Developing a COVID vaccination policy: Sample language.

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OSHA will soon require employers with 100+ workers to ensure their workers receive COVID vaccinations. But any organization can establish a mandatory vaccine policy now. Here is some sample language you can adapt to your purposes. (Note: The OSHA mandate, when released, could affect your policy details.)

Model vaccination policy

[Name of Company] is committed to protecting employees, customers, clients and vendors from COVID-19. To meet this goal, and in consideration of guidance released by the CDC and other public health authorities, [Name of Company] is implementing a mandatory vaccination policy for its workforce.

  1. All employees are required to have or obtain a COVID vaccination as a term and condition of employment at [Name of Company], unless an exemption is approved.

    All employees must report their vaccine status and provide approved documentation as proof of vaccination:

    * All current employees must report their status no later than [date].

    * All employees who are not vaccinated have until [date] to get fully vaccinated.

    * All employees who do not get vaccinated, including employees who receive an exemption from this policy, must submit to weekly COVID testing at their own expense. Employees who test positive must remain at home for 10 days. Such employees may work from home if their jobs permit. If their jobs do not permit working at home, such employees may use their accrued time off. Otherwise, the time off will be unpaid.

    * All new employees must provide proof of their vaccination status prior to the start of their employment.

    This policy applies to employees regardless of whether they work onsite or remotely, unless the employee qualifies for an exemption.

    Employees are considered fully vaccinated two weeks after they receive the requisite number of doses of a COVID vaccine.

    For Pfizer-BioNTech, Moderna or AstraZeneca, this is two weeks after employees received the second dose. For Johnson and Johnson, this is two weeks after employees receive a single dose. [Note: This section may need to be updated to include booster shots.]

  2. All employees, regardless of whether they previously attested to their vaccination status, must provide documentation of their vaccination.

    Employees' documentation must be on official forms and include the vaccination received, the number of doses received, the date each dose was administered and the name of the health care professional or clinic administering the vaccine. The following documentation...

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