Few situations are as uncomfortable for an employer as talking with an employee about their personal hygiene. Still, poor personal hygiene can have a negative effect on clients and co-workers, and hygiene concerns should be addressed carefully. The following are some guidelines for addressing personal hygiene issues with an employee.
Confirm there is an issue.
Before trying to address a body odor or poor hygiene issue based on a co-worker's complaint, try to confirm that a problem actually exists by interacting with the employee in person.
Never assume you know the cause.
Personal hygiene problems may be caused by a variety of factors, including medical issues, cultural differences, mental health issues, personal problems, or poor grooming habits. Never assume that any one of these factors is the cause and be mindful of nondiscrimination laws when addressing a personal hygiene issue.
Understand workers' rights.
Under Title VII of the Civil Rights Act, the Americans with Disabilities Act (ADA), and similar state and local laws, employers may be required to make reasonable accommodations for individuals with disabilities, and for an employee's sincerely held religious beliefs and practices, unless it creates an undue hardship on the business.
For example, if the employee indicates the cause of a personal hygiene issue is a result of a medical condition that qualifies as a disability, the employer generally must work with the employee to find an effective accommodation.
This might include offering flexible schedules/rest breaks for the employee to take care of personal needs, providing a private office with an air-purification system, using odor-absorbing products in the work environment, allowing the employee to use leave for treatment (if applicable), and/or permitting the employee to work from home.
Or, if an employer requires employees to be clean-shaven, the employer might need to make an exception for individuals who maintain/start maintaining beards as part of their religious practices.
Prepare to respond.
If you have verified that a personal hygiene issue exists, it should prompt a conversation between the employee and a manager or HR representative who has the training and experience to handle these types of difficult conversations.
Meet with the employee in private.
The conversation should be held in private and in person (when possible). If another employee brought the issue to your attention, they should be reminded that you will handle the situation and that they shouldn't take action on their own.
Be tactful, but direct.
When starting the meeting with the employee, let the employee know that you plan to discuss a difficult topic. Then, provide an explanation of the issue, treating the employee with respect. Use factual terms, give specific information about what the problem is, and avoid judgmental language. Cite your policy (if applicable) and describe how the body odor or poor hygiene is affecting the business.
Give the employee an opportunity to speak.
During the meeting, give the employee an opportunity to respond. If the employee indicates the cause of a personal hygiene issue is a result of a medical condition or is related to a religious belief or practice, start a conversation with the employee to help determine whether Title VII, the ADA, and/or a state law applies and whether there are accommodations that may resolve the issue without causing undue hardship on your business. Consult legal counsel as needed.
Set expectations and document.
At the end of the meeting, clearly communicate your expectations and next steps. Document the conversation, what actions need to be taken to address the issue, and the potential consequences of failing to rectify the issue (in cases not involving an accommodation).
If an accommodation will be provided, make sure you document the possible options for accommodation, the chosen accommodation, and how the accommodation will be implemented.
Follow up with the employee.
Follow up with the employee to see how they're doing. If you have seen signs of improvement, acknowledge them. If an accommodation was provided, confirm with the employee that the accommodation is effective.
Conclusion
When personal hygiene is a problem in the workplace, focus on working with the employee to identify the issue and find a solution in a timely manner.
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