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Employee Face Mask Policies: Guidelines from the CDC and OSHA

October 7, 2020

Wearing a face mask has already become part of the daily routine for many Americans, with 97% saying they wear one at least once in a typical week. As more businesses continue to reopen or bring their employees back to the office over the next several months, face masks will likely remain an important preventative measure — especially since both the Centers for Disease Control and Prevention (CDC) and the Occupational Safety and Health Administration (OSHA) recommend that employers encourage workers to wear them in the workplace to help reduce the spread of COVID-19.

But given the patchwork of rapidly evolving mandatory and voluntary face mask orders that vary among states, counties and even cities, coming up with a compliant face mask policy that keeps your employees safe can be challenging. Does your entire staff need to wear face masks? Who should provide them? And what are best practices for wearing them in the workplace?

Below are guidelines from the CDC and OSHA on employee face mask policies, including:

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Is a workplace face mask policy right for your business?

According to the CDC, there is evidence that people who don’t know they have COVID-19 can spread the virus as they move about in public. Masks can act as a barrier to help reduce the spray of respiratory droplets from traveling into the air and onto other people when someone coughs, sneezes or talks.

But face coverings may not be appropriate for every employee. Here are a few tips to help determine if they’re right (or required) for your business.

1. Check state and local rules

First, find out what the face covering requirements are in your area. In some places and jobs, face masks are mandatory and many states are requiring employers to provide masks to their workers.

At the federal level, the government currently considers face coverings in the workplace to be voluntary. However, many states, like California, have mandatory statewide mask mandates, while other states, like Arizona, leave it up to local governments to implement face mask requirements of their own. To make matters even more confusing, some states and cities require people to wear face masks only if they work in public-facing jobs (e.g., restaurant server, barber, retail worker).

Employers that don’t enforce face mask requirements for their employees can even be cited or risk losing their business license, depending on state, county or city orders. That’s why it’s important to stay up-to-date on the local requirements and recommendations before creating a face mask policy for your employees — especially if you have multiple locations across cities or states.

2. Assess workplace hazards and conditions

Another factor to consider when deciding if your employees should wear masks in the workplace is the level of risk, especially if your business is located in an area that recommends but doesn’t require face masks. OSHA has divided job tasks into the following risk levels:

High risk employees regularly come into contact with people who may have been exposed to COVID-19 (e.g., healthcare workers, medical first responders). Personal protective equipment (PPE) is often mandatory for this category of workers, according to OSHA.

Medium risk employees are those who regularly come within six feet of other people, such as retail workers, restaurant servers and hair stylists. Since the CDC recommends that everyone over the age of two wear a mask in public and around other people who don’t live in the same household (especially when social distancing isn’t possible), masks are highly recommended for people working in these types of positions. A recent survey also found that just over two-thirds of shoppers are more comfortable when employees wear masks.

Low risk employees are those who don’t routinely come into close contact with coworkers or members of the public — including those who work alone in private offices, outdoor workers who can maintain six feet from others and delivery drivers with no face-to-face interaction. However, the CDC recommends that these employees still have masks readily available so they can put them on when entering and exiting buildings, moving around common areas and interacting with others. For example, employees in San Francisco aren’t required to wear a mask when they’re alone in their own private office with the door closed, but need to be able to put on a face mask when someone enters.

3. Determine what types of masks your employees may need

OSHA draws a distinction between cloth face coverings, surgical masks and respirators:

Cloth face coverings: Usually made using bandanas, t-shirts or another common fabric, cloth face masks are recommended for employees in medium and low risk work environments (e.g., retail stores, restaurants, office buildings). Cloth face coverings should have two or more layers of breathable, washable fabric, fully cover the nose and mouth, and fit snugly against the side of the face without any gaps. Since they are meant to protect others, not the wearer, and are often DIY, OSHA does not classify cloth face coverings as PPE.

Surgical masks: Typically more protective than cloth face coverings, surgical masks are single-use PPE that protect healthcare workers against large-particle droplets, splashes and sprays that may contain viruses and bacteria. However, like cloth face coverings, surgical masks will not protect the wearer against particles already in the air due to their loose fit and lack of adequate seal and filtration, says OSHA. The CDC recommends saving medical-grade surgical masks for healthcare settings where they’re needed the most.

Respirators (including N95s): Like surgical masks, respirators are recommended to be reserved for healthcare providers, medical first responders and other frontline essential workers. Professional respirators offer a higher level of protection than cloth face coverings and surgical masks because they contain filtering material and a tight-fitting seal that prevents the wearer from breathing in small particles in the air.

What to consider including in your employee face mask policy

A clear, detailed policy can help your employees understand the value and limits of wearing cloth face coverings in the workplace. Here are some suggestions for what to include in your employee face mask policy in accordance with guidelines from the CDC and OSHA and state and local requirements.

As always, be sure to check with your legal team when developing new workplace policies.

Why face masks are important

Start by explaining why face masks are necessary for your business. For example, you might explain that face coverings are mandatory in your city. If there are no government face mask requirements in your area, outline the reasons why you’re requiring employees to wear one.

Remind employees that, according to the CDC, cloth face coverings may not protect the wearer from being exposed to COVID-19, but can help minimize the spread of the virus among employees, customers and the public. It’s also worth noting that cloth face masks are not a substitute for social distancing or regular handwashing.

Which employees are required to wear masks and when

Include details about which employees are required to wear masks and when they’re allowed to take them off. Is it okay for employees to remove their mask once they’re in their personal cubicle or office? Can employees who make phone calls during the day take off their masks while talking? Check with state and local rules to guide this section of your policy.

