Part 3 of a series featuring our video Rules of the Road: Return to Work in the Time of COVID-19.

Whether physically in the office or not, regularly washing your hands should already be a routine practice. However, this innate rule is especially important, and recommended by the Center for Disease Control (“CDC”), to help prevent the spread of COVID-19 and to maintain safe, healthy and respectful workplaces.

Wash Your Hands…All the Time

Everyone should already be washing his or her hands – all the time. This is a cardinal hygiene rule that everyone learns in elementary school. Although this advice is not novel, it is critically important to encourage employees to make a concerted effort to thoroughly wash their hands. Specifically, the CDC recommends that all individuals should wash their hands with soap and water for at least 20 seconds (during which you can recite the ABCs, or hum the chorus of “No Scrubs” by TLC – but make sure to still scrub for 20 seconds) after sneezing, coughing, before and after work shifts, and after putting on, touching, or removing cloth face coverings.

In addition, the CDC also recommends using alcohol-based hand sanitizer that contains 60% alcohol, if soap and water are not available. In certain states, hand washing is not only recommended, it is required, as employees return to work. For example, New York City requires that employees wash their hands when interacting with delivery workers. Thus, to maintain a healthy work environment, employees should always wash their hands and employers should ensure that they provide employees and individuals entering the workplace with plenty of soap and hand sanitizer.

Employer Obligations Regarding Hand Hygiene

Handwashing is not only recommended by the CDC, but is also a requirement in order to reopen the workplace in certain states. Some examples of state and local hand hygiene requirements include:

  • In New York, Office-Based Work Guidelines require employers to provide and maintain hand hygiene stations in the office. Specifically, the guidance states that such stations must include: soap, running warm water, disposable paper towels, and a lined garbage can, and an alcohol based hand sanitizer containing 60% or more alcohol for areas where handwashing is not feasible.
  • In Los Angeles, employers must provide hand sanitizer that is effective against COVID-19 and soap and water to all employees. Los Angeles employers must also allow frequent breaks for employees to wash their hands. Further, with respect to members of the public who would have direct interactions with the workplace, employers are required to provide hand sanitizer, soap and water, tissues and trash cans at or near the entrance of the workplace, at reception, and anywhere else inside the workplace or immediately outside where people have direct interactions.

Hand Hygiene-Related ADA Considerations

Employers should also be mindful of the mental health effects of COVID-19, especially on individuals who may have pre-existing mental health conditions, such as obsessive compulsive disorder (“OCD”) or anxiety disorder. As many employees have fears surrounding COVID-19 and may be extra careful with hand-washing, individuals with OCD or other mental health issues may experience excessive fears about the virus, creating the need for increased or prolonged hand washing. In order to accommodate employees’ needs to feel comfortable and safe, employers should be mindful of the requirements under the Americans with Disabilities Act (“ADA”). Under Title I of the ADA, employers are prohibited from discriminating against individuals with disabilities and must provide a “reasonable accommodation.” Thus, employers may provide individuals with workplace flexibilities, such as increased breaks for hand washing or supplying additional sanitizers around the office, to accommodate the need for increased hand hygiene, as long as the accommodation does not result in disparate treatment. Ultimately, employers should ensure that they assess any accommodation request on an individual and case-by-case basis by engaging in an interactive process. An employer may ask employees questions to determine whether the condition is a disability and request documentation, but must maintain confidentiality and keep all medical documentation separate and apart from an employee’s personnel file. Employers may also discuss with the employee how the requested accommodation would enable the employee to keep working or explore alternative accommodations that would effectively meet the employee’s needs.

Overall, it is important to be understanding of all individuals who may be experiencing anxiety during this uncertain time. Reminding all employees to reach out if they need additional mental health support, creating proper hand hygiene stations, and providing all employees with office workplace plans can quell return to work fears. So, pick your favorite pop song and make sure to wash your hands, frequently and thoroughly – it is just one simple step that can have a huge impact.

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