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OSHA Updates FAQs to Clarify that Booster Shots Are Not Included in Definition of “Fully Vaccinated” for Purposes of COVID-19 ETS

The Occupational Safety and Health Administration (OSHA) updated its Frequently Asked Questions regarding the COVID-19 Vaccination and Testing Emergency Temporary Standard (ETS) to address questions about booster vaccine shots under the ETS.

Specifically, Question 4.E. on OSHA’s FAQs states:

“Some of my employees are eligible for a booster shot or additional doses of the vaccination. Am I required to collect or maintain information for these additional doses?”

OSHA responds that:

“Employers are required to determine the vaccination status of each employee, including whether the employee is fully vaccinated. Booster shots and additional doses are not included in the definition of fully vaccinated under the ETS. Therefore, the employer is not required to obtain vaccination-related information beyond what is considered necessary to demonstrate that the employee is fully vaccinated as defined by the ETS.”

The full list of FAQs is available via OSHA’s website here.

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