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Department of Labor and Industry
Safety and Health Codes Board
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9/2/20  4:52 pm
Commenter: Jason Monk, Hampton Division of Fire and Rescue

Symptom-based RTW Guidelines Not Inline with CDC

The current temporary standard for symptom-based return-to-work guidelines (Page 22, 1.a.i.) are inconsistent with current CDC and VDH guidelines. The DOLI temporary guidance requires 72 hours without a fever as one of the three requirements. However, the CDC recommends 24 hours without a fever. Otherwise, the guidance of the DOLI document and the CDC recommendations for RTW are identical. Because DOLI is a lawful requirement, we must follow the current DOLI recommendations even if they are not consistent with CDC guidance. By making the DOLI document consistent with CDC, it will clear up confusion and allow us to follow the most current recommendations. Another consideration would be to add language that won't require a document change if the CDC guidance changes, such as, "...or the most current CDC recommendations."

I respectfully request that the DOLI document, specifically 1.a.i. on page 22, reflect the current CDC recommendations.

Current DOLI Guidance

a. For known or suspected to be infected with the SARS-CoV-2 virus employees the symptom-based strategy excludes an employee from returning to work until (i) at least three days (72 hours) have passed since recovery, defined as resolution of fever without the use of fever-reducing medications and improvement in respiratory symptoms (e.g., cough, shortness of breath) and (ii) at least 10 days have passed since symptoms first appeared

Current CDC Recommendations (HCP)

  • At least 10 days have passed since symptoms first appeared and
  • At least 24 hours have passed since last fever without the use of fever-reducing medications and
  • Symptoms (e.g., cough, shortness of breath) have improved

Current CDC Recommendations (all others)

  • For most persons with COVID-19 illness, isolation and precautions can generally be discontinued 10 days after symptom onset1 and resolution of fever for at least 24 hours, without the use of fever-reducing medications, and with improvement of other symptoms.
    • A limited number of persons with severe illness may produce replication-competent virus beyond 10 days that may warrant extending duration of isolation and precautions for up to 20 days after symptom onset; consider consultation with infection control experts.
CommentID: 84406