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Complying With OSHA’s COVID-19 Vaccination ETS – Employer Checklist

The Occupational Safety and Health Administration (OSHA) has issued an emergency temporary standard (ETS) that requires all businesses with 100 or more employees to ensure workers are either tested for COVID-19 once a week or fully vaccinated.

Brief Timeline of the ETS

The White House issued the ETS in November 2021. A week later, the order was blocked in federal court, effectively suspending enforcement of the rule.

On Dec. 17, 2021, the ETS was reinstated in federal court, allowing its enforcement to go forward. Employers now have until Jan. 10, 2022, to comply with most ETS obligations. Feb. 9, 2022, is the current deadline for employers to implement testing requirements.

This checklist is a jumping-off point to help employers prepare for the rule. Not all items will apply to all employers in every circumstance.

Download Checklist


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