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) 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” 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). Members of the community, and others as determined by the University, will sign an employee acknowledgement form (for faculty and staff, available via Workday) or a “Student Commitment to COVID-19 Community Health and Safety Requirements” form (for students) that affirms their understanding and acceptance of this policy.
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.
Faculty and staff who have been able to work from home – in full or in part and as determined by their supervisor – will continue to do so until alternate guidance is provided by the University.
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
Consistent with guidance from CDC and RIDOH, Brown community members who have been fully vaccinated for COVID-19 do not need to wear a mask or cloth face covering in any outdoor setting on-campus. Community members who have not yet been fully vaccinated must wear a mask outdoors if they are unable to maintain three feet of social distancing from others.
All Brown community members, visitors and guests authorized to be on-campus, regardless of COVID-19 vaccination status, must wear masks or cloth face coverings in indoor settings unless doing so would impact the individual’s health or unless alone in a laboratory, private office, residence hall room or similar area where there is no contact with others. Reasonable accommodations will be made for community members with health conditions preventing them from wearing masks.
- Wear a face covering at all times when teaching or attending an in-person class or similar academic activity or function in an indoor setting.
- Face coverings must be worn before entering a University building; while walking inside buildings; in areas such as stairwells, elevators, kitchens and bathrooms, where social distancing may be difficult to maintain; and while working, teaching, studying, conducting research or any other activity in the same indoor area as others.
- If you believe you need a higher level of protection such as an N95 respirator, as is appropriate in health care settings, please discuss concerns with your supervisor and have them contact Environmental Health and Safety (EHS) at [email protected] to conduct a risk assessment.
3.2.3 Personal Responsibility When Sick or Feeling Sick and for Public Health
All Brown community members must monitor their health conditions daily before arriving on campus and be aware of all possible COVID-19 symptoms. 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, have tested positive for COVID-19, have been exposed to COVID-19 (identified contact) and are not yet fully vaccinated for COVID-19, or otherwise are feeling sick. In the case of employees, they must inform UHR, and employees and students must contact their medical provider (University Health Services for students).
- 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.
- Any individual who has been exposed to COVID-19 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.
- 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.
Once an individual has fully received any COVID-19 vaccine (14 days after the final dose), 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 are contacted by RIDOH due to exposure.
- 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 are contacted by RIDOH due to exposure.
- 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 Workplace, Classroom and Other Physical Space Requirements
Physical work locations, including classrooms and laboratories, must follow the designated limits for capacity and proximity between individuals. To accomplish this minimum standard the following rules must be strictly adhered to:
- Individuals using classrooms, lecture halls, conference rooms, common spaces, huddle rooms and other similar convening spaces must maintain the designated social distancing at all times.
- Assigned work locations or assigned work schedules must be arranged to ensure that the designated social distancing standard is followed. Where possible, work locations must be physically separated from each other, or staggered schedules (including staggered breaks) established to allow for appropriate social distancing. Where staggered schedules and breaks are in place, the same cohorts of individuals to the fullest extent possible should work on the same schedules to further limit each employee’s network of contacts.
- In academic and administrative buildings the use of kitchen and break spaces is allowed with mask wearing required. Departments using such spaces will take responsibility for ensuring all coffee machines, microwaves, refrigerators and similar amenities are cleaned on a regular basis and disinfected before and after use.
- Limit to the extent possible eating and drinking to departmental approved areas where there are no groups, and maintain social distancing. Follow a best practice to disinfect surfaces before and after using rooms that will be used at other times by others.
- Eating while teaching or attending an in-person class or similar academic activity or function where mask wearing is required is not allowed. Drinking from a closed water bottle or similar container with a straw or similar device that allows for minimal uncovering of the mouth area is permissible, but should be kept to a minimum.
- In residence halls the use of kitchen and lounge and study spaces is allowed with mask wearing required.
- Work assignments and locations that require high-volume interaction with customers, students and the public at large will be protected with plexiglass or similar barriers to reduce the risk of transmission. Such locations include dining halls, Mail Services, Brown Bookstore, Campus Center, high-volume departmental reception areas, etc. Facilities Management will assess and install protections, and departments with such locations not already identified should note those needs in their plans and contact Facilities Management Service Response at 3-7800 for assistance.
3.2.7 Other Policy Expectations
- No social gatherings, formal or informal, in excess of the number of people allowed by the University.
- Meetings with visitors or guests that are essential must be held virtually. In the rare circumstance that a meeting cannot be held virtually, visitors must adhere to social distancing and wear face coverings, from arrival to and departure from University premises (or a University location).
- Shuttle transportation capacity will continue to be adjusted to abide by State of Rhode Island requirements. Faculty and staff should to the fullest extent possible make use of virtual meeting platforms to reduce the need to take the shuttle between campus locations during their workday.
3.2.8 Mandatory COVID-19 Testing
All faculty, staff and students and others as determined by the University (collectively “testing program participants”) who are working, living or studying on campus or approved to return to campus 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 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, the Rhode Island Department of Health, 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).
3.2.9 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.
This policy may be revised from time to time based on updated guidance issued by the CDC, RIDOH, OSHA, EEOC and WHO.
3.2.10 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.
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:
- COVID-19 Campus Safety Policy Employee Acknowledgment Form
- Student Commitment to COVID-19 Community Health and Safety Requirements Form
7.4 Frequently Asked Questions: