Legal Update Memo No. 02-2021 – CDPH Issues New Sweeping Schools Guidance (K-12)

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On January 14, 2021, the California Department of Public Health (“CDPH”) issued a 50-page COVID-19 and Reopening In-Person Instruction Framework & Public Health Guidance for K-12 Schools in California, 2020-2021 School Year[1] (“Guidance”). This Guidance consolidates and supersedes prior CDPH schools guidance, and updates CDPH’s COVID-19 and Reopening In-Person Learning Framework for Schools dated July 17, 2020.  All public and private schools in California (Local Education Agencies “LEAs”) must comply with this public health directive.

This Guidance supersedes the Elementary Education Waiver Process that was issued on August 3, 2020. All schools that opened under a previously granted waiver prior to January 14, 2021, that have stayed open, may continue to operate under that waiver.

This Guidance does not change CDPH’s September 4, 2020 Cohort Guidance  which allows groups of up to 16 individuals (high-need students and staff) to meet on campus for targeted support, intervention services, and internet service. [2]

Although we strongly recommend every LEA administrator read through the entire Guidance, below are critical highlights affecting LEA’s responsibilities to students, employees, and Local Health Officers (“LHO”), including new reporting requirements that begin on January 25, 2021, heightened mask requirements, consolidated regulatory requirements, and a streamlined process for elementary schools to re-open. California has also launched a “one stop shop” website “Safe Schools for All Hub” at which school administrators can seek assistance.[3]

I.Defining “Re-Opening” Schools (Guidance, pp. 5-6)

The terms “open” or “reopen” refers to operations for at least one grade at the school that are permitted only if the county satisfies the eligibility requirements for schools to “open” or “reopen.” Specifically, the school must have given all students in at least one grade the option to return for in-person instruction for at least part of the school week to be considered “open” or “reopen.” Hybrid models satisfy these criteria, so long as each grade level had an in-person option.

If a school is located in a county that shifts to the Purple Tier, the school may continue serving the students in-person as it did while in the Red Tier, but it may not bring additional students back for in-person instruction and services, unless it adheres to the Cohort Guidance for the students newly brought back in-person.

NOTE: A school is not “reopened” if it was previously permitted to reopen but became ineligible to reopen before actually reopening. However, “if a school was implementing a phased reopening (e.g., only opened grades 9-10 for in-person instruction with set plans to phase in grades 11 and 12) while the county was in the Red Tier, the school site may continue their phased reopening if the county reverts back to the Purple Tier, if authorized by [LHO]. This is only applicable to individual school sites. If a school district has a phased reopening of their schools, the schools in that district that did not open for in-person instruction may not re-open until the county meets the reopening criteria.”

II. Required Steps to Take for In-Person School Reopening (Guidance, pp. 7-13)

Grades K-6: Schools may open if COVID-19 case rate below 25 per 100,000.[4] 

Grades 7-12: Schools may open if COVID-19 case rate is between 1 and 7 per 100,000. 

COVID-19 Safety Plan (“CSP”). The Guidance requires a CSP be posted on the LEA’s website prior to reopening.  The CSP is comprised of: 1) the LEA’s COVID-19 Prevention Program (“CPP”) required by Cal/OSHA Emergency Temporary Standards;[5] and 2) the

COVID-19 School Guidance Checklist, a CDPH form to fill out regarding the LEA’s plans to comply with the new requirements.[6]

For schools in the Purple Tier, before reopening elementary schools, the LEA must submit the CSP to the State Safe Schools for All, at K12csp@cdph.ca.gov, and to the LHO for feedback.

Below is a table summarizing CSP posting and submission requirements:

School reopening actions for in-person instruction, by Tier
Yellow CR <1.0 TP<2%	Orange CR 1-3.9 TP 2-4.9%	Red CR 4-7 TP 5-8%	Purple CR>7 TP >8%
● CSP posted publicly for K-12th grades 5 days prior to in-person instruction.	● CSP posted publicly for K-12th grades 5 days prior to in-person instruction.	● CSP posted publicly for K-12th grades 5 days prior to in-person instruction. ● Must be in Red 5 consecutive days prior to reopening.	(1)  If previously opened: CSP must be posted publicly by 02/01/21.  –OR- (2)  Not previously open: ● CSP posted publicly for K-6, and submitted concurrently to Local Health Department and State Safe Schools for All Team. ● 7 business days for review. ● 7th-12th grade reopening not permitted if CR>7.[7] ● K-6th grade reopening not permitted if CR>25, though CSP can be posted and submitted for review. ● Note: Targeted in-person instruction may be offered pursuant to the Cohorting Guidance.

