OSHA ETS: What Records Must Covered Employers Collect, Retain, Safeguard, and Make Available Upon Request

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Last week, the Occupational Safety and Health Administration (OSHA) issued an Emergency Temporary Standard (ETS) implementing President Joe Biden’s COVID-19 vaccine mandate covering employers with at least 100 employees. The ETS is summarized here, including the general compliance deadline of 30 days from November 5, 2021, with an additional 30 days for testing to begin, if applicable.

Employers may already have the basic policy in place – get vaccinated or submit to periodic testing. But they may not be ready for the ETS’ record collection and record keeping requirements, or the obligations to make these records available upon request, sometimes within 4 business hours. Those are outlined here should the ETS survive the legal challenges filed in courts across the country.

When employers consider their ETS policies, they should consider these records issues to ensure compliance.

What records must covered employers collect and maintain?

Vaccination status. Because the ETS requires covered employers to determine the COVID-19 vaccination status of each employee, covered employers must collect

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