Compliance Bulletin – COVID-19 Vaccine and Testing ETS Policy Requirements for Employers

On Nov. 4, 2021, the Occupational Safety and Health Administration (OSHA) announced a federal emergency temporary standard (ETS) to address the grave danger of COVID-19 infection in the workplace. Affected employers will be required to comply with most provisions of the ETS by Dec. 6, 2021, and with its testing requirements by Jan. 4, 2022. Affected employers include private employers with 100 or more employees (firmwide or companywide count).

The ETS requires each covered employer to establish and implement a written mandatory vaccination policy unless the employer adopts an alternative policy requiring COVID-19 testing and face coverings for unvaccinated employees. To meet the definition of “mandatory vaccination policy,” the policy must require vaccination of all employees, including all new employees as soon as practicable, other than those employees for whom:

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