While the CSP is district-wide, site-specific precautions must be noted to address considerations unique to specific school sites, as applicable.

Each LEA must document and affirm consulting with labor, parent, and community organizations in preparing the CSP. Please note that for schools that have already reopened, labor consulting, which differs from negotiating, is not required. However, under the current Governor’s budget proposal, all LEA’s must submit to their County Office of Education a negotiated MOU as a condition to receiving an in-person instruction grant.

New Testing Guidelines. In addition, LEAs are encouraged to comply with testing guidelines; however, the testing cadences do not appear to be mandatory. That said, if an LEA plans to deviate from the testing cadences then we advise the LEA first consult with its County LHO and its insurer. This table summarizes recommended testing guidelines to correspond to each tier, and a new category for purposes of testing where the region has an adjusted case rate of more than 14 per 100,000. CDPH issued a separate guidance which provides more detail, information, and resources regarding its testing recommendations.[8]

	Yellow CR <1.0 TP<2%	Orange CR 1-3.9 TP 2-4.9%	Red CR 4-7 TP 5-8%	Purple CR >7-13.9 TP >8%	“Deep Purple” CR >14
Staff	Symptomatic and response testing.	Symptomatic and response testing.	Symptomatic and response testing + Every 2 weeks asymptomatic testing.	Symptomatic and response testing + Every 2 weeks asymptomatic testing.	Symptomatic and response testing + Weekly asymptomatic (PCR or twice weekly antigen testing).
Students K-12	Symptomatic and response testing.	Symptomatic and response testing.	Symptomatic and response testing + Every 2 weeks asymptomatic testing.	Symptomatic and response testing + Every 2 weeks asymptomatic testing.	Symptomatic and response testing + Weekly asymptomatic (PCR or twice weekly antigen testing).
Terms	CR = adjusted case rates.	TP = test positivity		Symptomatic testing = Testing an individual with symptoms.	Response testing = Testing individuals with or without symptoms, after a known or suspected exposure to a positive case.

Cal/OSHA Requires Employee Testing. Any school currently open is subject to the minimum testing requirement standards established by Cal/OSHA. These standards include offering “response” testing (on site or through a third party) testing for employees exposed at work, and outbreak testing for everyone weekly until no longer considered an outbreak.[9]

III.       School Reopening Recommendations (Guidance, pp. 14-30)

Please be aware, the Guidance has many recommendations related to reopening that are not requirements, per se.

A. Implement Phased-In Reopening.

K-12 grades should use a phased-in model to reopen. The Guidance states that schools should begin with the youngest and most impacted students. Some examples of phased re-openings include hybrid models; gradually allowing specified grades or a percentage of each grade in-person; gradually increasing the amount of students per grade or school site.

Even if a school began implementing a phased approach to in-person instruction that was cut short due to entering the Purple Tier, the school may continue phasing-in reopening.

B. Infection Mitigation.

Each mitigation strategy is intended to be layered in with other strategies to maximize effectiveness of each one. CDPH lists these mitigation strategies in order of importance: Face Coverings; Stable Groups; Physical Distancing; Ventilation; Hand Hygiene; Symptom Screening and Exclusion; and Testing. Eating and drinking indoors without physical distancing, and staff-to-staff contact, appear to be the most infectious scenarios, and are to be avoided.

Face Coverings. Face coverings must be worn at all times, unless exempted (students under 2 and people with documented medical condition).[10] Face coverings may only be removed during snacks, naptime, or when being replaced. Training must be provided to staff, students and families, and face coverings must be provided if needed. Face coverings are to be worn at all times to include: sports; and on buses and other LEA vehicles. LEAs must develop protocols to provide a face covering to students that inadvertently fail to bring a face covering to school.

If a student or employee is exempt, the LEA should employ: distancing; clear physical barriers; reduction of time with others; increased outdoor time; and/or increased ventilation. *NOTE: CDPH considers 3-ply surgical masks more effective than cloth for employees with frequent close contact.[11] “Persons exempted from wearing a face covering due to a medical condition, as confirmed by school district health team and therapists, must wear a non-restrictive alternative, such as a face shield with a drape on the bottom edge, as long as their condition permits it.” (Guidance, p. 16.)

Participants in youth and adult sports should wear face coverings when participating in the activity, even with heavy exertion as tolerated, both indoors and outdoors.

