COVID-19 Safety Regulations: Supervisor Guide

To protect the health and safety of the UO community, the University of Oregon has implemented safety regulations with input from campus stakeholders, local, state and federal health officials and its medical experts. Unit-requested changes or exceptions to these rules will generally not be allowed unless associated with an industry specific requirement or need. Exception requests should be made to the IMT wellness group.

Supervisor Resources

Supervisors play a vital role in promoting, incentivizing, and managing compliance with safety regulations. It is important that you take the time to set expectations and review the regulation information with employees prior to their return to campus and on a regular basis thereafter. These regulations apply to all employees working on campus - whether their job assignment takes place on campus regularly or they travel to campus on a more periodic basis. When on campus and in a UO building, all employees are expected to comply with UO’s safety regulations. These expectations also apply to students and community members while they are on campus. Supervisor behavior sets the tone and reinforces expectations of others.

Several resources are available to assist you with educating and informing employees about COVID-19 safety regulations:

UO Coronavirus Website

Supervisors should regularly check the university's website to make sure they have up to date information regarding safety regulations.

View Coronavirus Website

COVID-19 Workplace Checklist

Utilize this checklist to guide conversations with employees as your unit returns to on campus, in-person work.

View Checklist

MyTrack Safety Training

Use the Environmental Health and Safety's online training in MyTrack to educate and inform employees.

View Training

Safety Regulations Overview

Supervisors must know UO’s safety regulations, understand them, and regularly communicate about them with employees.

  1. Face-Covering Regulation: view regulation
    UO requires faculty, staff, students, visitors, and vendors across all UO locations to use face coverings, which include masks (note: masks with exhaust valves are discouraged), cloth face coverings, or face shields, when in UO owned, leased, or controlled buildings, except when alone in a space (e.g., room with four walls). However, It is recommended that individuals wear face masks when alone in a space.
    Importantly, the State of Oregon has also implemented a law requiring face masks. Questions about how UO’s safety regulation applies in light of the state’s guidance should be direct to
  2. Symptom Self-Check Regulation: view regulation
    The mandatory symptom self-check requirement applies to all employees and students coming to campus. It requires a review of health status related to COVID-19 symptoms before coming to campus and prohibits employees from coming to campus for a certain period if they are experiencing symptoms. An employee may return to campus only after meeting certain conditions.

Promoting Employee Compliance

In their discussions and daily interactions, supervisors should promote and incentivize compliance with safety regulations through communication with employees, on-going education, and positive reinforcement. Promoting compliance and reinforcing positive behavior is the university’s primary and preferred mechanism for achieving compliance with UO’s safety regulations.

Educate and Inform

Using a variety of communications strategies helps explain the regulations and convey their importance. Utilize direct email, one-on-one meetings, team meetings, and unscheduled interactions during the work day to implement and normalize safety regulations.

During interactions with employees, supervisors are encouraged to:

  • Explain the regulation to achieve understanding, and
  • Share their importance as a necessary part of the university's COVID response in order to prevent the spread of the virus and protect the health and safety of the UO community.

Again, because these regulations are new and impactful on an employee’s everyday behavior, it is critical to repeatedly discuss the requirements and why they are important.

Acknowledge Desired Behavior

Supervisors should also incentivize compliance by rewarding positive behavior. For example, recognizing a person who is appropriately socially distancing and wearing a face mask during a team meeting, during a 1:1 meeting, via email, etc. As we continue to increase the number of employees on campus additional approaches to reward behavior are being developed. Regardless of the approach the key is consistent, regular communication to promote compliance.

Enforcing Face-Covering Regulation

Consistent with guidance from the Oregon Health Authority (OHA), the university has implemented this regulation to help limit the potential spread of COVID-19. Wearing face coverings is a critical safety mitigation measure, protecting individual employees and our campus community. Employees are expected to comply and supervisors are expected to address non-compliance.

Supervisor response to an employee’s failure to follow the regulation should follow the three step process outlined below.
Note that all three steps require supervisors to address behavior in the moment by asking employees to put on a face mask if they are seen not wearing a face mask in violation of the university’s safety regulation.

