13 questions and answers about OSHA’s new COVID-19 vaccination standard

Here is the skinny on the Occupational Safety and Health Administration’s (OSHA) much-anticipated emergency temporary standard (ETS) on COVID-19 vaccinations for large employers. Released on November 4, the policy requirements take effect December 5 and must be fully implemented by January 4, 2022.

What large employers need to know

Who is covered? The ETS covers all private employers with 100 or more employees. It excludes healthcare employers already covered by an earlier directive issued in July as well as federal contractors covered by one of President Joe Biden’s Executive Orders (EOs) issued in September. It also doesn’t apply to employees who (1) don’t work around coworkers or customers, (2) work from home, or (3) work exclusively outdoors.

What does ETS require? Employers must adopt a written vaccination policy requiring all employees to be fully vaccinated unless they can’t get the shots for medical reasons or because of a sincerely held religious belief. The policy may offer them the option of (1) being fully vaccinated or (2) providing proof of regular testing for COVID-19 and wearing a face covering while at work. You can find sample vaccination and testing policies at https://www.osha.gov/coronavirus/ets2.

What is acceptable proof of vaccination? To comply with the ETS, employers must require—and maintain records of—one of the following types of vaccination proof: