Start planning for OSHA's vaccine mandate.

Don't wait for OSHA to officially unveil its promised Emergency Temporary Standard (ETS) to begin revising your policies and planning for accommodation requests.

The ETS--announced by President Biden on Sept. 9 and likely to be published and take effect this fall--will force employers with at least 100 workers to require their employees to get vaccinated against COVID or submit to weekly testing to prove they're not infected. The ETS will also require these employers to provide paid time off for staff to get vaccinated or recover from post-shot side effects.

Employers failing to comply with this new vax-or-test mandate (or the time-off requirement) could face fines of up to $14,000 per violation.

OSHA's ETS could be unveiled at any time and would likely take effect immediately. Opponents of the mandate are threatening lawsuits to block implementation (see page 7). But employers should start planning as if it will take effect any day.

What to do now? Start encouraging workers now to get vaccinated to make compliance easier once the ETS takes effect. Also, if tracking weekly test results would be too much hassle and cost...