14 October 2021

OSHA Sends Employer Vaccine Rule to the White House for Review

Yesterday, OSHA sent the Employer Vaccine Rule to the White House (Office of Information and Regulatory Affairs (“OIRA”)) for review. As explained in our September 10 client alert and our September 13 webinar, the rule is an emergency temporary standard requiring private employers with more than 100 employees to implement vaccine mandates or testing. Sending the rule to OIRA is the final stage for compliance check prior to publication.

We do not yet have a copy of the rule. We are also waiting on information whether the administration will hold key stakeholder meetings on a draft copy of the rule. Reports indicate that the rule could drop as early as this week, but it is likely by the end of the month. When the rule is published, it will take effect immediately, but will likely include a “ramp-up” period under which employers have time to get in compliance. As always, we will keep you informed as soon as we have information to share.