OSHA COVID-19 ETS: Recordkeeping Requirements

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).

The Occupational Safety and Health Act (OSH Act) requires employers to maintain accurate records of employee exposures to potentially toxic materials or harmful physical agents that are required to be monitored or measured. The requirements under the ETS for recordkeeping were developed in accordance with the OSH Act.

Continue reading this SSG Compliance Advisor that covers recordkeeping requirements imposed by the vaccine and testing ETS.

ACTION STEPS

Employers should review, understand and implement these ETS recordkeeping requirements. Employers should also include these recordkeeping requirements in their written 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.