For example, Connecticut office workers are required to wear a mask from the time they enter the building until the time they arrive at their cubicle, desk or workstation, where they can temporarily remove it. They must put it back on any time they’re moving around common areas (e.g., hallways, stairwells, bathroom, break room), regardless of whether others are present.

In California, face coverings are required for employees who interact with others, work in a space other people might use later, even if they’re alone (e.g., cubicles, shared desks, conference rooms), work in an area with shared equipment or handle, prepare or package food or any other items for customers.

Face mask policy exemptions

Some of your employees may be unable to safely wear a face covering due to a medical condition or disability. In your face mask policy, consider outlining the process for requesting a reasonable accommodation under the Americans with Disabilities Act (ADA). Read more about COVID-19 and the ADA here.

Additionally, many state and local mask orders have specific exemptions. For example, people may not be required to wear a mask under state and local rules if they have a health condition that prevents them from wearing one. Certain job tasks or workplace conditions may mean that wearing a mask causes new safety concerns (e.g., straps getting caught in machinery, risk of heat-related illness) that exceed the benefit of slowing the spread of the virus.

If an employee is unable to safely wear a cloth face mask at work, OSHA suggests employees wear a face shield or other type of PPE (e.g., surgical mask). Other ideas might include allowing the employee to wear a scarf or looser face covering, temporarily assigning them to a role where they don’t interact with others or allowing them to work remotely, if possible.

How to properly wear face coverings

In your policy, be sure to give clear instructions on how to properly wear a mask. According to the CDC, a face covering should cover the nose and mouth and fit snugly against the side of the face to prevent the transmission of viral particles. Masks shouldn’t be worn around an employee’s neck, on their forehead, under their nose, only on their nose, on their chin, dangling from one ear or on their arm.

Additionally, consider including guidance from the CDC on the proper way to put on and take off face coverings. The CDC recommends that employees wash their hands with soap and water for at least 20 seconds (or use hand sanitizer with at least 60% alcohol) before and after putting on or taking off face masks. Employees should avoid touching the inside or outside of the face covering, handling it only by the ear loops, ties or band.

The CDC also suggests that when employees remove their mask at work, they should store them in a container or paper bag labeled with their name.

Mask care and maintenance

Reusable masks should be washed after each use, either in a washing machine or by soaking in a bleach solution for five minutes. They should also be dried on a high setting or in direct sunlight to kill bacteria and viruses.

It’s generally up to you if you’d like to create an in-house laundering program or reimburse employees for cleaning expenses. Check with local uniform maintenance rules to help guide your decision.

Who will provide and pay for face masks

Decide if your business will pay for face masks or if employees will need to purchase or provide their own. According to OSHA, cloth face masks are not considered PPE, which means OSHA’s PPE standards do not require employers to provide them.

However, some state, county or city orders may specifically require employers to provide and pay for masks. For example, employers in New York must purchase face coverings for workers who have direct contact with customers or members of the public. In Washington, employers must provide employees with masks. Other jurisdictions may not specify who should pay for them. In this case, check existing state laws regarding expense reimbursement.

Here is an excerpt from Ball State University’s employee face mask policy:

“Individuals may supply their own face mask for general use. In addition, the University will provide up to two washable and reusable face masks to every faculty, staff, and on-campus student who requests them. To obtain a face mask from BSU, employees should contact their direct supervisor.”

Even if it’s not required in your area, providing all of your employees with face masks is a good idea. Face coverings protect other people, not the wearer, which means slowing the spread of COVID-19 depends on everyone in your workplace wearing one. Additionally, if you decide to provide your employees with masks, you can even brand them with your company logo and make sure they fit in with your company’s dress code.

Consequences of not wearing a face mask

Determine any disciplinary action you may take if an employee who has not sought an exemption refuses to comply with your face mask policy. You may follow the same disciplinary action process you normally follow for violations of HR policies (e.g., official warning, disciplinary meeting, termination).

FAQs about face masks in the workplace

Can employers require employees to wear cloth face masks at work?

According to the Equal Employment Opportunity Commission (EEOC), employers can typically require employees to wear masks or other protective gear (e.g., gloves, gowns) during a pandemic. However, employees with disabilities or religious beliefs may be able to request a reasonable accommodation under the ADA or Title VII of the Civil Rights Act.

Where can I obtain cloth face coverings for my employees?

At the start of the COVID-19 outbreak, masks were harder to come by, with many people having to make their own out of t-shirts and other common fabrics around the house. Now, cloth face coverings are more accessible and can even be branded with your company’s logo. You can typically buy in bulk, possibly for as low as $1-$2 per mask, depending on the store. There may even be a free or discounted mask program specifically for small businesses in your area.

When choosing what kind of face masks to purchase, take into account how comfortable they’ll be for employees who may need to wear them for entire shifts. Masks made with 100% cotton may be more breathable and comfortable than masks made with other materials like polyester. Adjustable ear loops and bendable wire nose strips can also improve comfort and fit.

How many face masks should I provide for my employees?

If you’re in a state that requires you to provide and pay for your employees’ masks, check with state and local rules. For example, while there may be no set requirement for the number of masks you need to give your employees, businesses in Washington must immediately replace an employee’s mask if they request a new one, or if it becomes contaminated, wet, dirty or damaged.

If you’re not required to provide masks by state or local law, and would like to, consider providing a mask for each day of the week. That way, your employees can always arrive wearing a fresh one because they have time to wash them at home.

While you follow these guidelines from the CDC and OSHA to create a face mask policy that keeps your employees safe and healthy, you can also make your workplace more comfortable for customers and visitors.

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