By Brent I. ClarkJames L. CurtisAdam R. YoungPatrick D. Joyce, and Craig B. Simonsen

Seyfarth Synopsis: The CDC recently updated its Guidance on Domestic Travel During the COVID-19 Pandemic. The guidance also provides domestic travel recommendations for unvaccinated people.

Image from CDC.

The CDC recently issued updated guidance regarding travel. It is important to recognize that the CDC’s guidance on COVID-19 is not a law or regulation. However, various agencies and public health authorities have adopted some or all of the CDC recommendations, including recommendations regarding travel. Consequently, employers should consult actual laws and regulations regarding travel for their specific jurisdictions to understand requirements versus recommendations and guidance, especially employers who are considering their own travel policies.

As COVID-19 vaccinations in the United States continue, the CDC and other authorities will likely adjust their requirements and guidance to address the vaccinated population. Employers should be sure to closely track developments and make adjustments to their own policies as the risks associated with COVID-19 and travel change over time.

Domestic Travel Recommendations for Vaccinated People

According the CDC’s updated guidance, people who are fully vaccinated with an FDA-authorized vaccine can travel safely within the United States. People are considered fully vaccinated:

  • 2 weeks after their second dose in a 2-dose series, such as the Pfizer or Moderna vaccines, or
  • 2 weeks after a single-dose vaccine, such as Johnson & Johnson’s Janssen vaccine

Individuals who have not completed the 2-week period are not fully vaccinated, so the CDC recommends continuing to take all precautions until they are fully vaccinated. The CDC also cautions that immuno-compromised individuals may need to limit travel, even if vaccinated.

During Travel

The CDC recommends that fully vaccinated travelers still wear a mask over their nose and mouth while traveling. Masks are required by federal law on airplanes, buses, trains, and other forms of public transportation traveling into, within, or out of the United States and in U.S. transportation hubs such as airports and stations.

Fully vaccinated individuals should also avoid crowds and physically distance, staying at least 6 feet from anyone who is not traveling with them, and should continue good hygiene practices, washing hands often or using hand sanitizer (with at least 60% alcohol) according to the most recent guidance.

After Travel

The CDC advises that vaccinated travelers should self-monitor for COVID-19 symptom, and to self-isolate and get tested if they develop symptoms. They must also abide by state and local requirements, even if it differs from the CDC’s guidance.

The CDC does not advise that vaccinated individuals (and those who had COVID-19 in the past 3 months) self-quarantine after travel.

Domestic Travel Recommendations for Unvaccinated People

If individuals are not fully vaccinated and must travel, the CDC recommends:

1. Before Travel

Get tested utilizing an FDA approved viral test 1-3 days before their trip.

2. During Travel

Wear a mask over their nose and mouth. Masks are required by federal law on planes, buses, trains, and other forms of public transportation traveling into, within, or out of the United States and in U.S. transportation hubs such as airports and stations.

Avoid crowds and stay at least 6 feet from anyone who is not traveling with them.

Wash hands often or use hand sanitizer (with at least 60% alcohol).

3. After Travel

Get tested utilizing an FDA approved viral test no sooner than 3-5 days after travel AND stay home and self-quarantine for a full 7 days after travel.

  • Even if the individual tests negative, they should stay home and self-quarantine for the full 7 days.
  • If the test is positive, the individual must self-isolate to protect others from getting infected.
  • If the individual decides not to get tested, they should stay home and self-quarantine for 10 days after travel.

Regardless of whether the traveler seeks a test after travel or not, they should avoid being around people who are at increased risk for severe illness for 14 days, self-monitor for COVID-19 symptoms (isolate and get tested if symptoms develop), and follow all state and local recommendations or requirements. Some state and local requirements do not allow travelers to test-out of self-quarantine.

Visit your state, territorial, tribal or local health department’s website to look for the latest information on where to get tested.

For more information on this or any related topic, please contact the authors, your Seyfarth attorney, or any member of the Workplace Safety and Health (OSHA/MSHA) Team.