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New federal vaccine mandate rules for large employers

Nov 4, 2021 | Hotel COVID-19 Operations Guide, Public Health Orders, Reopening 2021, Restaurant Reopening Guide

** UPDATE: 11.7.21

AP: Appeals court stays vaccine mandate on larger businesses

NEW ORLEANS (AP) — A federal appeals court on Saturday temporarily halted the Biden administration’s vaccine requirement for businesses with 100 or more workers. The 5th U.S. Circuit Court of Appeals granted an emergency stay of the requirement by the federal Occupational Safety and Health Administration that those workers be vaccinated by Jan. 4 or face mask requirements and weekly tests.

Click here to read more from the Associated Press.


The long-anticipated Occupational Safety and Health Administration rules on President Biden’s vaccine mandate were released this morning. The rule is nearly 500 pages, so it’ll take a few days to fully analyze its impact on the hospitality industry. What we know so far based on early analysis:

  • Workers at companies with 100 or more employees (within the entire organization, not per location) will need to be fully vaccinated against COVID-19 by Jan. 4, 2022 or get tested for the virus weekly.
  • Unvaccinated workers will be required to test negative for COVID-19 at least once a week and wear a mask while in the workplace.
  • Companies won’t be required to provide or pay for the tests, but they must give paid time off for employees to get vaccines and sick leave to recover from side effects that prevent them from working.
  • The rule requires covered employers to develop, implement, and enforce a mandatory COVID-19 vaccination policy starting December 5, which includes mask requirements for unvaccinated employees and paid time off for getting the vaccine (up to four hours per shot).

What this means for Washington state businesses is still uncertain. Gov. Jay Inslee can implement the federal mandate as is, though he also has the authority to strengthen the OSHA standards for Washington employers.

We expect to hear more details from the governor’s office in the coming days. The association’s government affairs team will continue to monitor the situation for any new developments and will pass those along to you when we learn more.

Webinars: Save the dates & register today

Be sure to register for upcoming webinars where this new policy will be discussed in greater detail and your questions will be answered.

  • AHLA: OSHA Vaccine Mandate ETS: What It Means for Hoteliers: 10 a.m. PDT, Nov. 5 [Register here]
  • National Restaurant Association: 1 p.m. PST, Nov. 8 [Register here]
  • Ask a Lawyer with Catharine Morisset: 10 a.m., Nov. 24 [Register here]