Face Coverings in the Workplace: 5 Lessons You Need to Know

As more businesses reopen and workers – many wearing face masks – return to in-person interactions with co-workers, customers and clients, here are five things that every worker should know about face masks in the workplace.

  1. What are the different types of face coverings and masks?

Generally, there are three categories of face coverings and masks: cloth face coverings, surgical masks, and respirators/filtering masks.

Cloth face coverings have become commonplace during the national health emergency created by COVID-19. They may be commercially produced, homemade, or improvised (scarves, bandanas and other items.) A cloth face covering covers the wearer’s nose and mouth to form a barrier that reduces the spread of germs from the wearer to others by containing the wearer’s potentially infectious respiratory droplets. A cloth face covering is not, and may not substitute for, Personal Protective Equipment, as a cloth face covering does not protect the wearer because of its loose fit, inadequate seal and insufficient filtration.

Surgical masks are medical grade devices which generally are approved by the Food and Drug Administration. Do not be fooled, many commercially available face coverings resemble surgical masks in appearance but are not medical grade and do not offer medical grade protection. Surgical masks serve dual purposes – they protect the wearer from splashes, sprays and droplets of potentially infectious materials and they protect non-wearers by containing the wearer’s respiratory droplets.

Respirators/filtering masks are used to protect the wearer from small particles, including airborne and aerosolized infectious agents. These masks are not for everyone. They need proper filtering material (N-95 or better.) They must be certified by the National Institute for Occupational Safety and Health. They require special training, fit testing, oversight, and cleaning.

  1. Can employers require workers to wear cloth face coverings in the workplace?

Generally, employers may require cloth face coverings to enhance the safety of their workplaces. The General Duty Clause of the Occupational Safety and Health Act requires employers to provide workers with a place of employment “free from recognized hazards that are causing or likely to cause death or serious physical harm.” OSHA recognizes COVID-19 as a potential workplace hazard and expressly recommends that employers encourage workers to wear face coverings at work.

Cloth face coverings, however, are not suitable for all workers and all job tasks. Decisions on face coverings should be the result of employers’ individualized infectious disease preparedness and response plans. The plans should assess not just the advantage of face coverings, e.g. reducing the spread of germs, but the disadvantages and risks as well. For example, cloth face coverings will impair the ability of workers who lip-read to communicate so employers should determine whether cloth face coverings are appropriate under their accessible communications policies. Cloth coverings may absorb chemicals causing masked-workers who use cleaning and other products to inhale repeatedly any chemicals trapped in their masks. Where work is performed in high temperature or high humidity environments, cloth face coverings may exacerbate heat illness.

Even though OSHA recommends encouraging the use of cloth face coverings in the workplace and the Center for Disease Control recommends the use of cloth face coverings in public places, each employer should tailor its face covering policy to the individual needs of its workplace, work force and job tasks.

  1. Is an employer required to supply cloth face coverings to workers?

No. Cloth face coverings are not considered Personal Protective Equipment by OSHA. Specific to COVID-19, cloth face coverings are not intended to protect the wearer. They are intended to prevent a wearer who may have COVID-19 without knowing it (whether asymptomatic, pre-symptomatic or with misdiagnosed symptoms) from spreading the virus to others. When you see someone wearing a cloth face mask, that person is protecting you. When you wear a cloth face mask, you are protecting others.

In contrast, where surgical masks or filtered masks are required by OSHA as PPE to protect workers from particles in the work environment, employers are responsible for providing and maintaining the masks. For more information on masks as PPE please see 29 CFR 1910.132 and 29 CFR 1910.134.

  1. Do cloth face masks eliminate the need for social distancing?

No. OSHA expressly rejects the use of cloth face masks in lieu of compliance with social distancing guidance. Cloth face coverings generally are inadequate to prevent workers from inhalation hazards because of their loose fit, lack of seal and insufficient filtration. Social distancing plus appropriate face coverings should be included in every employer’s control plan unless they create a greater hazard for workers.

  1. Do not let cloth face masks lull you into a false sense of security.

Face coverings provide important, but limited, protection. Therefore, just as every employer should have a preparedness plan, every worker should have an individualized preparedness plan. Consider keeping a spare face covering, such as a mask, scarf or bandana, available in case one breaks or gets spoiled. If you wear a cloth face covering, bring it home and wash it regularly. Maintain social distancing, especially in places where ventilation is poor or you encounter others who are not wearing face coverings. Wash your hands at every opportunity. Disinfect surfaces in your work area and common areas with alcohol-based wipes (at least 60% alcohol) or other similar cleaners. Where possible, refrain from sharing headsets, food utensils, tools and office supplies; where this is not possible, clean the shared equipment thoroughly with alcohol-based cleaners before and after each use. Consider using a wipe, glove or other covering for opening doors in public places, pushing elevator buttons or doorbells, and holding handrails. If you become symptomatic during the day, tell your employer so someone can clean your work area and then go home and to the extent possible isolate yourself to protect others.

More information on face coverings in the workplace is available at www.osha.gov. More information on face coverings, including how to make your own face coverings, is available at www.cdc.gov.

This summary is not intended to contain legal advice or to be an exhaustive review. If you have any questions regarding this article, please contact David L. Kelleher at Jackson & Campbell, P.C.