What To Do When An Employee Tests Positive For COVID-19?

1.      If the employee is at your dealership, immediately send the employee home. This is required under Execuive Order 122, which remains in effect.

2.      Talk to the employee.

• When an employee notifies you that he/she has tested positive for COVID-19 or has a suspected case, the dealership needs to learn who the employee has interacted with and where the employee has gone in the dealership. The employee’s answers will guide your next steps. Ask the employee questions, such as:
• When did you begin to have symptoms?
• When were you diagnosed?
• What staff members have you been in contact with in the 14 days before you began to experience symptoms?
•  Did you have any contact with customers or other third parties? If so, do you know who they were?
• Did you attend any meetings?
• Did you talk to any vendors?
• Did you deliver any vehicles or parts?
• Tell the employee to stay home. In the case of an employee who has symptoms, but has been unable to get tested, you can still tell the employee to stay home. Regardless of what the employee may be later diagnosed with, you still can tell them to stay home.

3.      Notify employees.   [Updated November 4, 2020]

• Notify all employees that an employee has tested positive for COVID-19. However, you must not identify the sick employee. Federal law prohibits employers from sharing the identity of sick employees. Take care to use gender-neutral pronouns (they/them) to further protect the sick employee’s identity.
• [Added October 23, 2020]-  You must also notify all employees with whom the sick employee was in close contact in the previous 14 days. “Close contact” is defined by the CDC as having spent at least a total of 15 minutes within 6 feet of an infected person over a 24-hour period. The 15-minute threshold does not have to be consecutive to be considered close contact. The 15-minute threshold includes instances such as when a sick employee is within 6 feet of a colleague for five minutes, then two minutes, then eight minutes over a 24-hour period. You must send those exposed employees home to prevent the spread of COVID-19.
• Advise the employees to call their doctor or the public health department for guidance on how long they should stay home.
• [Updated November 4, 2020]- The current guidance from the CDC and the New Jersey Department of Health recommends:
  • The CDC now generally recommends only a symptom-based test for ending isolation and returning to work. For most persons with COVID-19, isolation and precautions can usually be discontinued 10 days after symptom onset and resolution of fever for at least 24 hours, without the use of fever-reducing medications, and with improvement of other symptoms. At that point, the person may end isolation and return to work. The New Jersey Department of Health agrees with this recommendation.
    • Previously, the CDC’s guidance was more stringent. The old recommendation was that a person with COVID-19 remain home for 10 days since symptoms first appeared and at least 72 hours since recovery (defined as resolution of fever without fever-reducing medications and improvement in respiratory symptoms). It is up to dealers to determine whether it makes sense for their dealership to follow the new guidance or to adhere to the more conservative guidance as a precaution. It should be considered that some people with severe COVID-19 illness may still be contagious beyond 10 days. This situation may warrant extending isolation and precautions up to 20 days and consultation with infection control experts.
  • If the COVID-19-positive person never develops symptoms, isolation and other precautions can be discontinued 10 days after the date of their first PT-PCR test for SARS-CoV-2 RNA. The test-based strategy is generally no longer recommended for determining the end of isolation for asymptomatic cases. The New Jersey Department of Health concurs with this recommendation.
    • Previously, the CDC recommended that an asymptomatic person have two negative tests collected more than 24 hours apart before ending isolation and returning to work. This test-based strategy was an alternative to the 10-day isolation. Now, the CDC recommends testing only if someone seeks to end isolation before the 10 days of quarantine are over or if the person is severely immunocompromised.
    • If the initially asymptomatic person develops symptoms, the symptom-based test should be used to determine the end of isolation.
  • The CDC no longer generally recommends a test-based strategy for COVID-19-positive people with symptoms, unless someone seeks to discontinue isolation or precautions earlier than 10 days since the onset of symptoms.
    • Previously, the CDC recommended, as an alternative to the symptom-based test, that the person have two negative tests collected more than 24 hours apart, before ending isolation and returning to work. Additionally, their symptoms had to have improved and their fever resolved without fever-reducing medications.
  • If someone has COVID-19 symptoms but tests negative, they may end isolation and return to work after waiting at least 24 hours after their symptoms end. But if this person is a household or close contact or a traveler from an area on the travel advisory list, they should still complete the 14-day quarantine recommended by the New Jersey Department of Health.
  • If an asymptomatic person was tested for COVID-19 and they tested negative or were never tested, no quarantine is necessary.
    • The only exception to this is the 14-day quarantine resulting from a household or close contact or if they just returned from an impacted area. However, in such a circumstances, the basis for their quarantine is their household or close contact or their recent travel, and allows time for COVID-19 symptoms to develop before the person returns to work.

4.      Clean and disinfect the affected area(s) of the dealership.

• The following recommendations come from the Center For Disease Control and are designed for businesses that do not house people overnight and have had an employee with a confirmed or suspected case of COVID-19:
  • Immediately close off the areas of the dealership where the employee had been working. Wait as long as possible before cleaning and disinfecting the area (this will prevent accidental exposure to respiratory droplets).
  • If you can, open up doors and windows to circulate fresh air into the dealership. If possible, wait 24 hours before cleaning and disinfecting those areas.
  • Develop policies for worker protection and train cleaning staff on-site before beginning the cleaning. Training should include when and how to properly put, use, take off, and dispose of Personal Protective Equipment (PPE). Also ensure that workers are trained on the hazards of workplace cleaning chemicals. With respect to both PPE and the cleaning chemicals, further guidance can be found with OSHA.
  • Download the manufacturer’s Safety Data Sheet (SDS) and share with employees as needed, and make sure the cleaners used are on your list of workplace chemicals used as part of the Hazard Communication Program (which almost all employers maintain).
  • Have the areas where the employee worked or frequented cleaned and disinfected. These areas may include: offices, desks, bathrooms, and break rooms. Special attention should be paid to frequently touched surfaces, such as keyboards, phones, remote controls, etc.

5.      Be ready to answer questions.

• Assign one person or a very small team of individuals (such as the HR manager and dealer principal) to answer internal and external questions. This will avoid confusion and misinformation from spreading through your dealership and your community.
• Do not share details about the infected employee with anyone. Federal and state confidentiality and privacy laws prohibit employers from sharing that information with anyone.
• Share the steps you are taking to follow health and safety protocols with employees.
• Have a standard statement ready for any media inquiries. For example:

• Be truthful and compassionate.