Compliance Perspectives

Use Contact Logging to Ensure Lab Employees Practice Social Distancing

Managing a lab compliance program in the age of COVID-19 poses new and unprecedented challenges. One of the biggest and most important is ensuring that lab employees and the persons they interact with on the job follow social distancing requirements. To succeed in this effort, you must have the capability to track actual encounters. One possibility is digital technology, the use of apps, wearables and other so called “contact tracing” solutions that monitor encounters in real time. But in addition to being highly privacy-invasive, these solutions may be too costly and cumbersome for many labs. So, you may want to consider using this cheaper, easier and less intrusive manual method instead.

What’s At Stake

Without a vaccine or treatment, social distancing, i.e., keeping at least six feet away from other people, has been the primary defense against COVID-19. Even though the shutdown phase of the pandemic is ending, labs and other businesses will have to keep following social distancing requirements or risk shutdown and penalties, not to mention infections to staff.

The Role of Contact Logging

“Contact tracing” is the generic term for a system of gathering data about individuals’ physical encounters with other people. In the COVID-19 context, this data plays a crucial role in social distancing compliance monitoring by enabling your lab to:

  • Analyze the number, duration and nature of potentially dangerous encounters, i.e., those closer than six feet, involving lab employees; and
  • Identify the individuals involved in those encounters in case it becomes necessary to notify them of potential exposure, e.g., a physician who spent a lot of time working in close contact with one of your lab’s phlebotomists who tested positive for COVID-19 24 hours later.

How Contact Logging Works

Contact logging is a method of contact tracing in which employers gather the data manually by requiring each person who comes to their facilities complete a form logging the contacts they had while they were at the premises. As with any other system, contact logging requires clearly defined metrics. For purposes of social distancing, the key metric is contact closer than six feet.

But you also need to maintain a sense of proportionality and accept the fact that some close contact is bound to occur at some point during the day with the understanding that COVID-19 infection risk is a function of not only distance but also duration of exposure. So, rather than every close encounter, the better metric would be close encounters lasting longer than a prescribed time period, such as 10 seconds. Two other key metrics:

  • “Dangerous contacts” that pose immediate hazard of infection regardless of distance and duration, e.g., somebody sneezes or coughs on another person; and
  • “Prolonged close contact,” a cumulative close contact exposure threshold (e.g., 15 minutes in a single shift) triggering the need for the lab to initiate discipline, notification or other organizational response.

The Mechanics of Contact Logging

For as long as the social distancing mandate remains in effect, you should require all persons who come to your facilities—not just lab employees but also vendors, clients, patients and visitors—to complete a log of close or dangerous contacts they had during their shift or visit, including the name of the person and approximate duration of close contacts in minutes and seconds and submit it to a supervisor. (You can adapt the Model Encounter Log for your own use).

Designate a lab supervisor to process the logs to confirm that each employee and visitor present during the shift submitted one, flag any dangerous contacts and total the cumulative minutes and seconds of each close contact time to determine whether there was any prolonged close contact.

Organizational Response Action

Require supervisors to immediately notify you of any dangerous or prolonged close contact so you can decide what, if anything, your lab should do in response. For example, should the employee be barred from entry and ordered to go into self-isolation? Do visitors involved in prolonged close contact need to be notified of their potential exposure? The supervisor should also follow up with any employee subject to prolonged close contact during the very next shift to go over the social distancing rules, get the employee’s explanation and determine whether to impose discipline in accordance with the lab’s progressive discipline policies.

Takeaway

If, like many compliance managers, you’ve been made the COVID-19 coordinator for your lab (if not, you might want to forward this analysis to whoever at your lab is performing that function), you face the daunting responsibility of enforcing social distancing. Contact logging is a relatively simple and inexpensive method for gathering the encounter data you need to ensure your own employees are following the rules.


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