IMPLEMENTING TEMPERATURE-SCREENING MEASURES
Public health officials across the European Union and the UK have implemented stringent measures to help contain the spread of COVID-19, such as safer at home and face covering mandates. Some jurisdictions also require employers to screen the health of employees, often as they begin a shift or enter buildings.
WHAT OPTIONS DOES OUR BUSINESS HAVE IN IMPLEMENTING A TEMPERATURE SCREEN OF EMPLOYEES? SHOULD WE ASK EMPLOYEES TO SELF-MONITOR, HAVE EMPLOYEES SCREENED AT THE DOOR, OR SOME COMBINATION?
In implementing temperature-screening measures, there are several options.
First, consistent with self-monitoring practices, an employer could require employees to take their temperature each day before reporting to work and to stay home if they have a fever. The CDC has defined a fever as 38 Degrees C or higher.
A second option is to provide employees with thermometers for use both prior to reporting to work and to monitor their temperatures throughout the day while at work for any spikes in temperature. Similarly, if the employee has a temperature of 100.4 ºF or higher, they should be instructed to leave the workplace and seek medical attention.
Both of the above options eliminate the need to have another employee take each employee’s temperature and for tracking and monitoring the time employees may otherwise spend waiting in line to be screened and being screened.
However, some employers may choose to designate an employee to screen employees and others entering the workplace for fever and other COVID-19 symptoms. If an employer chooses to do so, they should use a no touch thermometer or other temperature monitoring device which allows for distance between the operator and the individual being screened. Additionally, any employee performing such screening should be provided with the proper PPE including a protective gown, mask, and gloves.
Again, if the employee or other individual attempting to enter the workplace exhibits a fever or other COVID-19 symptoms, they should be instructed to leave and seek medical attention. Also keep in mind that the employee tasked with taking temperatures will therefore have access to confidential employee medical information, as temperature screens are considered “medical examinations” by the EEOC; for this reason, some businesses may wish to avoid having an employee’s direct supervisor perform the screening, to avoid a later allegation that the supervisor acted adversely to that employee based on their medical condition.
In addition, an employee’s results should be kept as confidential as possible, shared only on a need to know basis as necessary to protect against the threat of exposure to COVID-19, and kept in a separate file from the employee’s personnel file.
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