Do you have employees who have expressed that it's "unsafe" to wear a face covering throughout the workday? If yes, you're not alone.
 
There are some adults who cannot safely wear a face covering. Specifically, CDC guidance states that a person "who has trouble breathing" should not wear a face mask, along with anyone who is "unconscious," "incapacitated or otherwise unable to remove the cloth face covering without assistance." 
 
If an employee requests an exemption from your face covering policy, provide them the ADA Recommendations Form for the physician to complete, which will confirm: (1) the employee is a qualified individual with a disability, and (2) an exemption from the face covering policy is an accommodation that would allow the employee to perform the essential functions of the job. Upon receipt of the physician's recommendations, the employer will need to decide if the accommodation request is reasonable under the circumstances.  If not, the employer will need to analyze whether there is a reasonable alternative to the face covering, such as a face shield, isolated office location, or telework.
 
For everyone else, it is appropriate to require face coverings and direct your employees to OSHA and CDC Guidelines, including OSHA's most recent Q&A:  
 
 
COVID-19 Q&A
 
 
Does wearing a medical/surgical mask or cloth face covering cause unsafe oxygen levels or harmful carbon dioxide levels to the wearer?
 
No. Medical masks, including surgical masks, are routinely worn by healthcare workers throughout the day as part of their personal protective equipment ensembles and do not compromise their oxygen levels or cause carbon dioxide buildup. They are designed to be breathed through and can protect against respiratory droplets, which are typically much larger than tiny carbon dioxide particles. Consequently, most carbon dioxide particles will either go through the mask or escape along the mask's loose-fitting perimeter. Some carbon dioxide might collect between the mask and the wearer's face, but not at unsafe levels.
Like medical masks, cloth face coverings are loose-fitting with no seal and are designed to be breathed through. Workers may easily remove their medical masks or cloth face coverings periodically (and when not in close proximity with others) to eliminate any negligible buildup of carbon dioxide that might occur. Cloth face coverings and medical masks can help prevent the spread of potentially infectious respiratory droplets from the wearer to their co-workers, including when the wearer has COVID-19 and does not know it.
 
Still have questions regarding how to deal with employees who fail or refuse to wear face coverings at work? Need an ADA Recommendations Form? Don't worry, we're here to help!
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