There are several inconsistencies in the Guidance Document that need to be clarified:

1. While the document is labeled as "guidance," there are elements that read as mandates - such as those that appear to prohibit employers from enforcing their own mask mandates.
2. The issue of prohibiting enforcement seems to nullify statements giving employers the right to have their own policies OR to follow other governmental requirements (local, state, or federal).
3. This standard treats all employers with a broad brush, when there are multiple nuances to various industries.  Healthcare providers are dealing with strong CDC guidance that clearly advises broad use of PPE (not just masks) in all healthcare settings.  
   1. CDC guidance/recommendations may not qualify as mandates, but they DO mandate prudence and self-protection against liability in an environment fraught with risk to workers, patients and visitors. 
   2. The proposed Guidance Document appears to carry the potential interpretation that healthcare providers could be caught in a "Catch-22" situation.
4. In summary, the Guidance Document appears to make broad political statements to a collection of employers that are complex and nuanced.  The document needs to be clarified to help all of us know how to protect our employees, our customers, and our businesses.  It is more complex than the draft document presumes.