Few situations are as uncomfortable for an employer as talking with an employee about their personal hygiene. Still, poor 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, confirm that a problem actually exists. In light of the ongoing COVID-19 pandemic, remember to follow safety protocols even as you investigate the issue.

Never assume you know the cause.

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 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. Title VII and the ADA apply to employers with 15 or more employees, but many state and local laws apply to smaller employers.

Meet with the employee in private.

If you have verified that a 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. The conversation should be held in private. The employee should never be informed of a hygiene issue anonymously, via email, or in some other indirect way. 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 meeting with the employee, set the stage by letting the employee know that you plan to discuss a difficult topic. In some cases, the employee may be unaware that a problem exists and may need specific information about what the problem is. Provide an explanation of the issue, treating the employee with respect. Use factual terms 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 the 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. For example, accommodations may 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), or permitting the employee to work from home. 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. If an accommodation is the solution, document the discussion with the employee, the possible options for accommodation, and how the accommodation will be implemented. Once implemented, periodically check in with the employee to ensure 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.