Many employers are currently wondering what OSHA expects from them and their employees being vaccinated? What is considered compliant/non-compliant? During this interim time, under the assumption that the OSHA ETS will move forward, there are plans that employers can make now to prepare and consider:
What Can Employers Be Doing Now to Prepare?
- Ensure a written vaccine program policy allows for qualified exemptions/ADA compliance – communicate the policy clearly within the organization and apply the policy consistently to everyone, at all levels, within the organization.
- Provide a clear timeframe for completion and be flexible with PTO/sick time to allow employees to receive and recover from the vaccine.
- Consult with counsel to make sure you are implementing the procedures properly and seek their input into language.
- Follow the law closely as it is changing daily and update policies, procedures, and protocols accordingly.
- Establish how proof of vaccination is to be provided and how it will be kept confidential and secure.
- Start considering timing and implementation of possible booster mandate requirements/policies.
- Review/revise any overlapping operational and employment policies – Employee Handbook, Employment Contracts, Document Retention, etc.
- Be prepared to think about how to manage the need for employees to show proof of vaccination versus mere attestation and do so within the context of medical privacy concerns.
If you have questions about your company's OSHA compliance or how to prepare for changing vaccine mandates, reach out to the Goosmann Law Firm attorney team to help navigate you through the process.