Vaccine and Testing Requirement Update

Comments: 0

A message from Jim Herr.

Recently, I provided everyone with an update on the status of various vaccine/testing requirements that covered our business. Recall there were three categories of requirements:

  • Customer
  • Federal Contractor
  • OSHA Emergency Temporary Standard (ETS)

Today, I will provide another update, along with steps we are taking at ORR.

We are still dealing with customer requirements, mainly on a case-by-case basis after discussions with the customer. On December 7, 2021, the federal contractor requirement was stayed pending further litigation. When in effect, this required companies doing business directly with the federal government (or as a subcontractor) to have all employees vaccinated. It remains stayed until further notice. The OSHA ETS was initially stayed in November, but recently the Sixth Circuit dissolved the stay. This means the OSHA ETS is in effect, even as petitions to stay are pending before the United States Supreme Court.

The OSHA ETS, which was issued by the Occupational Safety and Health Administration, requires all businesses with 100 employees or more to either require vaccines for all employees or to allow a choice between vaccination or weekly testing. ORR falls under the scope of this requirement and we must be in compliance by January 10, 2022, with testing to begin on February 9, 2022. The OSHA ETS requires ORR to publish a policy, which we will. It will provide guidance to associates on how to navigate requirements. In short, associates should either get vaccinated (the simplest and least disruptive choice), or work with our soon-to-be-retained vendor to test weekly (every Friday) and submit test results. It is incredibly important that you participate in this process. ORR is subject to strict oversight and fines if you do not. 

In most circumstances, you should plan to take the test (as directed by our testing vendor) while at work. Our testing vendor will provide telehealth services so the results can be read in line with the OSHA ETS rules. You cannot self-administer and read your own results. We will ship tests to you, either to your local branch or your home. Associates who choose weekly testing (or are not completely vaccinated) must wear a face mask at all times, per the OSHA ETS

Please bear with us as we navigate this process. As you can imagine, this is quite a process and is very expensive. You can read more about how the OSHA ETS is expected to work here on the FAQ page: https://www.osha.gov/coronavirus/ets2/faqs 

If you intend to be vaccinated to avoid weekly testing, that’s great news! We will need proof of vaccination, which you can submit to Associate Services (via Tara Johnson, me, or the AppSheet survey that’s gone out to determine vaccination status). Like documentation of weekly testing, this proof of vaccination is necessary for ORR to proceed under the OSHA ETS. If you’ve already been vaccinated, but have not submitted your card, please do so now. 

Additionally, if you have not responded to the prior surveys from ORR regarding vaccination status, please do so now. Without an accurate baseline, we cannot estimate the number of tests needed for our associates. I’ve talked to many of you, and I realize that vaccination is a personal choice, but I urge you to consider getting vaccinated. It is the best way to move forward through these challenging times. The vaccines are safe and effective. They have proved to reduce the potentially drastic negative effects of COVID-19. The last thing we want is for you to become ill and unable to provide for your family.

I hope everyone had a wonderful holiday season and is ready for a new year. Together, we can overcome these challenges facing our business. I appreciate your commitment to ORR. As associates of ORR, it is our mission and purpose to protect and serve others. Meeting the requirements of the ETS will assist us in keeping our associates, our customers, and our communities safe during this challenging time. If you have any questions about the OSHA ETS, please contact me at 502.338.7394.

About the AuthorJim Herr

Jim is ORR's Executive Vice President of Administration, Development, and Legal Affairs. He also serves as President of InspectionLogic.