It happened in Missouri. (Twice.) It happened in New York, and then again in Oklahoma.

Salon professionals are testing positive for COVID-19 and they will continue to for as long as COVID-19 exists.

Hence the title of this article. I’m using “when” (not “if”) intentionally. No matter what precautions you take in your salon, one of your employees will likely have a positive test at some point in the future. Consider it an inevitability and plan for it today.

What should my COVID-19 response plan include?

1.) A notification script.

How, exactly, will you notify customers? Which words will you use? What guidance will you give them? Which questions can you preemptively answer? What resources will you refer them to?

This message should be crafted long before you need it. The content of this message will be highly dependent on the individual salon, so by way of an example, I’ll share the one I’ve drafted for mine.

“We have just learned that our employee tested positive for COVID-19 and that you may have closely interacted with this employee in some capacity over the last two weeks. As we have been far exceeding both the state and federal pandemic guidelines, it is highly unlikely anyone else was exposed. However, in an abundance of caution, we are choosing to get tested and self-isolate, and are encouraging our clients to please do the same. We will keep you updated through the salon’s website and via email. If you have any questions, please contact Tina Alberino at mysecret@emailaddress.com.”

In our script, which is written to be read aloud, posted, and texted, our COVID-19 precautions are linked in the content, as is our site’s COVID-19 blog category URL (which displays any and all posts relating to COVID-19) and my actual company email address.

2.) A procedure for notifying the clients.

Does your salon software allow you to filter clients by the date they last visited? If so, can you also easily compose emails and text messages exclusively for them? How?

Figure it out today. Write down the steps if you don’t think you’ll remember them. Contact tracers with the CDC and/or your local health department may require that data, so learn how to easily export it now.

Once you’ve figured out how to quickly send communications to that subset of clients, create a plan for contacting them via phone as well. If your salon has been servicing a large number of clients (more than can be contacted by phone by a single person in a single day), I would recommend dividing the list among your employees to ensure they’re all notified as expeditiously as possible. If you suspect this measure will be necessary, inform and train the employees on how to conduct those calls in advance.

3.) A public statement.

As soon as the news breaks that one of your professionals tested positive, the public will look to you for an explanation. They’ll want to know what you did to protect your customers and what you’re doing moving forward. Will you stay open? Will you close the salon until all of the employees are tested?

Answer all of the questions reporters and the public are likely to ask and put those answers in writing.

Should I reveal the identity of an employee infected with COVID-19?

Absolutely not. First, you’re unlikely to know which employee tested positive to begin with unless they tell you. Should an employee test positive, you will be contacted by a health department official who will notify you. They are not permitted to share that employee’s name.

Employees have the right to a reasonably safe work environment and the right to privacy. (As a matter of fact, those rights are entrenched several in federal laws such as HIPAA, the FMLA, and the ADA.) So, how do we reconcile those things with our responsibility to our professionals and clients?

We comply with the laws and protect the employee’s identity to the very best of our abilities while providing the appropriate notice to those who may have come into contact with that employee.

The EEOC has clarified when employers can ask about travel or symptoms during the pandemic. I recommend reading the entirety of that page, but I’ve included the most relevant parts here.

Directly from the EEOC:

Generally, a disability-related inquiry or medical examination of an employee is job-related and consistent with business necessity when an employer has a reasonable belief, based on objective evidence, that:

• An employee’s ability to perform essential job functions will be impaired by a medical condition; or
• An employee will pose a direct threat due to a medical condition.

This reasonable belief “must be based on objective evidence obtained, or reasonably available to the employer, prior to making a disability-related inquiry or requiring a medical examination.

All information about applicants or employees obtained through disability-related inquiries or medical examinations must be kept confidential.

And further down, they state in all bold:

Based on guidance of the CDC and public health authorities as of March 2020, the COVID-19 pandemic meets the direct threat standard.

Per the EEOC’s guidance, during a pandemic, employers may:

• send employees home if they display COVID-like symptoms
• ask sick employees if they are experiencing COVID-like symptoms
• ask why individuals were absent from work why they were absent if the employer suspects it was for a medical reason
• measure employee body temperature
• follow the CDC and state/local public health guidelines regarding information needed to permit an employee’s return to the workplace after traveling, including COVID-19 test results
• require employees to wear PPE and adopt infection control practices designed to reduce transmission of pandemic infection

Employers may be held legally responsible for purposeful concealment of a workplace danger.

