Maryland Governor Larry Hogan’s Executive Order 20-07-29-01 (“Executive Order”) expands the statewide requirement to wear Face Coverings, and takes effect at 5:00 p.m. July 31. One of many expansions applies to persons “engaged in work in any area where: (a) interaction with others is likely, including without limitation, in shared areas of commercial offices; or (b) food is packaged or prepared.” Excerpts from Governor Hogan’s Executive Order on Face Coverings are attached here.

Businesses with employees may also wish to take the following actions:

1. ensure existing COVID-19 related health and safety policies meet the requirements under the Executive Order.
2. use clear internal policies and procedures to guide planning, documentation, and training on how violations will be handled, and follow uniformly.
3. consider federal requirements under the Americans with Disabilities Act (ADA) and related exemptions that may apply to employees or customers refusing to wear Face Coverings.
4. consider options and necessary precautions when addressing customer refusals to wear Face Coverings (e.g., security guard).

All businesses are encouraged to review Section IV of the Executive Order to determine how the broad mandate will be applied within their industry. Notably, commercial tenants may also need to consider any obligations imposed by landlords, such as an obligation to enforce the requirements of the Executive Order with their employees or customers.

If you have questions on these topics, you should contact your Miles & Stockbridge attorney.

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