Monday, May 25, 2020

Opinion: New Mexico's Contact Tracing Logs are an Overreaction

On May 15, New Mexico Secretary of Health Kathyleen Kunkel published the latest Public Health Order for New Mexico. In it, she ordered that:
"Any business opening pursuant to this provision must comply with the pertinent CSP's [sic] set out in the "All Together New Mexico: COVID-Safe Practices for Individuals and Employers" [link added].

In the "All Together New Mexico" document, it is a "best practice" for all employers "to support contact tracing, retain a daily log for at least four weeks including the date, name, phone number of all customers and employees who enter the workplace" 

Further it is "required" for restaurants to "To support contact tracing, retain a daily log for at least four weeks including the date, name, and phone number or email address of all customers and employees who enter the establishment".

Lastly, it is "required" for automobile dealers & services [sic] to "Retain a daily log for at least four weeks including the date, name, phone number and email address of all customers and employees."

Casting aside the three different versions of the mandate, it is notable that this is not a requirement, but rather a "best practice" under the "all employers" section for any of the other categories of businesses delineated in the document:
  • Retail
  • Office & Call Centers
  • Grocery Stores & Farmers' Markets
  • Youth Programs
  • Manufacturing, Warehouse & Food Production
  • Hotels, Resorts & Lodging
  • Golf Course
  • Tour Operators
  • Houses of Worship
  • Farms, Ranches & Dairy Producers and Processors
  • Veterinarians & Animal Care Facilities
  • Construction & Field Operations
  • Medical Providers & Other Industries

What's so special about restaurants, car dealers, and mechanics?

Restaurants have been operating in New Mexico for takeout and delivery since the coronavirus shutdowns began. Why do they now suddenly have to keep track of who comes into the building? It's not because of dine-in customers, because the requirement is for "All customers [emphasis added]," not just dine-in customers.

Further, is it reasonable to believe that car mechanics are somehow more conducive to viral spread than a store? It sure seems like people spend more time going around and touching things in a clothing or electronic store for example than they would at a mechanic. Additionally, like restaurants, car mechanics [including the service side of dealerships] never shutdown. Why, like restaurants, are they suddenly required to keep a log?

Who's responsible for an error in the log?

Let's say a patron comes in and says their name is "Micky Mouse," and their email is "micky@disney.com." Surely the employee in charge of the contact tracing log knows that's not true, but what can they do about it? Are they required under the State's CSPs to challenge the customer and get them to provide real information?

If a patron comes in and provides believable yet false information like "John Wilson [sounds real enough to me]," and "505-827-2613" [Kathyleen Kunkel's office phone], is the employee expected to validate the information in some way? What happens if the State determines that an individual with COVID-19 did in fact come into the establishment, and finds out that this false information was provided by a customer? Would the business be liable for having collected false information?

Has contact tracing gone too far?

Is it really believable that a customer with COVID-19 who comes into a restaurant in the morning for takeout can infect someone who comes in that evening (remember, the logs are required to keep track of the date, not the time, that someone enters a business)? It seems far-fetched, especially with the regular cleaning that businesses are required to do under the CSPs.

Contact tracing is supposed to find everyone who could potentially have been infected by someone who is later determined to have had a communicable disease [in this case COVID-19]. But when contact tracing becomes too broad, suddenly a huge chunk of the population is determined to have been in contact with an individual. And then all of those people can be tied to even more people. Just like the Six Degrees of Kevin Bacon, a single person can indirectly have contact with thousands of people.

Yet the vast majority of those thousands of people won't contract COVID-19. Further, since they will be told by a State contact tracer that they have been in contact with a COVID-19 positive person, they may decide to self-isolate for 14 days, or be denied the ability to go to work or enter parks due to their inability to "pass" a health screening that asks about contact. Is it really necessary to scare someone by saying they might have COVID-19, and then have them sit-it-out for two weeks because of extremely indirect contact?

There's a fine-line in contact tracing, and New Mexico's contact tracing logs cross that line.

That's Just My Thought.

Here's our sources, so you can decide for yourself:

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