Can Printing Operations Require Workers to Wear A Face Mask? 

The recommendations on face masks or face coverings during the COVID-19 pandemic have been very fluid and now some states and local municipalities are requiring employees in essential businesses that are interacting with the public to wear them at work. The orders have been silent on essential employees, such as workers in printing operations, who are not encountering the general population. Compounding the question is that many of the current orders involving social distancing are strongly encouraging everyone to wear a face mask or use a face covering while they are in public and could be interacting with someone. In the recent Centers for Disease Control and Prevention (CDC) guidelines for workers who have been exposed to the coronavirus, and could be asymptomatic, they are requiring workers in this situation to wear facemasks or face coverings.

The U.S. Equal Employment Opportunity Commission (EEOC) has released guidance that states an employer may require employees to wear PPE, such as a facemask, that is designed to reduce the transmission of the coronavirus during the pandemic. They also state where an employee with a disability needs a related reasonable accommodation under the Americans with Disabilities Act (ADA), such as being allergic to latex gloves, the employer should provide these as long as it does not present an undue hardship.

The key question is that as the COVID-19 pandemic continues, can printing operations require employees to wear facemasks or have a face covering in the workplace? The answer to the question is yes, an employer can require employees to wear facemasks or face coverings in the workplace to help prevent the spread of the coronavirus. There is growing evidence indicating that some people that become infected do not exhibit any symptoms and can infect others and a facemask or other face covering will help prevent an infected person from spreading the virus.

Since printing operations are considered by OSHA to be a low-risk category of operation in their COVID-19 guidance, N95 or similar types of higher efficiency respirators are not required. OSHA’s current guidance for lower risk workers is not currently recommending face covers even though the Centers for Disease Control (CDC) has recently recommended wearing cloth facemasks in public, especially in high-risk areas.

Common facemasks such as surgical masks are not respirators as they are loose fitting while an N95 face mask is a disposable respirator. Respirators are tight fitting and are designed to protect your lungs not only against dust and pollen but other airborne particulates such as the corona virus. Since surgical masks and other face coverings are made of porous cloth or a synthetic fiber and they are loose fitting, they provide little protection against virus particles as they can easily get through or around the masks. The value of these types of face coverings is that they primarily protect others from your own germs. They also help the worker from touching their nose and mouth, then touching surfaces, such as doorknobs.

If a printing operation would require the use of a N95 or similar respirator, or an if employee chooses to wear one on a voluntary basis, the requirements in OSHA’s regulations covering respirators found at 29 CFR 1910.134 would have to be followed. The regulations require several actions including a written respiratory protection program that includes fit-testing, training, and medical exams.

Surgical masks and other similar face coverings do not have the same requirements. OSHA does require that the employee be given a copy of Appendix D of the standard. Appendix D Information for Employees Using Respirators When Not Required Under the Standard is mandatory and contains information about the proper use and limitations of these types of respirators.  SGIA has an Appendix D acknowledgement form that can be used to document the employee received a copy of it.

If an employee refuses to wear a facemask or has an underlying medical condition that prevents their ability to wear a mask, the employer cannot assign the employee work in areas that would require the employee to wear the mask. This may entail that they may not be able to perform their duties as required until the pandemic has subsided.

As the coronavirus pandemic continues to unfold, the use of face masks or other face coverings is becoming a more common recommendation by government agencies as one approach to help stop the spread of the virus. Some essential businesses are being mandated to have their employees wear face coverings, but for printing operations it is currently within the discretion of the company to require the continuous use of facemasks or other face coverings. If the company does decide to require them, they have the support of the government agencies and would have to address any situation where the use of them presents a concern for an individual employee.

For more information please contact the Government Affairs Department at