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OHA's Interim Guidance For Fully Vaccinated Individuals Author: Stephanie Leffler, 05/19/2021

Here we go again with more of the same. The burden of checking vaccination records falls on the employer if they choose to let patrons enter without an acceptable face covering.

OHA allows for most businesses without a vaccination policy need to continue to require face masks and physical distancing. (Exceptions include but are not limited to correctional facilities, shelters/transitional housing, grade schools, planes, buses and other public transportation and airports or other transportation hubs).

The only exception is if there is a vaccination policy in place that details checking for vaccination status, request and review proof. This leaves employers in a frustrating and logistic headache of trying to enforce the policy.

My guidance has not changed, continue to enforce wearing face masks unless your business chooses to implement a new vaccine policy.

Before you jump on the vaccine policy bandwagon, be aware that an employer is subject to fines if the patrons are not wearing a face covering that will comply with OSHA's definition below. If you are not prepared to monitor those entering your place of business, I would maintain the status quo. If you do want a policy, do not be selective and check everyone who enters or you may find yourself in some type of discrimination or other litigious claim.

Stay tuned for more information as it develops. I am happy to assist you with a vaccine policy.


“Face covering” means a cloth, polypropylene, paper or other face covering that covers the nose and the mouth and that rests snugly above the nose, below the mouth, and on the sides of the face.

The following are not face coverings because they allow droplets to be released: a covering that incorporates a valve that is designed to facilitate easy exhalation, mesh masks, lace masks or other coverings with openings, holes, visible gaps in the design or material, or vents.

• “Face shield” means a clear plastic shield that covers the forehead, extends below the chin, and wraps around the sides of the face.

• “Fully vaccinated individual” means an individual has received both doses of a two-dose COVID-19 vaccine or one dose of a single-dose vaccine and at least 14 days have passed since the individual’s final dose of COVID-19 vaccine, Source: OHA372705182021"


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