This is a reminder that the January 10, 2022 deadline set forth in OSHA’s November 5, 2021 ETS is still in effect. Aside from your general ongoing obligations to maintain a safe work environment based on OSHA and CDC guidelines and to comply with the ETS generally, the ETS requires covered employers to take the following additional steps by that deadline:

1. Establish a policy on vaccination;
2. Determine vaccination status of each employee, obtain acceptable proof of vaccination, maintain records and roster of vaccination status;
3. Ensure employees who are not fully vaccinated wear face coverings when indoors or when occupying a vehicle with another person for work purposes;
4. Provide each employee information about the ETS; workplace policies and procedures; vaccination efficacy, safety and benefits; protections against retaliation and discrimination; and laws that provide for criminal penalties for knowingly supplying false documentation

Also, don’t forget that by February 9, 2022, you must ensure that employees who are not fully vaccinated are tested for COVID-19 at least weekly (if in the workplace at least once a week) or within 7 days before returning to work (if away from the workplace for a week or longer).

Please review the OSHA ETS for more information or contact our Employment Law Team with any questions.

table ETS Obligation


Anne-Marie Storey, Esq. Rudman Winchell
Anne-Marie Storey, Esq
Rudman Winchell

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