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California Points New Definition of “Shut Contact” – Time for Tape Measures and Calculators (US)

The California Division of Public Well being (CDPH) revised its definition for what constitutes a “shut contact” for functions of Cal/OSHA’s Emergency Momentary Commonplace (ETS).[1] The revised definition will doubtless be excellent news for giant field retailers, giant producers and warehouses. The remainder of the state will stay certain by the prevailing commonplace.

As a reminder, this summer season, the CDPH outlined “shut contact” to be a person who shared the identical “indoor airspace” with an individual who’s contaminated with COVID-19 for a cumulative complete of quarter-hour or extra over a 24-hour interval. The brand new definition creates two requirements for “shut contact” and clarifies what’s a shared indoor airspace. In keeping with the brand new definition:

  1. In indoor airspaces 400,000 or fewer cubic ft per flooring (similar to house, clinic ready room, airplane, and many others.), an in depth contact is outlined as sharing the identical indoor airspace for a cumulative complete of quarter-hour or extra over a 24-hour interval (for instance, three separate 5-minute exposures for a complete of quarter-hour) throughout an contaminated particular person’s (confirmed by COVID-19 take a look at or medical analysis) infectious interval.
  2. In giant indoor areas larger than 400,000 cubic ft per flooring (similar to open-floor-plan workplaces, warehouses, giant retail shops, manufacturing vegetation, or meals processing services), an in depth contact is outlined as being inside six ft of the contaminated particular person for a cumulative complete of quarter-hour or extra over a 24-hour interval through the contaminated particular person’s infectious interval.

In different phrases, in case your workspace meets the “giant indoor area” definition, merely sharing airspace now not counts as being an in depth contact; the people should even be inside six ft of one another.  That ought to ease the burden on sending individuals house after a possible office publicity. 

Although the brand new Well being Officer Order consists of “open-floor-plan workplaces” for example of a giant indoor area, you’ll not qualify for the extra lenient take a look at in case your area shouldn’t be, in reality, larger than 400,000 cubic ft. So, it’s time to brush up on center faculty math and keep in mind, the system for the amount of a dice or rectangular prism (that’s prism . . . not jail) is:

Size x Width x Peak. 

These of you with much more architecturally fascinating areas – spherical or triangular shapes, for instance – should brush up on the formulation for triangular prisms and cylinders.    

You’re in all probability usually conversant in Size x Width. That’s what actual property individuals often market as a constructing’s sq. footage. You would possibly must get out a tape measure to examine your ceiling peak as a result of ceaselessly, lease descriptions discuss with the peak from one flooring to a different, however with options like drop ceilings, the precise peak of the airspace may very well be materially much less. If you already know the sq. footage and the peak of the ceiling, calculating cubic ft must be simple. However that is California . . .

The CDPH rule specifies areas separated by floor-to-ceiling partitions (workplaces, convention rooms, bogs, closets, and many others.) have to be thought-about as distinct indoor airspaces. Employers with sufficient gross sq. footage and excessive sufficient ceilings might but be disqualified from the extra lenient rule after subtracting the amount of the separate areas. Having finished the mathematics for Squire Patton Boggs’ open-space San Francisco workplace, I discovered that the cubic quantity of our total flooring solely amounted to about 189,000 cubic ft – and that was earlier than subtracting out the separate enclosed areas. In case your area is simply too small to make use of the brand new rule, know that you’ll be in good firm.

[1] Order of the State Public Well being Officer Past Blueprint (

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