In TAG’s May 2020 FSMA Fridays webinar, TAG President and CEO Dr. David Acheson MD and Senior Director, Regulatory and Scientific Affairs Dr. Ben Miller, Ph.D., MPH discussed Responsibly Reopening and Rebounding from COVID-19. Following is an overview of the webinar, to view the full presentation, visit the webinar web page.
Testing. As businesses continue to bring employees back to work, a fundamental aspect of employee protection is that of continuing to implement and enforce the Hierarchy of Controls (above). As part of the Employee Wellness Checks, TAG is often asked about including testing. While this can be beneficial, there are a number of factors to consider:
- Results Use. Whether considering a molecular (diagnostic) test to determine if a person is infected, or a serological (antibody) test to determine if they had been, the first question should always be, “What will I do with this data? In addition to that, companies should ensure they are using tests that have been “approved under FDA’s Emergency Use Authorization Process (EUA), and understand the extent of its sensitivity (false negatives) and specificity (false positives).
- Reason for testing. Conceptually, regular diagnostic testing could help identify asymptomatic carriers as employee wellness checks only identify symptomatic cases. But, in practicality, you will need to determine who will be tested and if it will be mandatory or voluntary; length of time for results and whether employees are excluded exclusion until results are attained; frequency of testing; cost; etc.
- Value of test. Best practice is to develop a robust sampling and testing plan and assume the worst-case scenario; using that lens, you can determine if testing is worthwhile as there is no universal answer.
- Deciding to test. If you decide to test, understand the reliability of the test you’ll be using; look for tests that have been independently evaluated
State Variation. Throughout the pandemic and during recovery modes, the states have responded in extremely varied ways, so it is essential that all businesses understand the expectations of local and state health departments and be prepared to describe and demonstrate what you’re doing.
While testing capacity has significantly increased in many states, it still varies and some states are combining diagnostic and antibody test results in their case counts – which TAG sees as bad practice because it does not accurately reflect current cases or risk.
TAG has developed a state matrix providing a risk comparison based on the amount of social distancing being practiced in the state (data source: University of Maryland Social Distancing Index) and the current velocity of the outbreak and state testing capacity (data sources: effective Rate of Transmission from Rt.Live; test positive rate calculated from The Covid Tracking Project).
Resuming Travel. Travel is essential to many businesses, and summer is the time of many employee vacations. But should travel be resumed or discouraged? Again, this will vary significantly, based primarily on the current health of those needing/wishing to travel (only well, non-symptomatic people should) and the risk determination of the destination and mode of travel. Always check government quarantine orders, conduct a pre-travel risk assessment of the location and facility (as applicable), and refer only to reliable sources. Following is a general risk matrix for standard modes of travel. For more in-depth information on this and a travel risk assessment, give TAG a call.
Regardless of all that has been learned about COVID-19 since its start, questions remain, and the nearly day-to-day changes continue. Since the time of the presentation, we’ve seen that reopening of some states has, indeed, created hotspots. But we do not yet know if we will see another change in behavior as people plan for a “second wave” in late fall/early winter coinciding with flue season? with COVID-19 overall and the spread of the pandemic. Or if testing technologies will improve to expand onsite testing options.
COVID-19 and its protections remain a complex topic, but TAG can help you stay ahead of the curve with our regularly updated State Matrix, COVID-19 & Recovery Toolkit, and other tools and checklists aligned with CDC guidance. Visit TAG, or contact us, for more information.
View the full Responsibly Reopening and Rebounding from COVID-19 here.
