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COVID-19 Workplace Safety Guidance Issued for Federal Contractors and Subcontractors Imposes Major New Employee Vaccination and Other Requirements

On September 24, 2021, in response to the Path Out of the Pandemic: COVID-19 Action Plan announced by President Biden on September 9, and Executive Order 14042, Ensuring Adequate COVID Safety Protocols for Federal Contractors (the “Order”), signed by the President the same day, the Safer Federal Workforce Task Force (“Task Force”) issued “COVID-19 Workplace Safety: Guidance for Federal Contractors and Subcontractors” (“Guidance”). The Guidance, which the Director of the Office of Management and Budget approved, is intended to ensure that COVID-19 safeguards are provided in workplace locations with individuals working on or in connection with a Federal Government contract or contract-like instrument.

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