Reopening Of The Church – Phase III Guidance

On July 6th, Massachusetts entered Phase III, Step 1 of the reopening process.  Specific guidelines for churches and other “places worship” can be found at the site here.

The biggest update in the Phase III guidelines is that churches can now have gatherings with up to 50% (formerly 40%) of their occupancy permit limit.  This represents a continued opening up of the churches from the strict 10 person total limit in place prior to May 18th.

Churches that don’t have an occupancy permit on file with their town or city are advised to use a limit of 10 persons per 1,000 square feet.  

There can also be gatherings of up to ten people in a smaller enclosed space, such as a small group meeting or prayer team.  


The mask requirements continue to be conflicted, as before, because the guidelines read as if you have to wear masks all the time, but the mask order they refer to only requires masks when you can’t socially distance six or more feet.   Some churches are interpreting that guidance as meaning that once you are seated with your family six feet away from everyone else, you can demask.  

Specifically, the ‘sector specific’ standards for places of worship say:  “All attendees and staff must wear face coverings or masks in accordance with COVID-19 Order No. 31 and the Department of Public Health’s Guidance while inside and while entering and exiting places of worship or otherwise participating in in-person services…”

However, when you read both the COVID-19 Order No. 31 and the DPH Guidance, they clearly state that facemasks are for when you are unable to socially distance (six feet or more):

“Effective Wednesday, May 6, 2020, any person over age two who is in a place open to the public in the Commonwealth, whether indoor or outdoor, and is unable to or does not maintain a distance of approximately six feet from every other person shall cover their mouth and nose with a mask or cloth face covering,…”  – Face Covering Order (emphasis added)


“Any person who is in a place open to the public in the Commonwealth, when unable to maintain a distance of approximately six feet from every other person, shall cover their mouth and nose with a mask or cloth face-covering.  (emphasis added)

Therefore, if you are six feet or more away from all non-family members in church, I do not believe a mask is required by the orders/guidance.  They may still be a good idea in general, but I don’t see them as required for a pastor who is by himself at the pulpit, etc.  This also is not an analysis of whether or not such orders/guidance are constitutionally valid. 


A second new feature of the Phase III church guidelines concern child care.  The guidelines say: “Any childcare services should follow the latest EEC child-care guidance.” This is an improvement over earlier phases where child care was not permitted.  The EEC child-care guidance is over 30 pages long, and lays out a rather onerous process they outline for commercial childcare providers.  It is not clear the extent to which this is appropriate for or applicable to the typical Sunday morning nursery or children’s church.  We will be researching this question and updating you with what we find out.  


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