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OSHA COVID-19 Vaccine and Testing ETS Policy Requirements for Employers

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 each covered employer to establish and implement a written mandatory vaccination policy unless the employer adopts an alternative policy requiring COVID-19 testing and face coverings for unvaccinated employees. To meet the definition of “mandatory vaccination policy,” the policy must require vaccination of all employees, including all new employees as soon as practicable, other than those employees for whom:

  • A vaccine is medically contraindicated;
  • Medical necessity requires a delay in vaccination; or
  • A reasonable accommodation is legally entitled under federal civil rights laws because they have a disability or sincerely-held religious beliefs, practices or observances that conflict with the vaccination requirement.

This compliance bulletin will cover the requirements for COVID-19 policies for mandated vaccinations and alternative policies that include testing and face coverings.

Action Steps

Employers should review, understand and implement the requirements for developing, implementing and enforcing COVID-19 policies within their workplaces by Dec. 6, 2021.


A face covering includes coverings that:

  • Cover the nose and mouth completely;
  • Are made with two or more layers of a breathable fabric that is tightly woven;
  • Are secured to the head with ties, ear loops or elastic bands that go behind the head;
  • Fit snugly over the nose, mouth and chin with no large gaps on the outside of the face; and
  • Are a solid piece of material without slits, exhalation valves, visible holes, punctures or other openings


  • 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 requirements.
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