1.0 Policy Purpose
The purpose of the Brown University COVID-19 Campus Safety Policy is to manage all teaching, research, learning, work and other activities in a safe and orderly manner.
2.0 To Whom the Policy Applies
This policy applies to all faculty, staff, students (graduate, medical and undergraduate), all Brown University visitors and guests, and any other individuals approved to live, work, teach, study and conduct research on campus. Where the policy refers to “faculty and staff,” “employees,” “students,” “individuals,” “visitors and guests” or “community members” it must be read as encompassing all on-campus activities and persons. “Campus” means all University-owned, -leased or -occupied facilities and grounds or other locations where University functions, programs and activities are conducted.
3.0 Policy Statement
The COVID-19 Campus Safety Policy sets minimum standards which all members of the Brown community must be familiar with and comply with in order to protect the health and safety of all community members. More specific and updated information regarding current operations, allowable activities, and other requirements can be found on the University’s COVID-19 Campus Activity Status page which community members are responsible for periodically reading.
All faculty and staff will follow the directives provided by University Human Resources and the respective senior officer responsible for their area. All students will follow the directives provided by the respective dean based on the students’ relationship to the University (Dean of the College, Dean of the Graduate School, Dean of the School of Public Health, Dean of the Medical School).
This policy is subject to modification as new regulations, information and guidance become available from the U.S. Centers for Disease Control and Prevention (CDC), the U.S. Occupational Safety and Health Administration (OSHA), Rhode Island Department of Health (RIDOH) and other federal and state agencies.
3.1 Principles Governing COVID-19 Campus Safety
- Provide for the safety and well-being of every Brown community member while following current and applicable public health guidance and considering individual circumstances.
- Minimize health risks through appropriate and necessary health and safety measures.
- Maximize simplicity with clear and consistent guidance that all community members can easily and effectively follow.
- Provide easily accessible reporting mechanisms for community members with health and safety concerns and appropriate consequences for lack of compliance.
3.2 COVID-19 Campus Safety Requirements and Expectations
3.2.1 General Policy Requirements
Community members are responsible for periodically reading the information provided by Brown University to remain aware of up-to-date guidance on continued preparedness, action and response to COVID-19, and ways to prevent its spread. Policies provided by the University are based on recommendations from the CDC, OSHA and RIDOH.
Brown community members will be provided with training and information regarding how to comply with this policy to ensure a safe working and learning environment for themselves and their colleagues. Reasonable accommodations will be made for community members with disabilities and underlying health conditions as necessary and appropriate.
3.2.2 Face Masks and Coverings
Current University policy regarding face masks and coverings for vaccinated and unvaccinated Brown community members and visitors and guests can be found on the University’s COVID-19 Campus Activity Status page.
Guidance regarding face masks and coverings may change from time to time based on public health conditions and guidance from CDC and RIDOH. The campus community will be informed and expected to comply with mask requirements as communicated on the University’s COVID-19 Campus Activity Status page, University signage and information in buildings and elsewhere, direction from University officials (including at events), and other means by which the University disseminates current information regarding face masks and coverings policy.
Reasonable accommodations will be made for community members with health conditions preventing them from wearing masks.
Members of the community who have a medical or religious exemption to the vaccine requirement that has been approved by University Health Services or University Human Resources have received individual instructions regarding health and safety measures they must follow.
Brown University visitors and guests must comply with all guidance, direction and requirements regarding mask wearing, including at events.
Any member of the community who is not otherwise required to wear a mask may voluntarily choose to wear a mask in any setting at any time and for any reason (including personal and community protection against seasonal flu and colds). This personal choice must be respected. As with vaccination status, no one should ask another individual about their personal choice to wear a mask.
3.2.3 Personal Responsibility When Sick or Feeling Sick and for Public Health
All Brown community members must stay home from work, class and/or other University events and functions if they are experiencing symptoms of COVID-191. Brown community members should maintain a log of close contacts to aid in the event of contact tracing due to a positive test or possible exposure.
All Brown community members who have tested positive for COVID-19 must contact their medical provider (University Health Services for students). Employees must also inform UHR. Further information for staff regarding sick leave and related matters can be found in the University’s Paid Time Off Policy.
