COVID-19 vaccine mandate for large employers

by Brandy Bruyere, NAFCU Compliance Blog

On November 4, 2021, the Occupational Safety and Health Administration (OSHA) published its awaited vaccine mandate for employers with 100+ employees. This interim final rule, published as an Emergency Temporary Standard, goes back to a September 2021 Executive Order issued by the White House, which also included a vaccine mandate for federal government contractors. We blogged previously about the Order and contractor mandate here and here. Of note, this OSHA mandate does not apply to those employers that are covered by the federal contractor vaccine mandate. Also, the links in this blog include to specific pieces of the rule to make it easier for credit unions to review the precise text that is being summarized.

So what does this mandate require? The rule has both a vaccine mandate and a face covering/testing requirement for unvaccinated employees, meaning those who qualified for a medical or religious exemption. For more information about such exemptions, OHSA points to this guidance from the Equal Employment Opportunity Commission.

The rule requires employers to develop a policy implementing the various elements of the rule, and to determine employees’ vaccine status. There are several ways for employees to show they are vaccinated outlined in the rule:

  • A record of immunization from a health care provider or pharmacy;

 

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