The author describes a specific scenario where a co-worker brought up these issues as work. So, yes, it sounds like for this person it was work-related.

However, I disagree with the author's recommendation to provide additional mental health support for people of color.

I think employee affinity groups for employees of different cultures can be a good idea, but specifically targeting POC for "mental health" services? That's not a good precedent.

Frankly, this memo is not well-written, my initial inclination was to dismiss aspects of it because I had a hard time following the reasoning, but once I read it a couple of times, I came around to agreeing about the diagnosis of the problem, but not all of the recommendations offered.