SA Health has released a new Exposure Response Framework that will apply from 23/11/2021.  This new framework brings welcome clarity to businesses and individuals on the vital question of how exposures to COVID-19 infected persons will be managed moving forward.  This Framework is something that ACAPMA has been actively working on with Health and represents a significant step towards ensuring that once the economy opens, it can stay opens.  Like all things there are still elements to be addressed, but a risk matrix approach that recognises the risk mitigation impacts of short exposure, masks and vaccination is a welcome step forward.

The Exposure Response Framework details how Health will classify persons who are exposed to an infected person, namely what will determine if they are a Close Contact UNVACCINATED, Vaccinated Close Contact, Casual Contact or Low Risk Casual Contact.

UNVACCINATED Close Contact

Exposed person must get a PCR test and isolate for 14 days regardless of the results.  Must also get a test on day 6 and day 13 or at any time if symptoms develop. All vaccinated people in the exposed persons household must get a test on day 1 and day 6 and isolate for 7 days unless they can be appropriately separate from the exposed person.  Any unvaccinated persons must follow full quarantine and testing requirements in the same manner as the exposed person unless they can be appropriately and fully separated from the exposed person.

Vaccinated Close Contact

Exposed person must get PCR test and isolate for 7 days regardless of results.  Must also get a PCR surveillance test on day 6 and day 13 or at any time if symptoms develop.  After release from isolation must wear a mask at all times when around others, not enter high risk settings (health care etc) other than for essential reasons, avoid non essential activities.  All vaccinated people in the exposed persons household must get a test on day 1 and day 6.  Any unvaccinated persons must follow full quarantine and testing requirements in the same manner as the exposed person unless they can be appropriately and fully separated from the exposed person.

Casual Contact

Exposed person must get a PCR test and isolate until results are received.  After receiving a negative result must wear a mask around others at all times and avoid non essential activities for 14 days.  Exposed person must also get PCR surveillance tested again on day 6 and on day 13 or at any time if symptoms develop.  No further obligations on the exposed persons household

Low Risk Casual Contact 

Exposed person must observe for symptoms and get a test if symptoms develop.  No further obligations on exposed person or their household.

What’s new in the Framework?

Risk controls, including masks, space and importantly vaccination is now taken into account in deciding if a contact was close or casual.

What’s missing from the Framework?

The Framework is complete, but it should be noted that Health may also adjust the isolation requirements for the contacts over time.

What does it mean for fuel wholesale and retail?

That missing element is worth remembering, but for now it is clear that for most fuel retail and transport staff, as long as the staff are vaccinated and wearing their masks, usual contact with an infected customers will most likely result in the employee being deemed to be Low Risk Contact which means that if exposed they will be required to monitor for symptoms and get a PCR test if they develop and symptoms, but will not be required to isolate.

How does the Framework work?

When there is an exposure to an infected person then the Framework will be used to determine the type of contact the exposed person is.

To determine the level of contact a series of questions will need to be asked and answered.  Some of these questions are about the exposure itself (time, distance and location), some are about control measures (masks) and some about the exposed person themselves (vaccination) .

The first question is;  Is the Exposed Person Vaccinated?

  • If the answer is NO then the Exposed Person will either be an UNVACCINATED Close Contact or a Casual Contact, depending on the nature of the exposure and the size and location of the venue
  • If the answer is YES then the Exposed Person will either be a Vaccinated Close Contact, a Casual Contact or a Low Risk Casual Contact, depending on the nature of the exposure and the size and location of the venue

The remaining questions have to do with the length of exposure, distance, masks and location.

Example 1 – vaccinated staff exposed to infected customer

Krystal is a console operator in a retail fuel site, and one of her customers tests positive for COVID-19.  Krystal is now an exposed person.

We work through the questions to find the correct classification in the matrix;

  • Vaccination – Was Krystal vaccinated? The answer is YES so the first layer of the matrix is used.
  • Distance – Did the Krystal come close (less than 1.5m) to the infected person?  The answer in this case is No.
  • Time – Was the exposure a) less than a minute, b) 1-15 minutes or c) more than 15 minutes?  The answer in this case is b) 1-15 minutes
  • Location – Was the exposure a) outdoor, b) indoor in a large space(>100sqm) or c) indoor in a small space (<100sqm)?  The answer in this case is b) indoor in a large space (>100sqm)
  • Masks – Were the infected and exposed person wearing masks?  In this case Krystal was wearing a mask, but the customer was not

Result:  Because Krystal is vaccinated, kept her distance, the exposure was less than 15mins and the exposure happened in an indoor large space, Krystal is a Low Risk Casual Contact and as such will need to monitor for symptoms and if symptoms appear she will need to get tested.