- Individuals who are diagnosed with COVID-19 must self-isolate. Employees must immediately notify UHR of their diagnosis and continue following the guidance of their health care provider; students must immediately notify University Health Services. The identity of anyone testing positive will be kept confidential by UHR and University Health Services and will only be shared by designated contact tracers who will notify the Rhode Island Department of Health, contact tracers employed or contracted by the University, other employees or contractors of the University on a need-to-know basis, and any other person or entity as required by law.
- Individuals must not return to work, classes and/or other University events or functions until the criteria established by federal and state agencies to discontinue home isolation are met.
Any individual who has been exposed to COVID-19 and is not Fully Vaccinated must seek medical attention as soon as possible to determine if they need to be tested for the virus and/or meet the criteria for quarantine.
Once an individual has been Fully Vaccinated, if they have been exposed to COVID-19 or travel to Rhode Island from out-of-state, they do not need to quarantine if they meet all of the following criteria:
- has received, at least 14 days before the last exposure or out-of-state travel, a final vaccine dose that is either FDA-approved or received an Emergency Use Authorization, or for which the World Health Organization has issued an Emergency Use Listing (WHO EUL); and
- they haven’t had symptoms of COVID-19 since the last exposure or out-of-state travel.
1 Symptoms may appear 2-14 days after exposure to the virus. People with these symptoms or combinations of symptoms may have COVID-19: Cough, shortness of breath or difficulty breathing (or at least two of these symptoms: fever, chills, repeated shaking with chills, muscle pain, headache, sore throat, new loss of taste or smell). Check the CDC website periodically as the symptom list may be updated as more medical information is learned.
3.2.4 Personal Responsibility to Report a Positive COVID-19 Test or Close Contact
All faculty and staff must notify UHR if they test positive for COVID-19 or if they are contacted by RIDOH due to exposure and they are not Fully Vaccinated.
- In consultation with UHR, employees will be informed of immediate next steps to take. UHR will receive and monitor inquiries throughout normal business hours at [email protected].
- Supervisors must notify their property manager (Facilities Management or other), so appropriate facility cleaning and disinfecting can be coordinated.
- The identity of anyone testing positive must be kept confidential. No personal identifying information can be shared, only that there is a positive case in an office, floor or building so that preparations can be made to clean the facility as recommended by the CDC.
- If closing of spaces is necessary, critical access will be handled on a case-by-case basis as directed by EHS.
- For additional information on steps to take when an employee has contracted COVID-19, please visit the UHR website.
All students must notify University Health Services if they test positive for COVID-19 or if they are contacted by RIDOH due to exposure and they are not Fully Vaccinated.
- Students will be directed to "isolate" from others. Information can be found on the Health Services website with regard to steps students can take when they are sick. Students will be contacted daily during their infectious period to check in on symptoms and respond to questions or concerns. Isolation will last a minimum of 10 days from the onset of symptoms.
- University Health Services will determine when isolation can conclude.
3.2.5 Responsibility for Promoting Safe Hygiene
Facilities Management and other property managers will clean and disinfect common spaces and high-touch surfaces in these spaces; however, all Brown community members must take responsibility for promoting safe hygiene practices, including vigilant hand washing and cleaning (sanitizing) of classrooms, laboratories, work stations and other office areas, especially including common work areas, surfaces and equipment, such as shared printers and copiers. The University increased the frequency of cleaning across campus, but individual behavior is critical to reducing the risk of spread for all community members.
3.2.6 Mandatory COVID-19 Testing
All faculty, staff and students and others, regardless of vaccination status, as determined by the University (collectively “testing program participants”) are required to undergo COVID-19 testing at times and dates established by the University to determine if they have the virus and to allow the University to estimate the incidence of infection in the Brown community. Testing program participants will receive instruction from the University regarding testing requirements and frequency.
- Testing will be administered by a third party testing company selected by the University. Testing and/or health monitoring may occur prior to a participant’s return to campus, as a condition of the testing program participant’s continued work or presence on campus, and at any other time at the sole discretion of the University. In addition, the University may administer routine testing of faculty, staff and students and others, using the least invasive means of reliable and accurate testing available. The routine testing will allow a better understanding of the incidence of the 2019 novel coronavirus (COVID-19) in the Brown population.
- Testing costs and any expenses related to testing of participants through this program will be covered by the University.
