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.