So, a few of my colleagues and I have been wagering how long it would take the federal Department of Labor’s OSHA folks to prepare an initial draft of a regulation to implement President Biden’s private sector vaccination order. I won. (I said it would be before October 15, 2021.)

Late yesterday, OSHA sent an emergency temporary standard to the White House for review. Once approved by the Office of Information and Regulatory Affairs (which can happen anytime), the standard will be immediately effective. What does the standard say? We don’t know. We likely won’t know until it’s approved. But it’s coming.

Then Cal/OSHA will have 30 days to adopt a standard that is at least as effective as the OSHA standard.

Stay tuned.

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