On Friday, December 17 the Sixth Circuit  'dissolved' the stay previously issued by the Fifth circuit, regarding OSHA's vaccine mandate. This means that technically, employers have until *January 10th to implement a vaccine mandate for all employees reporting to a physical worksite, or a weekly testing option.

*Note that the end of the stay makes the ETS effective immediately, however the DOL has announced it will not enforce the mandate against employers until January 10th.

Employers with 100 or more employees should work in good faith to comply with the law, understanding it is possible we will see yet another change to the status of the mandate early in 2022.