The Occupational Safety and Health Administration (OSHA) issued an emergency temporary standard (ETS) on November 4, 2021, to all private organizations of the US that have more than 100 employees. Per the guidelines, employers must ensure their employees are either fully vaccinated or provide a weekly negative test report and adhere to the regulations of using masks.

Scope of the new mandate:

  • Covers all employers of private companies in the US with 100+ employees across various locations, and all categories of workers: full-time, part-time, remote, on-site, temporary, etc.
  • The new standard will supersede any conflicting state or local laws regarding masking, vaccination, and testing.

Important implementation dates for enterprises to note

Here are the new guidelines for all private enterprises in the US with over 100 employees: 

Implementation related to vaccination: 

  • Develop a COVID vaccination policy and circulate the same to all employees 
  • Determine the employees’ vaccination statuses and vaccination records 
  • Make a record of the total number of employees and the total number of vaccinated employees available to the concerned authorities. 

Implementation related to testing:

  • Implement weekly testing protocols for all unvaccinated employees. Collect and store the records appropriately. Both PCR and antigen tests are acceptable. 
  • Paid testing or paid time off for testing is not mandatory. 

Rules for masking:

  • Mandate face coverings for unvaccinated workers when indoors or in vehicles with other employees is mandatory. 
  • Provide paid time off for vaccination and reasonably paid sick leave for recovery from COVID. 


  • Vaccination/testing is not mandatory for employees working remotely and from home 

Maintaining vaccination records is mandatory 

As a part of OSHA’s new ETS, employers are required to collect and maintain an up-to-date record of the vaccination and testing statuses of all employees. Although employers are currently not required to submit these records or policies to OSHA authorities, they must be prepared to respond within four business hours if verification is requested.

The administration will continue to monitor employers. If required, they will request records and policies to ensure ETS is being properly implemented. Enterprises that are found to be willfully violating the OSHA mandates may face fines ranging from US$ 10,000 up to US$ 100,000.

Return-to-work challenges with OSHA mandates

Even though OSHA was announced two months ago and most private enterprises anticipated its release, a shorter implementation cycle is challenging for any business. Here are a few challenges enterprises will have to overcome to accelerate their return-to-office plans while adhering to OSHA mandates:

1.       Paper-based, error-prone  tracking methods

Some enterprises still rely on paper-based methods and spreadsheets to track the status of employee vaccination and testing. Manual processes make it difficult to pull out data and may often lead to errors and compliance issues.

2.       Time-consuming vaccination/testing status collection

It’s a time-consuming, and strenuous task which could take hours for your administrative teams to track, collect and organize data while adhering to compliance. Yet, there will still be scope for errors. 

3.       Implementation gaps

It’s also challenging for businesses to get real-time analytical data, hindering a complete overview needed for better decision-making for return-to-office policies. To meet enforcement needs, your business must have data ready at your fingertips to present to authorities within a few hours, if asked. Other challenges include contact tracing, incident case management, employee communication, and capacity management.

Tips to implement new OSHA guidelines without  hassles

As discussed above, process plays an important role in implementing  OSHA efficiently. Given the equal need to track vaccination and testing data along with communication of policies and contact tracing,  and COVID cases, your enterprise needs to have a robust system in place. Here are some tips to ensure timely implementation of the OHSA new ETS:

  • Transparency & communication

Transparency in creating and communicating vaccination/testing policies is key to ensuring your employees are well-informed about the mandate. When employees are aware of the updates, it would be easier to implement them in a short time. You should have a system in place for employees to raise concerns, request clarifications,  and provide feedback to make sure they are actively involved in the process.

  • Automation to rescue

As all private employers with over 100  employees are required to implement the mandates in a short period, failing to which may lead to penalties, organizations need a robust solution that helps them automate the circulating policies and latest changes, collect vaccination status, and maintaining vaccination/testing records ready for verification.

  • Leverage the right solution

The right solution not only helps your enterprise overcome the challenges of implementing OSHA mandates and aligning your return-to-work with them, but it also ensures you meet the audit requirement by maintaining a data record.

When you are choosing an automating software to accelerate your return-to-work, you must list down all the challenges and features you will need to tackle those challenges.  Firstly, you need a solution that is not only easy to use but also integrates quickly, allowing you to get started in weeks, not months, to meet your OSHA deadlines. The solution should also provide flexibility to adapt to future regulatory changes.

A single solution that provides a consolidated dashboard view of all your employee data will help simplify tracking the statuses of vaccination and testing. It must be easy to confirm negative results. . The right solution should provide valuable insights, simplify contact tracing, ease case management and capacity management, and enable seamless integration with your existing systems. It should also let your workers update their status from anywhere, any time.

Request Demo: Update vaccination status, collect test results, and get smart insights – all on a single dashboard – with Appian’s Workforce Safety Solution.

Ready for Change

Initiating full vaccination for all your employees will be an uphill task as some of them may oppose the idea. While it is a challenging time for private companies, the situation can be eased with mutual understanding and empathy towards employees. A robust communication plan that educates employees about the importance of vaccination, a personalized approach, and involving them in policymaking through surveys or feedback will go a long way in streamlining the process.

Apart from internal hindrances, some external factors may also affect your return-to-workplace plan with new OSHA updates. For example, the new update is being challenged by many, which may affect its implementation. Vaccination and testing requirement mandates may likely change further. Although change may be fast and unexpected, your enterprise can stay prepared with the right solution and processes.

In the competitive market, Appian’s Workforce Safety Solution empowers organizations to effortlessly strategize their return-to-work plan. With a powerful dashboard, valuable analytics, vaccination tracking and records feature, the Workforce Safety Solution can be built in just a few days’ time. You can stay on top of all the regulations, protect your employees and ensure no penalties are levied.

Are you ready to make your return-to-work safer, compliant, and vigilant? It’s easier with Appian’s Workforce Safety Solution. Learn More

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