On May 26, 2020, California Governor Gavin Newsom announced that barbershops and hair salons could open with restrictions in counties that meet certain health criteria.  Services at barbershops and hair salons must be limited to those that can be performed with both the worker and customer wearing a face covering that covers the mouth and nose, such as haircuts, weaves and extensions, braiding, lock maintenance, wig maintenance, hair-relaxing treatments, and color services.  Services that cannot be provided while both the customer and worker wear a face covering remain suspended, including eyelash services, eyebrow threading and waxing, facials, etc.

Cal/OSHA and the California Department of Public Health issued guidelines for hair salons and barbershops to foster a safe and clean environment for workers and customers. These guidelines cover several safety topics.

Cal/OSHA is adhering to traditional guidance and requiring that hair salon and barbershop operators create and implement a worksite-specific COVID-19 prevention plan for each location.  The plan needs to include how the employer intends to conduct a job hazard assessment, implement exposure control, perform training, continually assess risk in the workplace, investigate exposures, and perform contact tracing.  Cal/OSHA requires employers to identify the people responsible for compliance, implementation and enforcement, which is a similar requirement to the Cal/OSHA Injury and Illness Prevention Program (IIPP).  Many employers may think they need to revise their IIPP, but incorporating the pandemic plan as part of IIPP may also be an option.

There is also a training requirement that requires hair salon and barbershop operators to train their workers to recognize the symptoms of COVID-19 along with different measures to prevent transmission of the virus. Operators should also encourage workers to conduct self-screenings at home, including temperature and/or symptom checks, and to stay at home if sick or exhibiting COVID-19 symptoms. The training should also address the importance of physical distancing, handwashing with soap and water, and proper use of face coverings.  Employers should hold employees accountable for following training protocols because if the workplace is inspected, Cal/OSHA may determine that the training was not effective if employees are not rigorously following it. 

The guidelines require hair salon and barbershop operators to conduct individual control measures and screenings. These measures must include conducting temperature and/or symptom screenings for all workers at the beginning of their shifts.  Operators should also screen customers upon arrival and cancel or reschedule customers who indicate that they are ill or exhibit any COVID-19 symptoms.  Operators must also clearly display a set of guidelines to be a condition of entry, which needs to instruct customers to wear face coverings, use hand sanitizer, maintain physical distance from other customers, and communicate changes to service offerings. Operators should provide and ensure workers use all required protective equipment, including goggles and gloves, and offer clean face coverings for staff and customers.

Hair salon and barbershop owners and operators need to be ready to implement cleaning and disinfecting procedures so that high-traffic areas and regularly touched surfaces are frequently cleaned and disinfected. Operators should prepare and adhere to a plan for cleaning at the beginning and end of each shift and between customers, including cleaning and disinfecting workstations, electrical and non-electrical tools, shears, handles, hoses, spray nozzles and other equipment before and after use on a customer.  Operators should schedule time for workers to clean and disinfect during their shifts and consider it part of the workers’ job duties. Facilities must discontinue the use of breakrooms and shared food and beverage equipment—e.g., coffee brewers—and amenities, including magazines, coffee, water, etc. The restrooms should be routinely stocked with paper towels and soap, and all unnecessary products such as candles or beauty supplies must be removed. Owners and operators can also consider installing portable high-efficiency air cleaners, upgrading the building’s air filters if possible, and increasing the quantity of outside air and ventilation in all working areas.

Hair salon and barbershop operators must implement protocols to ensure physical distancing among workers and customers and to take measures to minimize exposure where physical distancing cannot be maintained, including providing additional engineering controls, administrative controls and/or personal protective equipment.  Operators must require workers to avoid unnecessary contact such as handshakes, hugs, or other similar greetings and discourage employees from congregating in high-traffic areas and during breaks.  Employers should close breakrooms or increase the distance between tables/chairs to separate workers and ensure physical distancing requirements are complied with at meetings, or conduct meetings via webinar whenever possible. 

The California Department of Public Health and Cal/OSHA cautioned that this guidance is not intended to revoke or repeal any employee rights nor is it a substitute for any existing safety and health-related regulatory requirements such as those of Cal/OSHA or the California Board of Barbering and Cosmetology.  Cal/OSHA has additional comprehensive guidance and the CDC has additional requirements in their guidance for businesses and employers.  Accordingly, the analysis of whether a hair salon and barbershop is in compliance with these safety standards must be performed on a case-by-case basis.