How to Create a COVID-19 Vaccination Policy in 4 Steps

December 7, 2021

Companies are contemplating how to comply with the Occupational Safety and Health Administration’s (OSHA’s) emergency temporary standard (ETS). Come January 4, businesses with over 100 employees will have to create an updated COVID-19 vaccination policy to adhere to these new guidelines.

What are the new guidelines?

According to OSHA’s new guidelines, employers will need to develop, implement, and enforce a  mandatory COVID-19 vaccination policy. There is, however, an exception for employers that establish,  implement, and enforce a policy that allows employees to elect to get vaccinated or undergo weekly  COVID-19 testing on top of wearing a face covering at the workplace.

In addition to the above standard, the new guidelines also require employers to:

  • 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.
  • Require employees to promptly provide notice when they receive a positive COVID-19 test or are diagnosed with COVID-19.
  • Make certain records available for examination and copying to an employee (and anyone having written authorized consent of that employee) or an employee representative.

For the complete list of requirements, see OSHA’s fact sheet.

When do these guidelines go into effect?

Originally, provisions were set to require employers to comply by December 6, 2021 — with the testing requirement going into effect on January 4, 2022. However, the 5th Circuit Court of Appeals temporarily blocked the rule from going into effect and, more recently, the 6th circuit denied a motion filed by the government to move the case to the circuit in Washington D.C.

While the mandate is currently suspended and facing legal challenges, employers can still prepare to comply with these guidelines. Some states and businesses have even taken action into their own hands and are requiring vaccinations.

Where do you start with creating these new policies?

Many employers have already introduced COVID-19 vaccination and testing policies. For others, they may be starting from scratch. For both situations, there are four key steps for companies to take to make sure they’re ready for the deadlines — regardless of litigation outcomes.


Step 1
Audit your existing policies against OSHA’s templates

Whether you’ve already established a COVID-19 vaccination and testing policy or this is your first round,  now is the moment to audit what you’ve put in place. Upon reviewing your current policies, it’s critical to  make the necessary changes to comply with the new requirements. While companies with existing policies will be a step ahead, every company will need to take another look to ensure no gaps or missing  pieces.

Some things to look out for from OSHA’S FAQs that your new policy should include:

  • Requirements for COVID-19 vaccination.
  • Applicable exclusions from the written policy (e.g., medical contraindications, medical necessity requiring a delay in vaccination, or reasonable accommodations for workers with disabilities or sincerely held religious beliefs).
  • Information on determining an employee’s vaccination status and how you will collect this information.
  • Paid time and sick leave for vaccination purposes.
  • Notification of positive COVID-19 tests and removal of COVID-19 positive employees from the workplace.
  • Information to be provided to employees and how the employer is making that information available to employees.
  • Disciplinary action for employees who do not abide by the policy.

On top of these requirements, employers should include the policy’s effective date, who the policy applies  to, all pertinent deadlines, and the procedures for compliance and enforcement. It’s also vital the  information you share with employees is in a language that all understand.


Step 2
Make the necessary changes to your policies

Once you’ve compared your existing policies with OSHA’s requirements, the next step is making the  necessary changes in your policy documents. In this step, it’s helpful to loop in stakeholders who can  check that nothing is missing so that you’re confident your policies are compliant.


Step 3
Find a partner to integrate your policies

Now that you have your updated policies, you’re faced with the looming question of how to put them into  place. With so many policy changes and compliance options, it can be overwhelming looking for the right  solution to help you put policies in place and safely bring your team back into the office.

You need to secure your building, determine your staff’s access eligibility, and enforce health screening  protocols in your office. While that may seem like multiple solutions, the good news is that you can partner with an access control provider to help you do all of the above so that you can transition your workforce safely back to on-premises operations.

Kastle makes it simple to ensure compliance with these new federal guidelines by employing your access control system to help comply with them. Kastle’s cost-effective and easy-to-use access control system integrates vaccination and testing status data into its access qualification criteria for employees and visitors.

And by configuring existing access control technology, Kastle keeps spaces secure and allows for effortless administration, with the ability to record and enforce health screening protocols into the daily office routine. Plus, this all seamlessly integrates with the KastlePresence mobile app or your office administrative team using the myKastle web portal. This function, combined with KastleSafeSpaces, will no doubt help you create the safest possible office re-entry while making it less complicated for you to comply with the federal mandate.


Step 4
Communicate policy updates to your employees

You’ve done all of the hard work of making sure your policies are compliant with the new standards and found the partner to secure your office, and now it’s time to let your employees know what exactly is happening as they make their return.

Creating and sharing this policy is a team effort, including the staff you communicate it to. Be prepared to answer your staff’s questions about these policies and how they affect them, and make sure both you and they understand that policies can change — as they have since the pandemic began.

You must also ensure that your team members know all of the deadlines, the ramifications of missing them, and what technology tools they’ll need to meet these deadlines. Remember, it’s critical that whatever you communicate uses a language that every employee understands.

Policy updates aside, this is also a great opportunity to reassure your team of all the steps you’ve taken to ensure a safe return to the office. Given that everyone (yourself included) has lived in a state of uncertainty since March 2020, you now have a chance to show everyone how you’re thinking ahead and mindfully bringing people back together.

And you don’t have to take this step alone. By partnering with a security provider like Kastle, your employees will see and appreciate that you are prioritizing technology that makes the office safer — while having an expert team help guide you in complying with a COVID-19 vaccination policy.

“To get more buy-in, remind them that just one mistake can cause major problems, and no one wants to be the person to blame. So, being well informed is in their best interest.”

– Brook Carlon, SPHR, SHRM-SCP
Chief Human Resources Officer, Kastle

Learn more about how Kastle can help you bring your team back together, safely.

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