Outside of the healthcare industry, an employee vaccination policy seems like something a business wouldn't have to ever dream of writing. Cue a global pandemic.
As of December 17, 2021, OSHA's (Occupations Safety and Health Act) Emergency Temporary Standard has been reinstated. In case you were unaware of the initial ETS, it was a policy put in place, to be enforced by OSHA, requiring all employer's with 100 or more employees to have a current record of all employee's vaccination status and to implement a written vaccination-or testing policy. The ETS was suspended by a federal appeals court on November 6th, so that the courts could evaluate whether the ETS was a government overreach. The stay was lifted by the 6th Circuit Court in a 2-1 ruling.
"Based on the [Occupational Safety and Health Act's] language, structure and Congressional approval, OSHA has long asserted its authority to protect workers against infectious diseases," wrote Judge Jane Stanch for the majority. "OSHA relied on public health data to support its observations that workplaces have a heightened risk of exposure to the dangers of COVID-19 transmission."
At OnBoard, we have compiled some in-house tips to help you navigate this uncarted territory. After reading, if you are still unsure about where to begin, our team would be happy to guide you and your specific workforce through the implementation of a new policy.
1) Survey the Status of Your Workforce
Figuring out what percentage of your employee's are already vaccinated can make policy decisions easier. If 90% of your employee's are vaccinated, then the chore of masking and testing will be much easier. If 20% of your workforce is vaccinated, then more strategic masking and testing procedures will need to be created.
This seems simple, but have you ever tried to herd cats during a blizzard? Yea, that's what it may feel like. The trick here is to create a simple and confidential form that employee's can complete and return to management by the end of their shift. This needs to be done in a timely manner so that the next steps of the process can be completed.
If you have workers who are remote or not scheduled for a while, shoot them a personal email asking them to complete the form. Be sure when you receive the results, that only designated management has access to the information and that the information is placed in a secured separate file folder as to not violate HIPAA policies.
2) Make the Decision
Now that you have gathered all relevant data, it is time to make some decisions. This may seem like a political game, but try to approach this from a daily operations standpoint. This policy is a requirement, there is no option NOT to comply. The options you do have are:
- Require all employee's to be fully vaccinated (except those with protected exemptions)
- Require all employee's to either be fully vaccinated - OR - mask and test regularly
That's it. One or the other. But it is not that simple, you should also take the following into consideration:
- How many employee entrances are there? (How many testing stations are needed)
- How often will you require testing?
- Who will pay for the testing?
- What is the policy if an employee tests positive?
- What is the policy for employee's refusing to comply?
There is no black or white answer to the above questions, as OSHA has left it up to each individual employer to make the decision that best fits their business operation needs. OnBoard suggests putting together a committee of supervisors that represent various departments of the business. This will bring together multiple perspectives and result in a policy that works best for the majority of the workforce. Remember, you can not please everyone, and some bad apples may leave. But, you will have to cross that bridge when you get to it.
3) Communicate the Policy
Providing accurate and relevant information is key to communicating the necessity of compliance to the new organizational policy. Create posters that can be posted in break rooms, send emails, hold Q&A sessions and informational meetings. Make sure that all employees not only hear about the policy, but also have the opportunity to ask questions and voice concerns. If there is an overwhelming opposition to the new policy, create a town-hall like meeting, outside of working hours, where a few committee members can meet with concerned employee's in a non-confrontational manner.
Remember, as a business leader, you should remain in charge of the conversations. Expressing that you understand and hear your employees can go a long way, but if the conversation gets out of hand, you will need to stop the discussion and break the group down even smaller to get anywhere. You do not want to allow shouting matches or threatening/ violent behavior in these meetings. That behavior only escalates poor feelings and does not contribute to the overall reason for the meeting.
If you have read these tips and are still feeling the overwhelming dread of creating a policy, we are here to help. At OnBoard, we specialize in taking the heavy lifting off of business owners in times such as this. As a third-party, we can come in with fresh eyes and an objective view to help facilitate conversations and help your business make decisions that will be the best for employees and operations.
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