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GC Agenda: Customer-Facing Employee Safety | Dec 2020 / Jan 2021

By Robin Samuel on December 15, 2020

Originally published in Thomson Reuters Practical Law 

Customer-Facing Employee Safety

In light of the COVID-19 pandemic and approaching holiday season, employers with customer-facing employees, such as retail clerks and restaurant workers, should take steps to protect those employees from potentially hostile encounters with customers who challenge employers’ COVID-19 mask-wearing policies or other safety protocols.

To protect customer-facing employees, employers should:

  • Develop or revise policies on workplace violence, safety, and health to address COVID-19 issues.
  • Train employees regularly on employer safety policies, government-mandated COVID-19 masking requirements, and appropriate de-escalation techniques.
  • Post conspicuously all COVID-19-related policies, both physically in the business location and on employer websites.

When revising policies to address COVID-19, employers must be mindful of the Occupational Safety and Health Act’s General Duty Clause requiring employers to provide a workplace free from recognized harmful hazards, while balancing the employer’s obligation to reasonably accommodate customers with underlying health conditions. Employers should consider:

  • Determining which employees are responsible for dealing with customers who refuse to wear masks (for example, security personnel, supervisors, or front-line workers).
  • Ensuring that employees are trained on the employer’s relevant policies, state and local COVID-19 requirements, and workplace violence protocols.
  • Drafting and posting a policy addressing customer requests for medical accommodations related to mask wearing.
  • Offering alternatives to accessing the business, including curbside service or online shopping.

When developing employee training, employers should refer to guidance from:

  • The Centers for Disease Control and Prevention.
  • The Occupational Safety and Health Administration (OSHA) and state OSHA agencies.
  • State health authorities.
  • Industry-specific associations.
  • Posted in:
    Employment & Labor
  • Blog:
    The Employer Report
  • Organization:
    Baker McKenzie
  • Article: View Original Source

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