OSHA COVID-19 ETS Determination of Employee Vaccination Status

On Nov. 4, 2021, the Occupational Safety and Health Administration (OSHA) announced a COVID-19 vaccination and testing 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).

ETS requires employers to be aware of each employee’s vaccination status. Effective implementation and enforcement of a written vaccination policy also require employers to know the vaccination status of all their employees. Knowing each employee’s vaccination status is necessary in order to ensure that the vaccination, testing and face-covering requirements of the standard are met. As such, the ETS includes provisions for determining each employee’s vaccination status.

Continue reading this SSG Compliance Advisor that covers ETS guidance and requirements employers must follow to determine their employees’ vaccination status. 

ACTION STEPS

Employers should review, understand and implement the ETS requirements for determining employee vaccination status
Employers should also include these requirements in their
mandatory COVID 19 vaccination policies

IMPORTANT DATES

Nov. 5, 2021
ETS effective date.

Dec. 6, 2021
Compliance date for most ETS provisions.

Jan. 4, 2022
Effective date for ETS testing requirement.