OSHA has released its long-awaited emergency rule requiring the COVID-19 vaccine or weekly testing for many employers. With compliance deadlines coming up, employers must navigate this new rule to stay in compliance.

While we monitor the outcome of judicial review of OSHA’s ETS, we suggest taking the following steps to prepare your workplace for compliance with the new vaccine or test mandate:

• Develop a policy.

• Educate employees.

• Figure out who is already vaccinated and start a roster.

• Provide paid time off to support employee vaccination.

• Set up a system for tracking tests (if you are going to allow a testing alternative).

• Make records available to your employees.

• Consider purchasing and making face coverings available in the workplace.

And finally, remember that OSHA has provided a few resources for your liberal use, which we have linked here:

Factsheets:

• COVID-19 Vaccination and Testing ETS

• Key Compliance Dates

• Workers' Rights Under the COVID-19 Vaccination and Testing ETS

• Information for Employees on Penalties for False Statements and Records

• Reporting COVID-19 Fatalities and In-Patient Hospitalizations to OSHA

• Detailed FAQs

• Vaccination Policy Sample

• Vaccination or Testing and Face Covering Sample

• Social Media Toolkit