The notion that U.S. employers would engage in broad-scale temperature screening of employees would have once been essentially unthinkable. But the realities of COVID-19 are changing the workplace, as least for the time-being. With the encouragement of the Centers for Disease Control and Prevention (“CDC”) and some state and local governments, and in light of the blessing of the Equal Employment Opportunity Commission (“EEOC”), more employers are now considering the implementation of daily temperature screening before employees enter the workplace.
In Part 1 of our two-part series on temperature screening, we addressed the question of whether employers may (or must) implement a temperature screening protocol. Here, in Part 2, we address the question of how to implement such a protocol, i.e. what procedures for temperature screening in the workplace should employers implement? Below are a number of issues for employers to consider:
Outside: The CDC recommends that screenings be conducted before entry to a workplace. One option is to use a drive-thru screening process. If using such a process, employers should develop appropriate traffic controls, signs and markings (e.g., parking cones) to direct traffic and provide safe locations for testing. They should also make sure that exits are not blocked with waiting cars. If possible, another option is to set up a trailer or other temporary structure in a parking lot outside the entrance doors.
Inside: Ideally, the screening will occur very close to the entrance and each individual should use hand sanitizer prior to getting in line for screening. Employers should ensure that relevant employees (and, if screening others, contractors and visitors) all enter where they will be subject to screening. Employers should also ensure that those being screened practice physical distancing when waiting to be screened. Consider using painter’s tape or parking cones, setting up “lanes” on the floor or other methods to ensure individuals remain at least six feet apart during the process. Ensure that the screening location does not block building exits in case of an emergency.
The COVID-19 pandemic and its impact on the workplace is rapidly evolving. Employers should regularly consult with legal counsel and the CDC website to ensure they have the most up-to-date information and guidance.
 “Screening” can be used broadly to refer to various efforts to assess an employee’s symptoms of COVID-19. In this blog post, screening is used specifically to refer to the process of taking employees’ temperatures to assess the specific COVID-19 symptom of fever.