COVID-19 Vaccine and Testing ETS Paid Time Requirements

On Nov. 4, 2021, the Occupational Safety and Health Administration (OSHA) announced a federal 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 ETS requires employers to support vaccination by providing employees reasonable time, including up to four hours of paid time, to receive each primary vaccination dose and reasonable time and paid sick leave to recover from side effects following each primary vaccination dose. OSHA has stated that removing logistical barriers to obtaining vaccination is essential to increasing workforce vaccination rates. One such barrier for many employees is their lack of time off of work to receive the vaccine and recover from any potential side effects. This compliance bulletin will cover the requirements for employer support for employee vaccinations.

Action Steps

Employers should review, implement and enforce the requirements for helping employees with receiving the vaccination.


Fully vaccinated means:

  • A person’s status two weeks after completing primary vaccination with a COVID-19 vaccine with, if applicable, at least the minimum recommended interval between doses in accordance with the approval, authorization or listing; or
  • A person’s status two weeks after receiving the second dose of any combination of two doses of a COVID-19 vaccine that is approved or authorized by the FDA, or listed as a two-dose series by the WHO.


  • Nov. 5, 2021 – ETS publication and effective date.
  • Dec. 5, 2021 – Compliance date for most ETS provisions.
  • Jan. 4, 2022 – Compliance date for ETS testing requirement.

Support for Employee Vaccinations Overview

OSHA has indicated that employee concerns about missing work to obtain and recover from a COVID-19 vaccination dose are well-documented. This reflects the fact that many workers do not have access to paid time off to receive the vaccination or recover from side effects.

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