OSHA released new regulations around COVID-19 Vaccination and Testing Verification as an Emergency Temporary Standard (ETS). The regulations come after assessing the safety of workplaces across the country and concluding that many pose a threat to employees and the greater population. Characteristics of various workplaces such as indoor offices or close contact with coworkers and clients indicate that exposure to COVID-19 can occur across all industries. OSHA estimates that implementing the ETS will get 23 million Americans vaccinated. In addition, they believe the mandate will prevent more than 6,500 deaths and 275,000 hospitalizations.
So, what does your company need to do in terms of drafting an internal policy for a vaccine verification program? Well, a mandatory vaccination policy requires full vaccination of your workforce. That is unless an employee falls into one of three categories:
- Receiving a vaccination is medically contraindicated
- Existing medical conditions or necessities require a delay in vaccination
- A sincerely held religious belief, practice, or observance conflicts with the vaccination (under federal civil rights laws)
Your internal policy should address all requirements from the ETS including:
- Information on how an employee’s vaccination status will be collected and verified
- Paid Time Off (PTO) and sick leave
- Positive COVID-19 tests and the procedure for removing those employees from the workplace
- Disciplinary protocol for employees who do not follow the policy
If an employer’s workforce includes both fully vaccinated and unvaccinated employees, the internal policy will have to establish guidelines for those who are unvaccinated.
In addition to the points above, policies should also address deadlines, who the policy applies to, and procedures for compliance.
The ThrivePass Vaccine Verification Solution comes standard with a legal policy so that you and your workforce are covered. We handle all verification administration. Learn more.