The 10 things every mandatory mask policy should include.
What began as a public health guideline is evolving into a legal duty with municipalities across the country adopting bylaws requiring individuals to wear masks or face coverings in enclosed indoor public spaces, including workplaces. As a result, employers must adopt and enforce mandatory mask policies at their facilities. While mask requirements vary slightly by jurisdiction, here are the 10 basic elements they should include.
Start by stating that all entrants must wear a proper mask or face covering and that failure to comply will be grounds for denial of entrance or immediate removal and, if the violator is an employee, discipline up to and including termination (Policy, Sec. 1).
Statement of Purpose
Indicate that the purpose of this policy is to prevent COVID-19 infection and ensure compliance with regulatory requirements and public health guidelines (Policy, Sec. 2).
Definition of “Mask”
There needs to be a specific definition of what constitutes a mask, namely, a non-medical face mask, bandana or other covering that:
- Goes over the nose and mouth;
- Ties around the ears or back of the head;
- Fits snugly against the sides of the face and;
- Is secured under the chin.
Just as importantly, you want to clarify what a mask does not include, namely, the N95 type filtered medical mask required by healthcare workers nor a face shield that protects only the wearer (Policy, Sec. 3).
Whom the Policy Covers
Explain that the mandatory mask policy covers not just employees but all building entrants, including contract workers, vendors, clients, customers, visitors and guests, unless an exemption applies (Policy, Sec. 4).
Where the Policy Applies & Doesn’t Apply
Clarify that the policy covers not just all indoor spaces but also outdoor work areas where proper social distancing can’t be maintained, as well as in company vehicles. Also list exceptions where people don’t have to wear a mask, which may differ by jurisdiction but typically includes:
- Work or time spent alone in a personal office or workspace;
- Walking, exercising or other outdoor activity where individuals are at least 2 meters/6 feet apart;
- Driving a single-occupancy vehicle;
- Telework; or
- Other operations, conditions or situations where people are alone in a personal room or space or assembled but still maintain the required social distancing boundaries (Policy, Sec. 4).
Masks Don’t Replace Required PPE
Clarify that wearing a mask in no way relieves employees of their duty to use the job-specific PPE required by your company’s safe work procedures and OHS policies (Policy, Sec. 5).
Establish legitimate exemptions where wearing a mask could actually endanger the user, such as when:
- A medical professional has advised that wearing a mask may pose a health risk or impair the user’s breathing;
- Wearing a mask would create a health or safety risk to the wearer under federal, provincial or local regulations or OHS guidelines;
- The user can’t put on or take off the mask without assistance;
- The user is deaf or hard of hearing and relies on facial and mouth movements to communicate; or
- The user is a baby or toddler under 2-years-old (Policy, Sec. 5).
In addition to health and safety exemptions, human rights laws require you to make reasonable accommodations for disabilities, religious beliefs and other protected characteristics to the point of undue hardship (Policy, Sec. 6).
List the roles and responsibilities of different stakeholders under the Policy, starting with company management as employer. Under the OHS laws of most jurisdictions, employers must supply required PPE at their own expense, except for personal items like safety boots. While it’s unclear which side of the line COVID-19 masks fall, best practice seems to dictate that employers furnish the masks but allow employees to pay for and use their own masks instead. Other employer responsibilities include ensuring signs are posted, proper disposal or cleaning is arranged and training is provided (Policy, Sec. 7.1).
Other Roles & Responsibilities
Other roles and responsibilities to address:
- Department heads should assess and identify mask supply needs, ensure signs are posted and rules are followed in their work area (Policy, Sec. 7.1);
- In addition to carrying out the responsibilities exercised by department heads at smaller organizations without departments, supervisor should also deliver the necessary mask training and instruction and enforce the mask rules (Policy, Sec. 7.3); and
- Employees should be responsible for properly using and either disposing of or laundering/storing their masks, depending on what kind of masks you use (Policy, Sec. 7.4).