OSHA released new regulations around COVID-19 Vaccination and Testing Verification as an Emergency Temporary Standard (ETS). These new regulations for your workforce can be complex to understand (especially when it’s 490 pages long). Who does the mandate apply to? How do I count my workforce? What if some of my employees are remote? We’ve got your answers.
According to the OSHA regulations, the count should be done at the corporate-wide level, and not the individual geographic location level. If your company is based in multiple cities or states, all employees at all locations should be counted. Below is a breakdown of employee type and if they are covered by the ETS.
- Part-time employees: Yes. Part-time workers are counted toward the 100-employee minimum. Employers will need to add both their full-time and part-time employees to reach their total.
- Contract workers: No. Independent contractors will not count toward your 100-employee count.
- Seasonal workers: Yes. If the person(s) in question is employed at the time of the ETS, they should be included in the employee count.
- Remote workers: Yes and no. Employees who work from home should be included in the total employee count. For example, if 50 employees work remotely and 50 employees work from the office, the total employee count would be at 100. However, only the 50 employees who work at the office will be mandated to be vaccinated or have weekly testing. This logic also applies to employees who work exclusively outdoors.
It’s important to note that current vaccination status is not taken into consideration when counting employees. Therefore, if you have 200 employees and all are vaccinated, you are still covered under the ETS, but would only need to provide proof of compliance.
The ThrivePass Vaccine Verification Solution can verify vaccination and test result verification for everyone in your workforce. We handle all verification administration. Learn more.