Stable Groups. “Stable Groups” do not mix with any other groups for any activities. Stable Groups are different from Cohorts, which are groups of students who are meeting for targeted supports and intervention services, under the direction of an LEA, while the school is closed to in-person instruction and in addition to distance learning. Sometimes these groups are also called “learning hubs” or “pods.” Regardless of the name, all of the provisions in the Cohorting Guidance must be followed for such cohorts to meet, whether they are operated by LEAs, non-profits, or other providers, as a maximum of 16 individuals (students and staff). “Cohort” does not refer to the more general “stable groups.”

Elementary School: Stable groups stay together all day with a core teacher. Stagger lunch and recess. Rotate schedules, such as: one group on site Monday and Tuesday; another group on site Thursday and Friday; alternate weeks; one group on site in morning; and another group on site in afternoon. Conduct electives virtually.

Middle/High School:  Minimize crossover of staff. Examples: keep the group in one classroom and have teachers rotate in; stagger passing schedules; block schedules to reduce number of courses per day; and virtual electives.[12]

The Guidance notes the potential for inequity in establishing “stable groupings” and recommends remaining inclusive with access for all student populations.

Physical Distancing.  Maximize distancing in hallways by reconfiguring bell schedules and start and end times, and use multiple entrances if feasible. Avoid necessitating the use of lockers.

Buses. Distancing between students and driver. Open as many windows as possible. Masks required and provided if needed.

Classrooms. Students and teacher 6 feet distancing. Where 6 feet is not feasible, and with documented good faith effort, can reduce to 4 feet, with increased ventilation, partition, and/or minimized one-on-one.

Outdoor spaces. Maximize use of outdoor space. Band and choir permitted outdoors only; woodwinds not permitted at all.

Meals. Serve meals outside or in stable group classroom. Stagger meals. Avoid family/buffet style. Strongly avoid indoor dining without distancing. Minimize congregation of adults in break rooms. Allow higher risk staff to telework if appropriate. Conduct staff meetings and training outside or virtually.

Ventilation. Use filters with Minimum Efficiency Reporting Value (“MERV”) of at least 13. Use open windows and outdoor air unless asthma issue or poor air quality. [13]

Hand Hygiene. Teach and reinforce washing hands frequently or using hand sanitizer, not touching eyes, nose, mouth; and covering coughs and sneezes.

Symptom Screening and Exclusions of Staff and/or Students. LEAs should allow students and staff who are sick or had contact with a confirmed case to stay at home without fear of reprisal. All staff and students should screen at home before leaving for school. Students or staff showing COVID-19 symptoms[14] must be immediately isolated until they can leave, and recommended for testing.

Staff and students with symptoms may not return until all three conditions are met:

1. Symptoms have improved; AND
2. 24 hours have passed since fever resolved without medication; AND
3. They either have a negative test[15], medical documentation that their symptoms are not COVID-19, or at least 10 days have passed.[16]

Training. Mandatory training of all Staff and Families in: face coverings; distancing; symptom screening; preventing spread; increased sanitation; and staying home when sick.

C. Cleaning and Disinfection

This guidance revises prior advice related to disinfection. While frequent cleaning with water and soap is still required, due to chemical risk to students, disinfection with specified products is now only recommended after a case has been identified, in the spaces where the case spent a large amount of time (e.g. classroom or office). Clean frequently-touched surfaces at school and on school buses daily, such as sink handles, shared tables and desks, door handles, and shared technology.

IV. LEA Response to Confirmed or Suspected Cases of COVID-19 (Guidance, pp. 31-36)

The Guidance includes this table summary of which actions should be taken in response to a confirmed case or suspected case of COVID-19.