Employers may not disclose the identity of an employee diagnosed with or presumed to have COVID-19, and are required by law to maintain the privacy of any employee-related health information they gather—including their COVID-19 status.

What should I do if an employee tests positive for COVID-19?

Regardless of the precautions you’ve taken, you will be in for an intensely stressful time. Even if the employee was unlikely to expose anyone else, you’re going to be in charge of damage control moving forward. Here are my recommendations for what to do after you’ve notified all of your employees, even if your local laws do not require business owners to alert customers.

1.) Contact the health department and/or OSHA (if they didn’t contact you first).

OSHA recently issued guidance on employers’ obligation to record COVID-19 cases in the workplace. (Read that article ASAP.)

Once you have notified the local health department, follow their guidelines and recommendations moving forward in addition to those recommended here. Cooperate with any contact tracing efforts they may require you to participate in.

2.) If your team has not been wearing masks or face coverings 100% of the time, send them all home immediately.

I’m not going to ask why you chose not to wear masks or face coverings. I’m not going to let you see the fatal levels of side-eye I’m shooting your way. All I’m going to say is this: we don’t have the luxury of isolation from the general public during our routine work day the way most office workers do.

Masks are non-negotiable for us.

Masks should always have been non-negotiable for us. Every working professional should have been taking every effort possible to protect their lungs—not just from the virus, but from all of the other contagions, airborne debris, and chemical fumes we’re routinely exposed to.

If—for whatever reason—you made the choice not to enforce rules requiring face coverings in your salon, you have made your situation far more complicated and prolonged than it would have otherwise been. I’m not just talking about how your cute little act of defiance or complacency potentially impacted your community (and most certainly impacted the public’s opinion of our industry), I’m talking about the immense damage you’ll have done to your personal brand and the revenue losses you’re likely to endure as a result.

If you have suddenly made the choice to start behaving more responsibly moving forward, those losses start now. Cancel the rest of the salon’s appointments. Everyone in the building should immediately be sent home until they meet the standards for returning to work. You’re effectively closed for business until the salon has been fully disinfected and you have enough confirmed negative employees to reopen.

Because everyone in your salon has been in close-contact and breathing all over each other for at least ten or more minutes each service, it’s pretty likely that your first positive employee won’t be the only one…and that you will have a number of clients who test positive also. Pray they (and the public at large) don’t decimate your salon’s online reputation.

But what if we have been complying with employee and customer mask requirements?

Keep on keeping on. Your lone infected employee could have gotten COVID-19 anywhere, but since they’ve been wearing a mask in your facility, it’s unlikely they infected anyone while under your roof. Unless your health department (or other local authority) requires you to close, stay open and proceed with the rest of the steps.

Also, take a few minutes of your day to read the overwhelming positive support for The Clip Joint, a Missouri salon where an employee recently tested positive. They took every possible precaution to protect their customers and their appreciation shows. While The Clip Joint took five full days to notify customers, a length of time I consider irresponsible and inexcusable, it’s noteworthy to mention they were not actually legally required to notify anyone.

We should also be rejoicing that the first 40+ clients exposed by the Great Clips employees in Missouri have all tested negative—so far—likely thanks to their adherence to social distancing protocols, including mask requirements. These early results are extremely promising for those in our industry who are enforcing mask requirements.

2.) Get your team to make the client notification calls immediately while you prepare text and email notifications.

If you have more numbers to call than one person can handle, every employee with a phone should be using it to call each client that visited the facility over the last two weeks. Have them read the script and instruct the clients to direct any questions they have to you.

If you have the software infrastructure to support sending electronic notifications to every client the salon serviced in the last two weeks, get those messages configured and sent out now. This shouldn’t take longer than a few minutes, since you wrote your notice in advance.

3.) Publish your statement to your socials and refer all media requests to that statement.

