in that risk category must be supplied with appropriate personal protective equipment (PPE).  OSHA advises that such workers likely need to wear gloves, a gown, a face shield or goggles, and either a face mask or a respirator (e.g., an N95 filtering facepiece), depending on their job tasks and exposure risks.  Employers should review OSHA’s PPE standards at 29 CFR 1910 Subpart I and Respiratory Protection standard, 29 CFR 1910.134 for selection, training, and other applicable requirements, but from a basic process standpoint, test facilitators/administrators should take the following steps: (1) perform hand hygiene; (2) don appropriate PPE; (3) check temperature; (4) remove and properly discard PPE; and (5) perform hand hygiene.  Employers also should ensure that hand hygiene facilities (e.g., sink or alcohol-based hand rub) are readily available at or adjacent to the temperature station.

 

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