- The University and the testing company will maintain the confidentiality of a participant’s COVID-19 test results and will only share a test result with the individual tested, RIDOH, contact tracers employed or contracted by the University, other employees or contractors of the University or the testing company on a need-to-know basis, and any other person or entity as required by law. The name of an individual who tests positive for COVID-19 will only be disclosed to others if necessary to prevent a direct threat to health and safety in accordance with applicable law.
- The University will ensure that these mandatory testing requirements are applied in a consistent, non-discriminatory manner in accordance with all applicable laws and regulations.
- Test results will be maintained in a secure and confidential medical file that is separate from an employee’s personnel or student’s academic file.
- Non-exempt employees will be compensated for time spent traveling and waiting for the administration of a test. Testing times will be coordinated with work shifts when appropriate.
- Testing program participants should note that nasal swab testing only reveals if the virus is currently present. A negative test does not mean that the individual will not acquire the virus later. Therefore, even if an individual tests negative for the virus, individuals must continue to comply with all requirements in the COVID-19 Campus Safety Policy to help ensure a safe campus environment for themselves and their colleagues/peers.
- Failure to comply with these mandatory testing requirements will disqualify an employee or student from being on campus and may subject an employee or student to discipline, up to and including termination of employment for employees. Students may be subject to non-academic discipline through the Office of Student Conduct and Community Standards (see Section 6.0).
3.2.7 Employee COVID-19 Vaccination Requirement
In order to provide and maintain a safe work environment, Brown will require COVID-19 vaccinations of all employees (faculty, staff, postdoctoral scholars, visiting researchers, lecturers, and seasonal and intermittent staff) working at any Brown owned, leased or managed premises and/or engaging in any in-person work with other Brown employees, students, or visitors for the fiscal year 2022 (July 1, 2021 – June 30, 2022). This policy is based on guidance from the Centers for Disease Control and Prevention (CDC), the Occupational Health and Safety Agency (OSHA), the Rhode Island Department of Health (RIDOH), and the U.S. Equal Employment Opportunity Commission (EEOC).
All employees must either 1) provide proof that they have received a full course of a U.S. Food and Drug Administration (FDA) or World Health Organization (WHO) authorized COVID-19 vaccine, or 2) obtain a medical or religious exemption approved by Brown with a reasonable accommodation. The process for requesting an accommodation for either medical reasons or based on a sincerely held religious belief, practice or observance is set forth below. Employees who do not fulfill one of these two requirements will be placed on leave without pay, family and medical leave, or other employment status, and their status will be evaluated periodically.
To establish that they have received a vaccination, employees must provide proof of vaccination by uploading their vaccination card to Workday or emailing it to UHR. Instructions are contained on this University Human Resources website.
Brown will assist employees in obtaining vaccines by providing on-site access to immunizations or identifying sites where employees may receive vaccinations (e.g. pharmacies, State locations). Employees may take work-time to obtain their vaccinations. Vaccines are free of charge.
For an employee who has a disability or who has a qualifying medical condition that contraindicates the vaccination, or who objects to being vaccinated on the basis of a sincerely held religious belief, practice or observance, Brown will engage in an interactive process to determine if a reasonable accommodation can be provided to perform the essential functions of the job so long as it does not create an undue hardship for the university and/or does not pose a direct threat to the health or safety of others in the workplace and/or to the employee. To request an exemption and reasonable accommodation, go to the University Human Resources homepage for information regarding how to complete the Request Form and submit it through Workday. After receipt of the Request, UHR or other appropriate personnel will determine whether the employee qualifies for an exemption and engage in an interactive process with the employee to identify a reasonable accommodation. Requests for exemptions are encouraged to be submitted no later than July 1, 2021 or at such times that an employee determines that they may qualify for an exemption.
No one, including supervisors, should ask an employee about their vaccination status. UHR is tracking vaccination status of all employees and Student Health Services is tracking vaccination status of all students.
This policy may be revised from time to time based on updated guidance issued by the CDC, RIDOH, OSHA, EEOC and WHO.
3.2.8 Student COVID-19 Vaccination Requirement
Starting no later than the 2021 Fall semester, Brown will require COVID-19 vaccines for all students who will be on campus or engage in any level of in person instruction, whether in the U.S. or abroad. In addition, all Brown students who are engaged in on-campus activities (education, jobs, research, or engaging in any in-person education or work with other Brown employees, students, or visitors) during the Summer 2021 term are required to receive the final dose of their COVID-19 vaccine by July 1, 2021.
