Communication received from a contact of mine in the HR industry

By Beth P.

The Jan. 4 proposal for the
New OSHA Emergency Temporary Standard on COVID-19 (ETS) is a proposal for a permanent standard.



It’s happening fast. In early November, OSHA announced a COVID-19 Vaccination and Testing Emergency Temporary Standard (ETS). The goal? Implementation starting January 4.

The ETS is a proposal for a permanent standard, so the rules may evolve. Until then, if you have 100 or more employees, you should be thinking about new vaccination, masking and testing policies.

As a company, you can decide.
Will you mandate vaccination for all employees? Or will you allow unvaccinated employees to work while wearing masks and undergoing weekly testing. It’s up to you.

What do you need to do now?

Start obtaining workers’ vaccination status. This can guide your decision about whether mandatory vaccination or a vaccine-or-testing option is best for your company. You may also want to consider the nature of your work (e.g. mostly remote, outdoors, or in private offices), other safeguards in place, worker shortages, etc.

Begin preparing a clear policy around your selected approach.

Require any workers who are not fully vaccinated to begin wearing masks indoors or while sharing vehicles—and follow additional OSHA requirements—beginning January 4.

Download our COVID-19 compliance checklist ( to start following the guidelines and crafting policies.

Get trusted advice from Creative Workforce Solutions
From determining who is responsible for the costs of testing to ensuring that your policies are fair and practicable, Creative Workforce Solutions will help you get it right. Look to us for a full suite of services, including:

Compliance consulting and perspectives

Policy development support

Management and workforce training

Anti-discrimination consulting