Almost every state has now at least partially reopened, sending millions of Americans back to work. With COVID-19 not entirely eradicated, employers now have a new consideration when it comes to worker safety: exposure to a sick co-worker or worse, a companywide outbreak.

As states return to work, employer obligations with respect to temperature screening vary widely. While Colorado requires companies to implement workplace temperature screening, Delaware only recommends it, while other states, such as Florida, make no mention of it at all. These rules and guidelines are also constantly evolving as states gather more information, so it is essential that you are aware of your state’s current laws.

Regardless of state guidance, many companies are establishing new return-to-work protocols that include assessing the temperatures of returning employees. In its updated guidelines, the Centers for Disease Control (CDC) recommends that employers conduct “daily in-person or virtual health checks” on their employees, which include temperature screening.

Here is how temperature screening works and how you can implement safe, effective screening protocols at your workplace.

Understanding the Limitations

Temperature screening should be part of your return-to-work safety plan, but it cannot exclusively ensure the safety of your workforce. Instead, it should be part of a comprehensive plan. While a fever is a possible symptom of COVID-19, fevers are not exclusive to this disease. Many people also run higher than average temperatures under normal circumstances.

Temperature screening alone cannot rule out or confirm a COVID-19 infection. However, a fever is still a reliable indicator, and screening for temperature is currently something that can be easily done by any company. It is a tool, among many others, to help ensure the health and safety of your workforce.

How High is Too High?

Although the average human body temperature is pegged at 98.6 F (37 C) by most health experts, it can range as high as 99 F (37.2 C). It is important to note as well that temperature can range widely throughout the day and events such as menstruation can also cause temperatures to spike.

Experts usually describe a fever as any temperature over 100.4 F (38 C)

Temperature Screening

The CDC has provided guidance to businesses to implement temperature screening safely. These include several approaches you can take for temperature assessment.

Some workplaces where employers have found it impossible to host an internal screening program have implemented self-reporting. This involves asking workers to affirm that they took their temperature before leaving for work and that the results were normal. This attestation often comes in the form of a questionnaire that may include additional questions about the worker’s exposure. This less expensive and time-consuming process is preferred by companies who may have logistical challenges in setting up a company-sponsored temperature screen.

For in-house temperature screening, the CDC recommends that trained personnel greet each employee from a distance of at least six feet to confirm that they do not have a temperature over 100.4 F (38 C) and are not experiencing coughing or shortness of breath. Personnel should also visually inspect workers for physical signs such as flushed cheeks or fatigue.

Temperature Taking Devices

Temperature screening is much easier to implement in workplaces through the use of non-contact or limited contact devices providing instantaneous readings. Tympanic thermometers are infrared thermometers that are usually inserted in the ear and are considered reliable and accurate.

Other infrared devices that touch the skin are considered slightly less accurate, but high-tech thermal imaging devices typically used in airports do perform well. However, these require personnel with the technical skills to troubleshoot calibration and other issues associated with these devices.

Temperature screening in the workplace should always be conducted by trained medical personnel, ideally a nurse or similar health care worker.

Taking Temperatures Safely

The CDC recommends the use of barrier or partition controls made of glass or plastic between screeners and employees to protect from respiratory droplets when an employee sneezes, coughs or even talks. Screeners should also:

• Wash hands for at least 20 seconds
• Visually inspect employees for signs of illness
• Use disposable gloves and change between employees unless using a disposable or non-contact thermometer
• Clean and disinfect non-contact thermometers between employees
• Reach through or around the screen to take temperature while ensuring the employee’s face remains behind the partition
• Remove and discard personal protective equipment (PPE) and wash hands, preferably with soap and water for 20 seconds, or, if necessary, use hand sanitizer with at least 60% alcohol

Use of PPE by Screeners

If screeners must stand within six feet of an employee during the screening process, the CDC recommends using PPE, including a face mask and eye protection (either googles or a disposable face shield). Screeners should also wear gowns for extensive contact along with disposable gloves.

However, PPE is considered less effective in preventing COVID-19 transmission than social distancing and the use of barriers.

Returning to Work

Employees who are sick, including those exhibiting coronavirus symptoms, should notify their supervisors and stay home. Those with coronavirus symptoms must remain at home until after symptoms are no longer present or at least ten days have passed.

These guidelines, however, remain fluid as experts gather more information about the disease, and the CDC keeps an updated list here.

ADA and Risk Mitigation

The Equal Employment Opportunity Commission (EEOC) has recently reaffirmed its guidance on mandatory temperature screening in the workplace, stating that employers may screen employees before entering the worksite. As an employer, you also have the right to ask your employees about symptoms.

However, the implementation screening cannot run afoul of the Americans with Disabilities Act (ADA). It must be non-discriminatory, and any results must be treated just like any other confidential medical information. You may only share the results of temperature screening with supervisors and managers who absolutely need to know.

What this means to employers is that having an open assessment area with people waiting in line is not the best approach. This setup makes it difficult to maintain social distancing or to ensure privacy. Regardless of the screening setup you choose, you must also follow the EEOC and ADA guidelines.

Clarify the Message

Ensure that your employees understand that not having a fever does not necessarily mean they do not have the coronavirus.

Educate your employees about the wide variety of symptoms related to COVID-19 and how they can assess themselves. Various state health agencies, as well as the CDC, host online self-assessment tools.

Establish a back-to-work policy that clearly lays out your protocols and expectations for screeners, employees and employers. Temperature screening should be an integral part of this plan, but it should also include other critical safety measures including social distancing and appropriate PPE.