An EEOC Update: Navigating Religious Objections To Vaccine Mandates

On October 25, the U.S. Equal Employment Opportunity Commission (EEOC) updated its COVID-19 guidance with the addition of Section L to address employer obligations under Title VII of the Civil Rights Act of 1964 and religious objections to employer vaccine mandates. The update provides vital guidance to employers to navigate employee requests for religious exemptions from the employers' vaccine requirements, specifically those covered by the Occupational Safety and Health Administration's (OSHA) emergency temporary standard (ETS). 

Section L does not represent new policy but instead applies familiar principles to a specific scenario in order to provide succinct aid to employers' assessment of the increasing number of religious accommodation requests. As with an ordinary request for a religious accommodation, the EEOC counsels employers to make an individualized assessment of each request in light of the particular facts of each situation when an employee seeks