OSHA ETS Employee COVID-19 Vaccination and Testing Mandates

November 10, 2021


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On Nov. 4, 2021, the Occupational Safety and Health Administration (OSHA) issued an Emergency Temporary Standard (ETS) requiring employees of large employers either to get vaccinated or to test negative on a weekly basis. The ETS also requires large employers to provide employees with paid leave to get vaccinated and recover from vaccinations, and unvaccinated employees to wear a mask at work.

A panel of labor and employment and federal contracting team members from McGuireWoods provide an overview of compliance details coming out of the new OSHA ETS.


  • New OSHA vaccination, testing and PTO requirements
  • Timeline and scope of employer and employee coverage
  • Exceptions for religion and disability 
  • Impact on EO 14042 for federal contractors and CMS rule for healthcare
  • Impact on state law anti-vaccination provisions and other challenges 


  • Brian D. Barger, Partner
  • Rodney A. Satterwhite, Partner
  • Micah B. Schwartz, Counsel 

For more information, please contact Laura Pickert at [email protected].

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