Legal Alert

Spring Cleaning in the Time of COVID-19

by the Labor and Employment Group
May 1, 2020

As states “re-open”—or prepare to—many businesses have begun to consider how they will ensure that their workplaces are safe for employees, customers, and other visitors. Keeping their sites clean is among companies’ chief concerns. This week, the U.S. Environmental Protection Agency (EPA) and the Centers for Disease Control and Prevention (CDC) issued joint guidance to address this point. Specifically, the agencies published new guidance on April 29, 2020, regarding proper cleaning and disinfection of public spaces, workplaces, businesses, schools and homes.

Notably the guidance does not have the force of law or regulation, and there are no provisions or resources provided to enforce the measures. Nevertheless, given the uncertainty surrounding the standard of care applicable to issues of COVID-19 exposure, the guidance provides a helpful framework for cleaning and disinfections protocols.

This guidance offers a three-step method for cleaning and disinfecting in advance of re-opening businesses, public areas, schools, and homes:

1. Develop a plan

  • Determine what needs to be cleaned
  • Determine what needs to be disinfected
  • Consider the resources and equipment needed

2. Implement the plan

  • Clean visibly dirty surfaces with soap and water
  • Use the appropriate cleaning or disinfectant product
  • Always follow the directions on the label

3. Maintain and revise the plan

  • Continue routine cleaning and disinfection
  • Maintain safe behavioral practices
  • Continue practices that reduce the potential for exposure

The EPA also clarified that cleaning and disinfecting are not the same. “Cleaning” means using soap and water to remove germs, dirt, and impurities from surfaces. “Disinfecting” means using an EPA-approved disinfectant to kill germs on surfaces.

To that end, this new guidance cross-references a list of EPA approved disinfectants. If any of the EPA’s suggested disinfectants are not available, the EPA provides additional guidance on other disinfectant techniques that are equally effective. Finally, the EPA asks that individuals not over-use or stockpile disinfectants or personal protective equipment. Re-opening America will require cooperation, and the group development and maintenance of safe, daily habits.

Ballard Spahr’s Labor and Employment Group and Environmental and Natural Resources Group are following closely these and other developments related to COVID-19 as they impact workplaces and businesses. If you have questions, please contact any member of either Group for advice about your situation.

Copyright © 2020 by Ballard Spahr LLP.
(No claim to original U.S. government material.)

All rights reserved. No part of this publication may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.

This alert is a periodic publication of Ballard Spahr LLP and is intended to notify recipients of new developments in the law. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

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