In its first indication of upcoming policy changes under the new administration, last week the federal Occupational Safety and Health Administration issued updates to its COVID-19 infection prevention guidance. Among other things, the guidance urges employers to continue enforcing mask, social distancing, and other control measures even after employees have received a COVID-19 vaccination. The guidance cites CDC warnings that current studies have not determined whether vaccinated people can pass the COVID-19 virus to unvaccinated ones.

In addition to substantive recommendations, the guidance appears to set the stage for a widely anticipated emergency COVID-19 safety standard from OSHA. This includes recommendations on involving employees in the development and implementation of workplace safety measures, as well as adopting clear anti-retaliation policies for employees who complain about coronavirus-related issues. While only recommendations for now, these steps may be incorporated into an upcoming mandatory standard.