By Conn Maciel Carey’s COVID-19 Task Force

Early in the pandemic, popular sentiment—and to a lesser extent, the scientific community—believed that surface transmission of COVID-19 was one of the primary vectors of transmission.  Over time, however, epidemiologists gained a better understanding of how the virus was most typically transmitted.  As a result, the CDC’s guidance evolved to a point where surface transmission was viewed as a less significant mode of transmission than person-to-person transmission.

Throughout all that, spring cleaning took on a new meaning in 2020, as people rushed to purchase all the disinfectant wipes and sprays they could find, wiping down groceries and mail, sanitizing their hands, and treating door handles like they were radioactive.  Workplace sanitation similarly became an area of emphasis as employers distributed wipes, sprays and pump bottles throughout their facilities, hired additional janitorial staff and, in many cases, spent exorbitant sums on third-party vendors to clean and disinfect the workplace, even introducing aggressive surface cleaning techniques like fogging. And once the hygiene frenzy took hold in the workplace, there has been little reprieve for employers from regulatory bodies.  State and local health departments, federal OSHA and State OSH Plans, and even some state legislatures, recommended or imposed strict sanitization protocols, including requirements to routinely wipe down shared surfaces with disinfectant, to close workplaces for deep cleaning even when days had passed since a COVID-positive individual had been in the area, and implement daily cleaning and disinfecting plans.  The financial cost for employers associated with these requirements rose quickly.  Like pre-shift temperature screens, some of these requirements have persisted even after the science has recognized their limited efficacy.

Earlier this week, more than a year after the COVID-19 pandemic began, the CDC has released new guidance clarifying that the risk of contracting COVID-19 from contaminated surfaces is, in fact, quite low. Citing several studies evaluating surface transmission, the CDC indicated that the risk of infection through contaminated surfaces is generally less than 1 in 10,000.

The scientific data regarding the very low risk posed by surface contamination is welcome news.  The CDC studies evaluated the effectiveness of prevention measures intended to reduce the risk of surface transmission and found that surface disinfection once or twice-per-day had little impact on reducing risk.  The CDC explained that when accounting for both surface survival data and real-world transmission factors, the risk of surface transmission after a person with COVID-19 has been in an indoor space is minor after 3 days (72 hours), regardless of when it was last cleaned.

Notably, the CDC found that while disinfection was effective for preventing transmission within a household where at least one person has COVID-19, there was little scientific support for routine use of disinfectants in community settings, whether indoor or outdoor, to prevent COVID-19 transmission from surfaces.

In essence, what the new CDC guidance does is significantly reduce the circumstances when employers must disinfect (as opposed to just clean) the workplace.  In pertinent part, the guidance states:

Routine cleaning performed effectively with soap or detergent, at least once per day, can substantially reduce virus levels on surfaces. When focused on high-touch surfaces, cleaning with soap or detergent should be enough to further reduce the relatively low transmission risk from fomites in situations when there has not been a suspected or confirmed case of COVID-19 indoors. In situations when there has been a suspected or confirmed case of COVID-19 indoors within the last 24 hours, the presence of infectious virus on surfaces is more likely and therefore high-touch surfaces should be disinfected.

In addition to updating its guidance on surface transmission of COVID-19, the CDC also updated its guidance regarding Cleaning Workplaces.  The CDC continues to prioritize cleaning high-touch surfaces, but employers are now able to evaluate whether enhanced sanitizing and disinfection is even necessary, as “regular cleaning (at least once a day) is enough to sufficiently remove virus that may be on surfaces” in most cases.  The CDC’s current cleaning guidance advises that disinfecting shared spaces may be warranted – but not required – when certain conditions are present.

The guidance further clarifies that employers should still disinfect the workplace (using products on the EPA N List) when there has been a known or suspected positive case in the workplace within the past 24 hours.  However, regular cleaning with soap/detergent and water is generally sufficient.

The “certain conditions” that may warrant disinfecting the workplace (or specific parts of it), as opposed to simply cleaning, include:

• High rate of ongoing community transmission around the store;
• Lack of consistent mask-wearing in the store;
• Infrequent hand hygiene by employees;
• The space is occupied by high-risk individuals (i.e., people at increased risk for severe illness from COVID-19)

As the country continues on the path towards a broader reopening, the CDC’s revised guidance is a major step in re-thinking housekeeping standards moving forward.  While workplace sanitation will presumably continue to be a central element of workplace exposure control plans, the revised guidance should alleviate some of the hygiene hysteria as the focus shifts from fogging and serious cleaning with serious chemicals, to regular cleaning with simple cleaning products.  We recommend evaluating the CDC’s revised guidance and any applicable cleaning requirements under state or local health department orders or legislation to determine whether your current cleaning and disinfecting protocols can be relaxed.