Actions to take if there is a confirmed or suspected case of COVID-19 in a school
	Student or Staff with:	Action	Communication with school community
1.	COVID-19 symptoms (e.g., fever, cough, loss of taste or smell, difficulty breathing) Symptom screening: per CDC Symptom of COVID-19. [17]	• Send home if at school. • Recommend testing (If positive, see #3, if negative, see #4). • School/classroom remain open.	• No action needed.
2.	Close contact with a confirmed COVID-19 case.	• Send home if at school. • Exclude from school for 10 days from last exposure, per CDPH quarantine recommendations. [18] • Recommend testing 5-7 days from last exposure (but will not shorten 10-day exclusion if negative). • School/classroom remain open.	• Consider school community notification of a known exposure. No action needed if exposure did not happen in school setting.
3.	Confirmed COVID-19 case infection.	• Notify the Local Health Department within 24 hours. • Exclude from school for 10 days from symptom onset date or, if asymptomatic, for 10 days from specimen collection date. • Identify school contacts[19], inform the Local Health Department of identified contacts, and exclude contacts (possibly the entire stable group from school for 10 days after the last date the case was present at school while infectious). • Recommend testing asymptomatic contacts 5-7 days from last exposure and immediate testing of symptomatic contacts (negative test results will not shorten 10-day exclusion). • Disinfection and cleaning of classroom and primary spaces where case spent significant time. • School remains open.	• School community notification of a known case. • Notification of persons with potential exposure if case was present in school while infectious. **NOTE: There is also a duty to send a Notice of Potential COVID-19 Exposure to employees and each union representative within 24 hours per the Cal/OSHA regulations.[20] *Sample CDPH Notices Attached
4.	Symptomatic person tests negative or a healthcare provider has provided documentation that the symptoms are typical of their underlying chronic condition.	• May return to school after 24 hours have passed without fever and symptoms have started improving. • School/classroom remain open.	• Consider school community notification if prior awareness of testing.

Outbreak.  In addition, an “outbreak” is defined as 3 or more confirmed or probable cases of staff or students within a 14-day period. During an outbreak, the LEA will coordinate an investigation with its Local Health Department to identify, isolate, and/or test all potential cases and contacts.  Under Cal/OSHA regulations, each LEA must notify its Local Health Department of an outbreak within 48 hours.[21]

School Closure Determinations.   Consult with your LHO regarding closing school for at least 14 days when, within a 14-day period:

1) an outbreak has occurred in 25% or more stable groups in a school; or

2) at least three outbreaks have occurred in the school and more than 5% of the school population is affected.

Schools may reopen after consulting with the Local Health Department, cleaning and disinfection, and the public health investigation. (Guidance, p. 37.) Schools may also close voluntarily even when the two criteria has not been met.

V. New Mandatory Reporting Requirements (Guidance, pp. 44-49)

Report Confirmed Cases to LHO within 24 Hours. Report a confirmed employee or student case (who was present on campus), within 24 hours to the LHO by telephone (name, address, telephone number, date of birth of person who tested positive, date of test, school site affected, and contact info of person reporting).

Report Reopening Status to State Every Two Weeks. Beginning on January 25, 2021, and continuing every other Monday, each LEA shall notify the California Department of Public Health through an online CDPH link whether it is providing: full-time in-person instruction, part-time in-person instruction, cohort only services, or no in-person instruction or services of any kind.

VI. Vaccines (Guidance, p. 40)

Although there is currently no vaccine mandate by the federal or state governments, CDPH strongly recommends that all persons eligible to receive COVID-19 vaccines receive them at the first opportunity. As of January 14, 2021, children under age 16 are not eligible for the vaccine since trials for that group are still underway. CDPH will issue more detailed vaccine guidance on its website later. We recommend consulting with legal counsel before implementing any vaccine requirement.[22]

VII.     Links to Resources (Guidance, p. 41)

California has launched a “one stop shop” website “Safe Schools for All Hub” through which school administrators can seek assistance.

Safe Schools for All Hub: https://schools.covid19.ca.gov/

Testing Guidance:  https://www.cdph.ca.gov/Programs/CID/DCDC/CDPH%20Document%20Library/COVID-19/K12_School_Testing_Considerations_Information.pdf

LHO Directory by county: https://www.cdph.ca.gov/Programs/CCLHO/Pages/CCLHO-Health-Officer-Directory.aspx

Access State Technical Assistance: https://schools.covid19.ca.gov/

Regularly review for updated guidance:

CDPH: https://www.cdph.ca.gov/Programs/CID/DCDC/Pages/Guidance.aspx; and

CDE: https://www.cde.ca.gov/ls/he/hn/coronavirus.asp

See also the appendix for several notices promulgated by CDPH.

Please contact our office with questions regarding this Legal Update or any other legal matter.

 

The information in this Legal Update is provided as a summary of law and is not intended as legal advice.  Application of the law may vary depending on the particular facts and circumstances at issue.  We, therefore, recommend that you consult legal counsel to advise you on how the law applies to your specific situation.

 

© 2021 School and College Legal Services of California

 

All rights reserved.  However, SCLS grants permission to any current SCLS client to use, reproduce, and distribute this Legal Update in its entirety for the client’s own non-commercial purposes.