It is worth noting that;

  • Even with vaccination and the staff wearing masks if the space was smaller (less than 100sqm) then in this case Krystal would be a Vaccinated Close Contact and would need to isolate because the customer was not wearing a mask
  • If Krystal had not been vaccinated then in this case she would have been a Casual Contact and would need to isolate – and if the space had been smaller she would have been an UNVACCINATED Close Contact

 

Example 2 – vaccinated staff exposed to infected staff (during shift change over)

Amy is a console operator in a retail fuel site, and the worker who works after her tests positive for COVID-19.  Amy is now an exposed person.

We work through the questions to find the correct classification in the matrix;

  • Vaccination – Was Amy vaccinated? The answer is YES so the first layer of the matrix is used.
  • Distance – Did the Amy come close (less than 1.5m) to the infected person?  The answer in this case is No.
  • Time – Was the exposure a) less than a minute, b) 1-15 minutes or c) more than 15 minutes?  The answer in this case is b) 1-15 minutes
  • Location – Was the exposure a) outdoor, b) indoor in a large space(>100sqm) or c) indoor in a small space (<100sqm)?  The answer in this case is c) indoor in a small space (<100sqm)
  • Masks – Were the infected and exposed person wearing masks?  In this case Amy was wearing a mask, as was her colleague

Result:  Because Amy is vaccinated, kept her distance, the exposure was less than 15mins and the exposure happened in an indoor small space but both Amy and the infected person were wearing masks, Amy is a Casual Contact and as such will need to get tested and isolate until a negative result, wear a mask and avoid non essential activities for 14 days and get tested again on day 6 and day 13.

It is worth noting that;

  • If Amyl had not been vaccinated then in this case she would have been an UNVACCINATED Close Contact

Learnings for Fuel Retail and Wholesale

The above example highlights the importance to the business of staff being vaccinated, wearing masks and keeping their distance from customers AND OTHER STAFF.  Particularly when it is noted that the federal government support payments no longer apply when a staff member is required to isolate, meaning that they would either need to use their accrued leave or take leave without pay, and in the circumstance of a Close Contacts (UNVACCINATED and Vaccinated) this can include the whole household having to isolate

In order to minimise the impact of exposures to the operation of the business fuel retail and wholesale business should;

  • Ensure staff are maintaining 1.5 meter distance from each other and customers
  • Ensure staff shift change and cross over is minimised, ideally less than 15 minutes
  • Encourage staff vaccination

“ACAPMA is pleased to have clarity on exposure response as we move towards COVID-19 as an endemic disease.  There are still questions of operation and response, including cleaning response and isolation leave and payment implications.  ACAPMA is working through these with authorities and members, and encourages members to put forward their questions now, so that we can prepare for a much welcome open economy” explained ACAPMA Executive Manager for Employment and Training, Elisha Radwanowski.

More Information

General Information see; https://www.sahealth.sa.gov.au/wps/wcm/connect/public+content/sa+health+internet/conditions/infectious+diseases/covid-19/testing+and+tracing/test%2c+trace%2c+isolate+and+quarantine

Business response to exposure see; https://www.sahealth.sa.gov.au/wps/wcm/connect/bc5f555b-6b89-4389-8d90-07d1e0ce068a/21113.3+COVID+Ready+General+Business-151121.pdf?MOD=AJPERES&amp;CACHEID=ROOTWORKSPACE-bc5f555b-6b89-4389-8d90-07d1e0ce068a-nQxLgTF

Here to Help

 HR Highlights are things to consider, implement and watch out for in your business.  They are provided as general information for you to consider and do not constitute advice.  You should seek further advice on your situation by contacting your legal advisor.  ACAPMA members can access resources and receive advice, guidance and support from the ACAPMA employment professionals via employment@acapma.com.au , it is free for members.  ACAPMA Membership delivers this and more benefits, see; https://acapma.com.au/membership/  for more information.

Elisha Radwanowski BCom(HRM&IR)
ACAPMA

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