No matter what business you’re in, whether essential or non-essential, you won’t be allowed to re-open and remain open unless you comply with social distancing requirements. For social distancing to work, you must be able to track encounters closer than the permitted 6 feet/2 meters. One possibility is to use apps, wearables and other so called “contact tracing” solutions that monitor encounters in real time. But in addition to being highly privacy-invasive, contact tracing may be too costly and cumbersome for many employers. So, consider using this cheaper, easier and less intrusive method instead.
The Metrics of Manual Contact Logging
As with any other systems, contact logging requires clearly defined metrics. In the context of social distancing, you want to measure contact closer than 6 feet/2 meters. But you also need to accept the fact that people are going to come closer than they’re allowed at some point during the day. Keep in mind that infection risk is a function of not only distance but also duration of exposure. So, rather than every close encounter, require reporting only of those that last a prescribed amount of time; 10 seconds seems to be the best practice standard. There are also 2 other key metrics to account for:
- “Dangerous contacts” that pose immediate hazard of infection regardless of distance and duration, e.g., one person sneezes or coughs on another; and
- “Prolonged close contact,” a kind of occupational exposure limit for total exposure to close contact (e.g., 15 minutes) in a single shift or visit requiring an organizational response and perhaps discipline.
The Mechanics of Manual Contact Logging
Require all employees to complete a log of close or dangerous contacts they had during their shift, including the name of the person and approximate duration of close contacts in minutes and seconds and submit it to a supervisor. (See the Model Log below for an example.) Have the supervisor to process the logs to confirm that each employee present during the shift submitted one, check for any dangerous contacts and total the cumulative minutes and seconds of each employee’s close contact time to determine whether there was any prolonged close contact.
Organizational Response Actions
Require supervisors to immediately notify HR of any dangerous or prolonged close contact for an organizational determination of whether to let the employee keep working at the site or order them to go into self-isolation. The supervisor should also follow up with any employee subject to prolonged close contact the very next shift to go over the social distancing rules, get the employee’s explanation and determine whether to impose discipline in accordance with company progressive discipline policies.