Pennsylvania Secretary of Health Issues Order Mandating that Building Owners Clean High-Touch Areas in Accordance with CDC Guidance

NOTE: Because the COVID-19 situation is dynamic, with new governmental measures each day, employers should consult with counsel for the latest developments and updated guidance on this topic.

In its latest response to the COVID-19 pandemic, Pennsylvania has ordered mandatory cleaning protocols for large buildings throughout the Commonwealth.  On Sunday, April 5, 2020, Secretary of Health Dr. Rachel Levine issued an Order to take effect immediately at 12:01 a.m. Monday, April 6, 2020.  The Order was issued days after Governor Wolf recommended Pennsylvanians wear face masks or coverings when in public.


The Order applies to owners of buildings (1) of at least 50,000 square feet; (2) where a business is authorized to maintain in-person operations pursuant to the Orders issued by the governor and secretary of health on March 19, 2020, as subsequently amended, including businesses operating pursuant to an exemption from those orders; and (3) which are used for commercial, industrial or other enterprises, including but not limited to facilities used for “warehousing, manufacturing, commercial offices, airports, grocery stores, universities, colleges, government, hotels, and residential buildings with at least 50 units.”

Cleaning Protocols

Owners of covered facilities shall implement the following cleaning protocols in those areas where operations are conducted:

  1. Clean and disinfect high-touch areas routinely in accordance with CDC guidelines, in spaces that are accessible to customers, tenants, or other individuals. The CDC recommends a cleaning agent contact time of at least one minute.  The CDC provides separate guidance for cleaning and disinfecting in instances in which a person suspected or confirmed to have COVID-19 has been to the facility. 
  2. Maintain existing pre-existing cleaning protocols established in the facility for all other areas of the building.
  3. Ensure that the facility has a sufficient number of employees to perform the above protocols effectively and in a manner that ensures the safety of occupants and employees.
  4. Ensure that the facility has a sufficient number of security employees to control access, maintain order, and force social distancing of at least six feet, provided that the security employees are otherwise responsible for such enforcement. 

Rapid-fire orders from state officials have become the norm. Employers can monitor these orders on the governor’s website.

Information contained in this publication is intended for informational purposes only and does not constitute legal advice or opinion, nor is it a substitute for the professional judgment of an attorney.