Medical and religious exemptions will be granted and reasonable accommodations provided under applicable law. Students who are not vaccinated and do not qualify for a medical or religious exemption will be required to study remotely without permission to access campus. Further information regarding the implementation of this requirement, including the process for providing vaccination documentation and requesting exemptions, will be provided to students from University Health Services.
No one, including faculty, instructors, coaches or supervisors, should ask a student about their vaccination status.
3.2.9 COVID-19 Vaccination Booster Requirement
The University will continue to monitor the developments regarding the need for and recommended use of booster vaccinations for COVID-19 and follow guidance from the CDC and Rhode Island Department of Health (RIDOH) and best medical practice when available. When and if boosters become available and recommended, the University will communicate at that time whether they are required or not. If booster vaccinations for COVID-19 are required by the University, University employees and students will need to comply fully with that requirement in a manner similar to the COVID-19 Vaccination Requirement policy and processes delineated in sections 3.2.7 and 3.2.8 above.
3.2.10 Campus Visitor and Guest COVID-19 Vaccination Requirement and Mask Protocol
Beginning August 15, 2021, visitors and guests will be allowed on campus without specific approvals or permissions, subject to the following provisions and expectations:
Visitor and guest vaccination requirement: Visitors to Brown, whether researchers, faculty, students or others, who are engaged in any sustained and consistent in-person contact with other Brown employees, students or visitors are required to be vaccinated for COVID-19. Any visitor of this type who is not vaccinated for COVID-19 must engage with the University virtually. Exemptions for medical or religious grounds do not apply to visitors to the University. However, if the visitor is an individual with a disability, the individual may seek a reasonable accommodation.
Categories of Visitors: Given the range of types and lengths of visits to the campus, the implementation of the vaccination requirement may vary across programs. In general, visitors fall into three categories:
1) long-term (usually a semester or more although sometimes for shorter periods of time and with an appointment in Workday): Required to upload documentation of vaccination into Workday prior to beginning work at Brown;
2) short-term (four full days over the course of a month or more, but without an appointment in Workday): Required to sign a University vaccination attestation form;
3) limited-duration (visits of three days per month or less): not required to sign a vaccination form; they must abide by the COVID-19 Campus Safety Policy and any requirements specific to the facility or program they are visiting (e.g., health care or medical research settings with indoor mask requirements).
Campus Tours: Participants on campus tours conducted by the Office of College Admission are limited-duration visitors.
Additional information and guidance regarding vaccination requirements for visitors and guests, including links to the vaccination attestation form and information regarding seeking a reasonable accommodation for an individual disability, may be found on the Healthy Brown Website.
Mask Protocols: Visitors and guests must comply with all University mask requirements. Current University policy regarding face masks and coverings for vaccinated and unvaccinated Brown community members and visitors and guests can be found on the University’s COVID-19 Campus Activity Status page.
For the purpose of this policy, the term below has the following definition:
- Fully Vaccinated:
An individual who is 14 days past the date of their final dose of a U.S. Food and Drug Administration (FDA) or World Health Organization (WHO) authorized COVID-19 vaccine.
All individuals to whom this policy applies are responsible for becoming familiar with and following this policy. University leaders and supervisors are responsible for promoting the understanding of this policy and for taking appropriate steps to help ensure compliance with it.
6.0 Consequences for Violating this Policy
All members of the community must take seriously and follow the Brown University COVID-19 Campus Safety Policy. Corrective action will be taken if community members do not comply with the policy, up to and including suspension without pay or termination of employment, enrollment in or association with the University, in accordance with applicable (e.g., staff, faculty, student) disciplinary procedures, or, for other non-employees the suspension or revocation of the user’s relationship with Brown University.
7.0 Related Information
Report behaviors inconsistent with or in violation of this policy to a supervisor, UHR or other University official. For emergency situations, call the Brown Department of Public Safety at 401-863-4111. Additionally, Brown’s Anonymous Reporting Hotline allows anonymous and confidential reporting on matters of concern online or by phone (877-318-9184); however, please note this service does not generate an immediate response.
The following information complements and supplements this document. The information is intended to help explain this policy and is not an all-inclusive list of policies, procedures, laws and requirements.
7.1 Related Policies:
7.2 Related Procedures:
7.3 Related Forms:
7.4 Frequently Asked Questions: