Here is a recent (June 12) brief issued by Southeast ADA related to that:
The ADA and Face Mask Policies
Cutting to the meat of that article:
If a person with a disability is unable to wear a face mask, do I still have to allow them in my business or government agency?
Most states have either recommended or issued executive orders requiring the public to use face masks in public. Private businesses have also developed policies requiring the use of face masks. The ADA does not have any rules that address the required use of face masks by state and local governments or private business owners.
If a person with a disability is not able to wear a face mask, state and local government agencies and private businesses must consider reasonable modifications to a face mask policy so that the person with the disability can participate in, or benefit from, the programs offered or goods and services that are provided. A reasonable modification means changing policies, practices, and procedures, if needed, to provide goods, services, facilities, privileges, advantages, or accommodations to an individual with a disability.[10] The requirement to modify a policy, practice, or procedure does not include individuals without disabilities, as they are not protected under the ADA.
Examples of reasonable modifications to a face mask policy
Allow a person to wear a scarf, loose face covering, or full face shield instead of a face mask;
Allow customers to order online with curbside pick-up or no contact delivery in a timely manner;
Allow customers to order by phone with curb-side pick-up or no contact delivery in a timely manner;
Allow a person to wait in a car for an appointment and enter the building when called or texted; or
Offer appointments by telephone or video calls.
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Susan Rubin
Special Events Coordinator
Desert Botanical Garden
Phoenix AZ
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Original Message:
Sent: 06-19-2020 02:46 PM
From: Samuel Stephens
Subject: Face masks and ADA
I am a trustee and volunteer at the William Trent House Museum in Trenton, NJ. The museum will re-open sometime this summer and we are developing our policies and procedures. Wearing face masks and social distancing are key requirements for our visitors and staff, as well as hand sanitizing and facility cleaning. With regard to face masks, our question is this: "If we require visitors to wear facemasks, does this violate ADA requirements if the visitor states that they have a condition that makes breathing while wearing a mask difficult? If we deny such a visitor entrance to the museum, would this be a violation of their rights under ADA?"
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Samuel Stephens
Trenton NJ
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