 

 

 

APPENDIX: SAMPLE CDPH NOTIFICATIONS

SCHOOL EXPOSURE TO A CASE OF COVID-19 NOTIFICATION

 

[K-12 SCHOOL NAME/LETTERHEAD]

From School Principal (or Designee)

Date

 

Dear Parents/Guardians,

We would like to inform you that we have been notified about a confirmed case of COVID-19 (Coronavirus Disease 2019) in a member of our school community. The individual who tested positive (the “case”) was last on school premises on [DATE]. All school areas where the case spent time will be cleaned and disinfected before they are in use again.

Our school is working with the [LOCAL HEALTH DEPARTMENT] to follow up with the case and will reach out to all persons who are identified as having had close contact with the case to recommend home quarantine and COVID-19 testing. If you or your child are not contacted, it means that you or your child were not identified as exposed to the case.

Please remind your child to use their face covering, stay at least 6 feet from other people, and wash their hands often with soap and water for at least 20 seconds.

Symptoms of COVID-19 may appear 2-14 days after exposure to the virus and include:

• Fever or chills
• Cough
• Shortness of breath or difficulty breathing
• Fatigue
• Muscle or body aches
• Headache
• New loss of taste or smell
• Sore throat
• Congestion or runny nose
• Nausea or vomiting
• Diarrhea

 

Anyone with COVID-19 symptoms should be tested. However, many infected people do not develop symptoms, which is why it is recommended that exposed people be tested whether they have symptoms or not.

Ensuring the health and safety of our students, teachers, and staff members is of the utmost importance to us. If you have any questions or concerns, please contact [CONTACT NAME] at XXX-XXX-XXXX.

Sincerely,

 

 

COVID-19 SCHOOL OUTBREAK NOTIFICATION

[TK-12 SCHOOL NAME/LETTERHEAD]

From School Principal (or Designee)

Date

 

Dear Parents/Guardians, Teachers, and Staff Members,

We would like to inform you that we are working with the [LOCAL HEALTH DEPARTMENT] on their investigation of a COVID-19 outbreak in our school community. Our school is working with the [LOCAL HEALTH DEPARTMENT] to follow up with all cases and symptomatic contacts to identify all exposed persons and recommend home quarantine and testing. If you or your child are not contacted, it means that you or your child were not exposed to either a case or a symptomatic contact.

If you are a parent/guardian, please remind your child to use their face covering, stay at least 6 feet from other people, and wash their hands often with soap and water for at least 20 seconds.

Symptoms of COVID-19 may appear 2-14 days after exposure to the virus and include:

• Fever or chills
• Cough
• Shortness of breath or difficulty breathing
• Fatigue
• Muscle or body aches
• Headache
• New loss of taste or smell
• Sore throat
• Congestion or runny nose
• Nausea or vomiting
• Diarrhea

 

Anyone with COVID-19 symptoms should be tested. However, many infected people do not develop symptoms, which is why it is recommended that exposed people be tested whether they have symptoms or not.

Ensuring the health and safety of our students, teachers, and staff members is of the utmost importance to us. If you have any questions or concerns, please contact [CONTACT NAME] at XXX-XXX-XXXX.

Sincerely,

 

 

SCHOOL CLOSURE DUE TO COVID-19 NOTIFICATION

[TK-12 SCHOOL NAME/LETTERHEAD]

From School Principal (or Designee)

Date

Dear Parents/Guardians, Teachers, and Staff Members,

We are informing you that we are closing our school, starting on [DATE] due to the ongoing COVID-19 outbreak and likely continuing transmission at our school. In consultation with the [LOCAL HEALTH OFFICER], we have been advised that the school should be closed for 14 days to prevent further transmission of COVID-19 and to clean and disinfect the school before reopening on [DATE].

During school closure, the school will switch to online teaching to continue our classes; please see attached information sheet on how students can sign in to continue their schoolwork online. The [LOCAL HEALTH DEPARTMENT] will also continue to follow-up with cases and contacts during school closure to ensure isolation and quarantine and testing.

If upon school reopening, your child is feeling ill or having a fever or symptoms of COVID-19, even if symptoms are very minor, please do not send your child to school and consider getting your ill child tested for COVID-19. If your child is well without any symptoms, please remind your child before going back to school to use their face covering, stay at least 6 feet from other people, and wash their hands often with soap and water for at least 20 seconds. School staff should call in sick and stay home if having a fever or symptoms of COVID-19 and consider getting tested.

