Rippling's Legal Team on OSHA's New Requirements—and How We Automate Compliance

Find out what you need to know about OSHA's newest requirements, and discover how to stay in compliance automatically.


Vanessa Wu

General Counsel


Sarah Bloom

Employment Counsel


Charlie Ng

Manager, HR Solution Consulting


Key Takeaways


In November 2021, OSHA announced new COVID requirements for businesses.

It imposed a number of new requirements surrounding masks in the workspace, proof of negative tests, time off for vaccinations, and more. The Emergency Temporary Standard (ETS) applies to employers with 100+ employees, and penalties start at $13,653.


Businesses have policy decisions to make

Businesses must decide how they comply with OSHA's ETS. There is flexibility, like requiring vaccines or just offering regular testing. For example, vaccines for remote workers are not mandatory, but several companies have vaccine mandates anyway. In the end, businesses must consider what matches the objectives of the company.


Businesses should automate OSHA compliance to not slow the company down.

Rippling makes it easy to operationally collect and enforce vaccination policies. Admins can add a required custom field for vaccination status, create a custom vaccination time off policy for US-based employees, and even integrate vaccination status with third-party door access control systems.


You're supposed to keep this information as confidential medical records, which means it needs to be kept in a separate file electronically. There needs to be certain security provisions and access restrictions around that data.

Vanessa Wu

General Counsel at Rippling

The ETS is the floor that all employers must comply with, but employers do have the flexibility to go above the ETS and impose additional requirements. This is something we've been thinking about a lot as it pertains to our remote workforce.

Sarah Bloom

Employment Counsel at Rippling

It's really important that this information be easily accessible, because OSHA requires that employers produces information under the ETS like proof of vaccination and the roster.

Sarah Bloom

Employment Counsel at Rippling

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