The OSHA Vaccine Mandate: What Employers Need to Know - Grace Hill
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The OSHA Vaccine Mandate: What Employers Need to Know

Posted on November 5, 2021 by Grace Hill

Update: On Thursday, January 13, the United States Supreme Court invalidated the Occupational Safety and Health Administration (OSHA) COVID-19 Vaccination and Testing Emergency Temporary Standard (ETS). The ETS was initially scheduled to take effect in December 2021 and had been on hold while under judicial review.


The Occupational Safety and Health Administration (OSHA) has released an emergency temporary standard (ETS) obligating private employers with 100 or more employees to require vaccination or weekly testing and masking for their unvaccinated employees. The ETS requires covered employers to ensure all unvaccinated employees working in-person begin wearing masks by Dec. 5, 2021, and provide a negative COVID-19 test on a weekly basis beginning Jan. 4, 2022.

Key Requirements of Covered Employers Under the ETS

  1. Develop, implement, and enforce a mandatory COVID-19 vaccination policy, with an exception  for employers that instead establish, implement, and enforce a policy allowing employees to elect either to get vaccinated or to undergo weekly COVID-19 testing and wear a face covering at the workplace.
  2. Determine the vaccination status of each employee, obtain acceptable proof of vaccination from vaccinated employees, maintain records of each employee’s vaccination status, and maintain a roster of each employee’s vaccination status.
  3. Support vaccination by providing employees reasonable time, including up to four hours of paid time, to receive each primary vaccination dose and reasonable time and paid sick leave to recover from any side effects experienced following each primary vaccination dose.
  4. Ensure that each employee who is not fully vaccinated is tested for COVID-19 at least weekly (if in the workplace at least once a week) or within seven days before returning to work (if away from the workplace for a week or longer).
  5. Require employees to promptly provide notice when they receive a positive COVID-19 test or are diagnosed with COVID-19.
  6. Immediately remove from the workplace any employee, regardless of vaccination status, who received a positive COVID-19 test or is diagnosed with COVID-19 by a licensed healthcare provider, and keep the employee out of the workplace until return-to-work criteria are met.
  7. Ensure that each employee who is not fully vaccinated wears a face covering when indoors or when occupying a vehicle with another person for work purposes, except in certain limited circumstances.
  8. Provide each employee with information, in a language and at a literacy level the employee understands, about the requirements of the ETS; workplace policies and procedures established to implement the ETS; vaccine efficacy, safety, and the benefits of being vaccinated (by providing the CDC document “Key Things to Know About COVID-19 Vaccines”); protections against retaliation and discrimination; and laws that provide for criminal penalties for knowingly supplying false statements or documentation.
  9. Report work-related COVID-19 fatalities to OSHA within 8 hours of learning about them and work-related COVID-19 in-patient hospitalizations within 24 hours of the employer learning about the hospitalization.
  10. Make certain records available for examination and copying to an employee (and to anyone having written authorized consent of that employee) or an employee representative.

Helpful Grace Hill Policies and Training Available Today



Policies & Training

Reasonable Accommodation Requests

To help you handle requests for exemptions from vaccine requirements


  • MG 6715 | Accommodation Requests
  • 6015 | Equal Employment Opportunity, ADA, and Accommodation
OSHA Recordkeeping

To help you gather and maintain vaccination and testing records appropriately


  • MG 6755 | Employment Records
  • MG 6815 | Occupational Safety and Health Act (OSHA)
  • Safety Series: Required OSHA Recordkeeping
Mask Usage

To help you communicate to unvaccinated employees about proper mask usage


  • Mask Use During the COVID-19 Outbreak
General COVID-19 Protocols

To help remind all employees about the seriousness of COVID-19 and basic prevention measures that help keep everyone safe


  • COVID-19: Basic Prevention and Preparation

To help supervisors and employees understand what constitutes retaliation and that retaliation is prohibited


  • Safety Series: OSHA 300
  • Safety Series: Manage Maintenance Safety
  • Safety Series: Practice Maintenance Safety
Handling Difficult Situations

To help people have difficult conversations they may need to have as the mandate is implemented


  • MG 6715 | Conversations with Team Members
  • De-escalation courses and boosters
  • De-Escalation Strategies
  • Booster: De-Escalating Conflict
  • Booster: Practice in De-Escalating Conflict
  • Quick Quiz: De-Escalation Strategies
  • Using Empathy to Develop Meaningful Connections with Others

Coming Soon From Grace Hill

  • A new policy to help you comply with the ETS.
  • A new course you can assign to employees in Vision to help meet the requirements of paragraph J of the ETS.
  • A searchable FAQ resource with topics most relevant to the property management industry highlighted and summarized.

Grace Hill is also updating some of our existing training on recordkeeping, confidentiality, and reasonable accommodations for disability and sincerely held religious beliefs to better help you navigate the requirements of the ETS.

Grace Hill’s marketing content team aims to create informative resources that help multifamily and commercial industry professionals elevate their performance. From blog posts and ebooks to infographics, checklists and webinars, the Grace Hill team has a singular focus: creating meaningful and engaging content that resonates with real estate professionals across the industry.  However, what makes Grace Hill so unique is the range of collective experience and collaborative spirit of its marketing content team. A group of talented writers with expertise in the real estate industry, overall management effectiveness, marketing strategy, and operational efficiency, the team provides new ideas to take performance to the next level. As a thought leader, Grace Hill's content team constantly pushes the envelope, experimenting with new resources and tools to keep industry professionals ahead of the curve.  Whether you're a seasoned pro or just starting out in the real estate industry, the content team at Grace Hill is creating resources to help you succeed. Learn more about Grace Hill on LinkedIn.

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