Step 1 – First Occurrence

At first sighting, supervisors should:

  1. Remind the employee that they are required to wear a face covering;
  2. Require them to put on a face mask immediately, and
  3. Provide the employee with a disposal mask to wear if they do not have one with them.
  4. After the immediate conversation, provide a written reminder about the regulation and the university’s expectations related to face coverings and safety regulations, either by providing a hard copy or via email using the Step 1 template notice.

Step 2 – Second Occurrence

After the first conversation and notice, supervisors should take the following action if the employee fails to wear a face covering:

  1. Require them to immediately put on a face mask providing one if they do not have one with them;
  2. Instruct them to complete the university training highlighting the importance of safety regulations and wearing face coverings, and
  3. Right away, provide a written reminder refers the employee to the training and lets them know that if they fail to comply with the face-covering regulation again, formal progressive disciplinary action may follow. Deliver the written notice in a hard copy or via email using the Step 2 template notice.
    It is critically important that supervisors enforce this expectation consistently and without regard for race, ethnicity, gender or any other status protected by law or university policy.

Step 3 – Third Occurrence

  1. Require them to immediately put on a face mask providing one if they do not have one with them; and
  2. Reach out to to discuss formal corrective action.

Helping Address Needs of Employees with Medical Conditions

Recognizing that not everyone is able to wear a traditional cloth or paper face mask, the university has several exceptions to the regulation, including one for individuals who have a physical or mental health condition that makes it difficult to comply. Supervisors and HR partners should work collaboratively with employees who raise such concerns.

These collaborative conversations should be focused on identifying and implementing an effective solution that meets the employee’s needs and furthers the interests associated with this requirement.

When put on notice of an employee’s concerns with wearing a face mask, the supervisor and HR partner should schedule a phone call or physically distanced meeting with the employee to discuss the situation and brainstorm possible solutions.

Important questions for the unit to ask the employee:

  • How does wearing a mask impact your medical condition when working? For example, does it trigger anxiety, does it distract you, does it make it difficult to breathe?
  • Is wearing a mask always difficult or only when performing certain tasks or when worn for an extended amount of time?
  • What type of face coverings have you tried? Do you think other types of face coverings, like paper masks, cloth masks or a face shield would work better for you? If not, why?
  • Are there other changes we could make to help address your concerns? For example, would it be helpful to have shorter, more frequent breaks (5 minutes every hour) where you could walk outside without a mask on?
  • Do you have any other ideas or is there anything else you want to share that you think could help us find an effective solution?

There are several important things the supervisor and HR partner should remember in connection with these conversations:

  1. These discussions should be private;
  2. You should not ask an employee to disclose their underlying medical condition or ask for medical documentation.
  3. You should take the employee’s representations about the impact wearing a mask has on them at face-value. The focus of this conversation should be on brainstorming solutions that meet their needs without undermining the larger health/safety objectives.
  4. Raising these concerns or asking for an accommodation (such as a modified break schedule) is protected activity. Retaliation is strictly prohibited.
  5. Units are permitted and encouraged to informally authorize requests for certain accommodations – such as trying a new type of face covering (such as a face shield) or temporarily implementing an adjusted break schedule. However, units are not authorized to excuse an employee from wearing a face covering in accordance with the regulation. Such requests must be reviewed, and can only be approved, by the ADA Coordinator, or designee.
  6. Units may not unilaterally make changes to the face-covering safety regulations or OHA guidance. If units are unable to find solution within that framework, they should reach out to the ADA Coordinator.

When to Contact Employee and Labor Relations

If the unit’s efforts are unsuccessful to find a solution within the safety regulation framework, then the supervisor should contact the ADA Coordinator in order to schedule a call to discuss the situation and determine next steps. The ADA Coordinator will assess each situation on a case-by-case basis.

If the employee is granted an accommodation to the face-covering safety regulation, then the unit may need to make other accommodations to protect the health and safety of other employees (for example, the employee may be asked to attend team meetings via phone rather than in-person). The unit will also need to re-emphasize the critical importance of effective hand-washing hygiene, physical distancing and abiding by all other safety measures intended to help reduce the potential spread of COVID-19.