It can be easy to unintentionally say something damaging when confronted by the media. Throughout the years, I’ve seen salon owners admit to misclassification and wage theft on national television and in trade magazines. Throughout the pandemic, I’ve seen salon owners and professionals alike show how painfully ignorant they are about sanitation, disinfection, and sterilization—even while using our “superior knowledge of bacteriology” to make a case for a swift reopening.

Don’t risk a misstep. Instead, refer any press to your official statement.

4.) Disinfect the facility.

Follow the CDC’s Cleaning and Disinfection for Community Facilities with Suspected/Confirmed COVID-19. (Essentially, it boils down to “SCRUB ALL OF THE THINGS.”)

Here is where we have to make a distinction between what you’re required to do and what you’d be wise to do despite not being required to do it.

Whether or not the following are required by your local authorities, they are objectively responsible things to do. Therefore, I personally feel they should be done and have made these steps part of my own plan.

5.) Notify all vendors and delivery companies whose employees may have had contact with the employee.

If there is a possibility that the employee had close contact with a non-client while working in the salon, call those companies and inform them. (“Close contact” means being within six feet of the sick employee for a prolonged period, 10-30 minutes.)

6.) Keep COVID-19 positive employees home beyond the minimum period of time recommended.

Employers can utilize one or both of the following strategies recommended by the CDC when it comes to determining when an employee should return to work. These strategies are being referred to as “symptom-based” and “test-based.”

Symptomatic employees may discontinue isolation under the following conditions:

• At least 3 days (72 hours) have passed since recovery defined as resolution of fever without the use of fever-reducing medications and improvement in respiratory symptoms (e.g., cough, shortness of breath); and,
• At least 10 days have passed since symptoms first appeared.

(Text emphasis comes directly from the CDC.)

If you have access to testing and sufficient laboratory capacity, the test-based strategy looks like this:

Persons who have COVID-19 who have symptoms and were directed to care for themselves at home may discontinue isolation under the following conditions:

• Resolution of fever without the use of fever-reducing medications and
• Improvement in respiratory symptoms (e.g., cough, shortness of breath), and
• Negative results of an FDA Emergency Use Authorized COVID-19 molecular assay for detection of SARS-CoV-2 RNA from at least two consecutive respiratory specimens collected ≥24 hours apart (total of two negative specimens).

(Again, text emphasis comes directly from the CDC.)

The CDC also notes that there have been reports of prolonged detection of RNA without direct correlation to viral culture (translated: detecting viral RNA via PCR does not necessarily mean that infectious virus is present), but I’d recommend against being influenced by this information and urge you instead to listen to the lawyers. Many public health announcements are advisory in nature. During the pandemic, it is unwise to act on unconfirmed data unless that data encourages taking further precautions.

It is better to be safe than sorry.

When can my employees come back to work?

Your local authorities will likely provide further guidance, but my recommendation—as always—is to listen to the lawyers and exercise the utmost caution.

Legal experts and human resource blogs are recommending a combined approach, advising that employers instruct infected employees to remain home for the longer of the period of time recommended by their health care provider or the applicable health department, or until:

• at least 72 hours have passed since the resolution of fever without the use of fever-reducing medications AND improvement of respiratory symptoms, AND
• at least 10 days have passed since symptoms first appeared, AND
• two consecutive negative tests collected ≥24 hours apart. (Assuming you have access to testing.)

Listen to your gut here. If it’s telling you not to allow employees back into the salon until they have two consecutive negative tests, you’d be wise to follow that instinct. Also keep in mind that immunocompromised employees may remain contagious for longer than those who are not.

If you want to stay open, stay cautious.

Here are the CDC’s Discontinuation of Isolations for Persons with COVID-19 Not in Healthcare Settings. Read them.

At a bare minimum, I would recommend requiring medical clearance confirmation directly from a physician or health clinic. This may come in the form of an official email or document—not merely an employee’s insistence that they’ve been cleared to return to work. For as long as people are capable of masking their symptoms, it falls to employers to conduct due diligence.

I recognize what an incredibly stressful time this is for all of us who interact closely with the public and am grateful for all of the diligent work professionals and salon owners are doing to keep their communities safe during the pandemic. If nobody has told you recently—your efforts are appreciated.