On Sept. 9, 2021, President Biden issued his Executive Order on Ensuring Adequate COVID Safety Protocols for Federal Contractors (EO), mandating vaccines for all federal employees and covered federal contractor employees. Although the respective agencies are expected to promulgate guidance and rules effectuating the EO, which will become effective Oct. 15, 2021, the Safety Federal Workforce Task Force has given guidance as to protocols federal contractors should follow, building on the prior government safety protocol directive. Until federal contractors are contractually required to be vaccinated, contractors should note the following safety protocols for their employees who are not yet fully vaccinated or decline to provide information about their vaccination status.

The Task Force has advised agencies with onsite contractor employees as follows:

  • Onsite contractor employees not part of an agency testing program must provide proof of a CDC-approved negative COVID-19 test from no later than the previous three days before entry into a federal building;
  • Onsite contractor employees regularly tested pursuant to an agency testing program do not need to provide proof of a negative COVID-19 test no later than the previous three days prior to entry into a federal building, unless required to do so by the agency testing program; and
  • Federal contractor employees working on site should regularly complete virtual or in-person health checks, the information gathered from which will be used to assess the individual’s risk level and to determine whether the individual should be allowed entry to the workplace.