COVID Vaccination Mandate Details Just Released by OSHA

Finally, details have been released about the Biden’s COVID Vaccination mandate for organizations with 100+ employees:

  • OSHA published its Emergency Temporary Standard (ETS) requiring COVID vaccination or testing for employees of employers with 100+ employees.

  • Employers must start following the ETS requirements by December 5.

  • However, the testing requirements don’t apply until January 4, 2022.

  • Major legal challenges are expected.

  • TAKE NOTE: Once an employer hits the 100-employee mark (on or after November 5), they remain subject to the ETS for as long as it remains in effect, even if they drop below 100 employees.


HERE'S THE OVERVIEW:

  • Covered employers (100+ employees) must choose between:

    • Adopting a mandatory vaccination policy OR

    • Adopting a policy allowing employees to choose to either get vaccinated or test weekly and wear a face-covering indoors

  • Covered employers must ensure their employees have received two doses of Pfizer or Moderna or one dose of Johnson & Johnson by January 4.

  • Employers are required to have a written policy requiring all employees to be vaccinated (subject to medical or religious exemptions) OR allowing employees to choose between getting vaccinated or tested for COVID weekly and wearing a face-covering indoors.

  • OSHA states its standards overrule state or local requirements that limit an employer’s ability to require COVID vaccination, COVID testing, or face-coverings.

  • Such state and local bans are overruled, even for employers who have fewer than 100 employees.


TESTING DETAILS

  • All covered employers must ensure employees who have not received the necessary shots produce a negative test on at least a weekly basis.

  • Employers are not required to pay for the cost of the tests (but be sure to check state & local laws).

  • Tests cannot be performed by the employee at home.


PAID TIME OFF

  • Covered employers must provide up to four hours of paid time off for employees to get vaccinated during work, including travel time.

  • Employers cannot take this time out of an employee’s leave bank.

  • Employers are not required to reimburse employees for transportation costs to get vaccinated.

  • Employers must also provide two days of paid sick time to recover from vaccine-related side effects.

  • Employers can require employees to use their accrued sick leave or PTO (but not vacation).


THE FOLLOWING EMPLOYEES ARE EXEMPT:

  • Employees who work entirely alone (there are no other employees, clients, or customers present during their workday).

  • Employees who work from home.

  • Employees who work exclusively outdoors.


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