OSHA Emergency Temporary Standard: It's Out!

The U.S. Department of Labor's Occupational Safety and Health Administration (OSHA) released the Emergency Temporary Standard (ETS) that concerns vaccine mandates and large private employers early Thursday, November 4^th. Covered employers must comply with the ETS by December 5, 2021. The ETS allows covered employees to complete their respective vaccination regimen by January 4, 2022 (and therefore the testing requirements will not be required until then).

Below are a few important takeaways (we will have a more comprehensive discussion about the below and recommendations for best practices published in the coming days):

• Covered Employers: 100 or more employees. To determine if the employer meets the threshold, employers must consider: (1) all U.S. locations, (2) includes all part-time employees, but not independent contractors; (3) all locations of corporate entity with multiple locations; (4) franchises treated separately; (5) integrated companies that handle