Letter to CDC Regarding FAQs for Employers

Thursday, May 28, 2020 - 10:45am

Robert R. Redfield , MD, Director
Centers for Disease Control and Prevention
1600 Clifton Rd.
Atlanta , GA 30329

By electronic mail: RRedfield@cdc.gov

Dear Dr. Redfield:

The undersigned associations represent hundreds of thousands of employers who employ
millions of employees. Many of these companies have been idled by the coronavirus pandemic
and various orders to shutdown, while others have been able to main tain some level of
operations. Without exception all of these companies are seeking reliable and authoritative
answers to questions about how best to protect their employees and what is expected of them as
they reopen or increase their level of business. To assist employers, w e believe CDC should
expand its current Frequently Asked Questions page to allow businesses and employers to
submit specific questions to whic h they need detailed answers .

The CDC is the most widely cited authority for specific procedures on protecting
employees and the general public . As you know, CDC guidelines are central to how OSHA
expects employers to comply with the General Duty Clause for protecting employees. In
addition, CDC is looked to by state and local public health and safety agencies, as well as
companies in general.

While the CDC guidelines have been the standard reference document s, many issues are
surfacing where more spe cific information and direction is needed. Several of these issues will
determine whether and to what extent companies can reopen, and how they will conduct
business. An FAQ process that accepts questions from employers would provide direct answers
to ques tions and allow CDC to disseminate information in an efficient and timely way.

Various a gencies have set up employer directed FAQs that have been highly effective in
helping employers understand what is expected of them, or how they could acc ess government
relief. In particular the Department of Labor’s Wage and Hour Division even conducted a widely
attended conference call to solicit questions that employers had to make sur e they addressed the
questions that mattered most to employers.

As an initial set, our members have told us they need guidance on the following
questions:
 While the six foot distancing recommendation is widely known, there are many settings
where maint aining that leve l of separation is not possible, and as more companies come
back, those types of settings will increase. What should employers do to protect their
employees when keeping them six feet apart is not possible?
 Whether customers are comfortabl e coming back to various businesses such as
restaurants and stores may depend on whether they have confidence that publicly

available restrooms have been sufficiently sanitized. What restroom cleaning protocols
does CDC recommend?
 Various workplaces are, by nature, very confined. These include restaurant kitchens,
small retail boutiques, certain construction sites, and long haul truckin g and delivery
services where the driver is accompanied. What does CDC recommend for these settings
where six foot separ ation is not possible?
 What protocols does CDC recommend for testing of employees before reentering the
workplace? For instance: Which test(s) should employers use? How frequently should
employees be tested? How should an employer isolate an employee who tests positive?
Should employers rely on employees self -testing at home? Should employers rely on
employees answering questionnaires regarding whether they are symptomatic, or their
movements?

We are sure there are many more scenarios where further clar ity in the practical application of
CDC guidelines would be useful , which would likely surface if CDC initiates a process for
questions to be submitted .

As America’s businesses look to recover and lead the rebound of the economy, they will
need as much precise information on how to reopen responsibly as possible. They will be
looking to the CDC for guidance and answers. Developing a submission process for employers
would be the most efficient way to further CDC’s mission of promoting sound public health
practices while also helping America’s employers bring employees bac k to work. We look
forward to working with CDC on this effort.

Sincerely,

Associated Builders and Contractors
Co llege and University Professional Association for Human Resources
HR Policy Association
Natio nal Association of Manufacturers
National Retail Federation
U.S. Chamber of Commerce

CC: John Howard, MD, MPH, JD, LLM, MBA
Director, NIOSH
Anne Schuchat, M.D. Rea r Admiral, USPHS (ret.) , Principal Deputy Director Centers for
Disease Control and Prevention
Frank J. Hearl
Kyle McGowan