Symptoms of COVID-19 may appear 2-14 days after exposure to the virus and include:

• Fever or chills
• Cough
• Shortness of breath or difficulty breathing
• Fatigue
• Muscle or body aches
• Headache
• New loss of taste or smell
• Sore throat
• Congestion or runny nose
• Nausea or vomiting
• Diarrhea

 

Ensuring the health and safety of our students, teachers, and staff members is of the utmost importance to us. If you have any questions or concerns, please contact [CONTACT NAME] at XXX-XXX-XXXX.

 

Sincerely,

 

[1] https://www.cdph.ca.gov/Programs/  CID/DCDC/CDPH% 20Document%20Library/COVID-19/Consolidated_Schools_Guidance.pdf

[2] CDPH Cohort Guidance adopted on August 25, 2020 and revised September 4, 2020; https://www.cdph.ca.gov/Programs/CID/DCDC/Pages/COVID-19/small-groups-child-youth.aspx

[3] https://schools.covid19.ca.gov/

[4] NOTE: The prior K-6 waiver process is no longer in effect. Schools that have already opened under a previously granted waiver may continue to stay open under that waiver, even if the current rules would dictate being closed.

[5] See our Cal/OSHA Legal Update – Addendum to Legal Update Memo No. 72-2020 https://sclscal.org/addendum-legal-update-memo-no-72-2020-cal-osha-issues-emergency-covid-19-regulations-for-all-employers-k-12/; see also https://www.dir.ca.gov/dosh/dosh_publications/CPP.doc. The CPP became a requirement effective December 1, 2020.

[6] CDPH CSP Checklist Form: https://www.cdph.ca.gov/Programs/CID/DCDC/CDPH%20Document%20Library/COVID-19/COVID19_School_Guidance_Checklist.pdf. We recommend you consult with legal counsel if your pre-existing CPP and MOU have any terms inconsistent with these new guidelines.

[7] “CR” means adjusted case rate.

[8]  https://www.cdph.ca.gov/Programs/CID/DCDC/CDPH%20Document%20Library/COVID-19/K12_School_Testing_Considerations_Information.pdf

[9] See Cal/OSHA COVID-19 Emergency Temporary Standards Frequently Asked Questions for complete guidance on testing: https://www.dir.ca.gov/dosh/coronavirus/COVID19FAQs.html#testing

[10]  For all exemptions, see: https://www.cdph.ca.gov/Programs/CID/DCDC/Pages/COVID-19/guidance-for-face-coverings.aspx ).

[11]  Purchase face coverings and other PPE through DGS: https://covid19.ca.gov/masks-and-ppe/ .

[12]  More ideas: https://k12playbook.ccee-ca.org/guidebook/schedules-and-cohorts/#tab3 .

[13]  See ventilation guidance: https://www.ashrae.org/technical-resources/reopening-of-schools-and-universities .

[14] Covid syptoms: https://www.cdc.gov/coronavirus/2019-ncov/symptoms-testing/symptoms.html

[15] An employer may not require a negative test for a return to work under the Cal/OSHA regulations, and a negative test will not shorten the 10-day exclusion period. (Guidance, p. 32).

[16]  CDPH Return to Work Guidance https://www.cdph.ca.gov/Programs/CID/DCDC/Pages/COVID-19/Guidance-on-Returning-to-Work-or-School-Following-COVID-19-Diagnosis.aspx

[17] https://www.cdc.gov/coronavirus/2019-ncov/community/schools-childcare/symptom-screening.html#symptoms

[18] https://www.cdph.ca.gov/Programs/CID/DCDC/Pages/COVID-19/COVID-19-Quarantine.aspx

[19] A contact is defined as a person who is within 6 feet from a case for more than 15 minutes cumulative within a 24-hour period, regardless of face coverings.

[20]  See our Cal/OSHA Legal Update – Addendum to Legal Update Memo No. 72-2020 https://sclscal.org/addendum-legal-update-memo-no-72-2020-cal-osha-issues-emergency-covid-19-regulations-for-all-employers-k-12/

[21] See our Cal/OSHA Legal Update – Addendum to Legal Update Memo No. 72-2020 https://sclscal.org/addendum-legal-update-memo-no-72-2020-cal-osha-issues-emergency-covid-19-regulations-for-all-employers-k-12/

[22]   More information related to vaccine guidance is available on the Safe Schools for All Hub at https://covid19.ca.gov/vaccines/