The Occupational Health and Safety Administration’s plan to require employers with 100 or more workers to institute a COVID-19 vaccine mandate will go forward after all, thanks to a decision by the U.S. Court of Appeals for the Sixth District to reverse a lower-court ruling that blocked the Emergency Temporary Standard. The deadline for implementation is January 10, 2022, leaving urgent care operators who offer occupational medicine services precious little time to help their clients roll out their own initiatives. However, as noted in OSHA’s own language, the agency is drawing a distinction between compliance with the program as a whole and the testing component when it comes to enforcement and consequences of noncompliance:

“OSHA will not issue citations for noncompliance with any requirement of the ETS before January 10 and will not issue citations for noncompliance with the standard’s testing requirements before February 9, so long as an employer is exercising reasonable, good faith efforts to come into compliance with the standard.”

Complete details are available on OSHA’s COVID-19 Vaccination and Testing ETS page.

That Vaccine Mandate for Private Businesses That Was Called Off? It’s on Again—and the Clock Is Ticking
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