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Davis Brown Employment and Labor Law Blog

HR Quick Take: Disease Risk with Multiple Employers - March 20, 2020

Q: I have several employees who work for more than one employer. Should I be worried about their potential COVID-19 exposure in some other workplace?

A: Yes - inquire about the side hustle. OSHA’s general duty clause requires that you assess issues of safety in a global manner so if employees go from your low risk workplace (lots of space, no forward facing public contact) to a more high contact job (healthcare and retail may be two examples) you will need to speak with them regarding their risk factors. For long-term care workers, where it is very common for staff to work at multiple facilities, the CDC has stated that those who work in “multiple locations may pose higher risk and should be asked about exposure to facilities with recognized COVID-19 cases.” How that will be handled once you have the information is a case-by-case assessment.

HR Quick Takes features client questions and answers from Iowa employment attorneys. If you have a question you’d like answered, email

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